A BrainCo Marketing Interface
Version: 1.0 dated May 21, 2021
BrainCo develops applications and devices that collect data to improve learning processes and/or train attentive relaxation abilities. In order for our applications and devices to best serve our customers, it is necessary that personal data is collected from each customer to make use of our product. Our products create a personalized experience that uses personal data to provide analysis and insights to the individual customer.
This privacy notice provides information on how the FocusCalm application processes data and is organized into eight sections:
- Purpose of Data Processing
- How We Get Data
- Data We Process
- Legal Basis for Data Processing
- Use of Data After Processing
- Rights of the Individual
- Contacting BrainCo
1. Purpose of Data Processing
The FocusCalm application processes data retrieved through the BrainCo headband and calculates the levels of calmness an individual has to help improve their ability to concentrate, increase productivity and enhance skills to aide in relaxation.
2. How We Get Data
- Data is received from the headband and from data that is entered into the application by the user.
- Each time the application is used data is retrieved from our servers to provide historical data and to make sure that a user’s account is accessed in a secure manner.
3. Data We Process
|Category||Direct/Indirect Personal Data||Description||Purpose|
|Profile Information||Direct||We collect information about the individual using the application such as a nickname the user assigns themselves, gender, date of birth, and email address. The application will assign a userID that connects to an email address entered. We store all data in this category on both the application on the user’s smart device and in BrainCo’s cloud-based servers. Users also have the option of uploading a picture to the app. This picture allows users to personalize the application. The picture is not further processed.||We collect these data to allow the user to secure their app, for the app to authenticate identity for use, and to allow a personal touch to users interacting with the application.|
|Direct||EEG data received from the BrainCo headband is transmitted to the FocusCalm application. All EEG data remains in the FocusCalm application within the user’s smart device and is purged from the application at the conclusion of each use.||We process EEG data to assign metrics that appear on the application to show levels of calmness.|
|Brain Games: These include memory tests and focus test||Indirect||Information is collected as you play the games to obtain your attentiveness and after you are done playing the game you see a score with the number of questions answered correctly and your relaxation level as measured by the headband.||To provide feedback to the user about your attentiveness, and try to identify the user’s feeling of calm.|
4. Legal Basis for Data Processing
- BrainCo processes data through the FocusCalm application for clients as outlined in the FocusCalm terms of service. By using the FocusCalm application, the user is agreeing to the processing of their personal data by BrainCo on their behalf in order for the user to interact with the application.
- BrainCo will not process data for anyone under the age of 13 years of age.
- BrainCo will not process data on behalf of an employer such that any data sharing agreement would allow for said employer to gain access to specific employee data.
5. Use of Data After Processing
- All the data collected and processed, with the exception of EEG data, is stored on BrainCo’s servers.
- BrainCo does not sell data to any individual or entity.
- BrainCo intends to store the data processed for at least 15 years.
6. Rights of the Individual
- Right to Know: BrainCo will keep you informed of any changes to this privacy notice and you may reachout to use with questions regarding how your data is collected, used, and stored. Please contact us as outlined in number seven below.
- Right to File Complaint: If you have any concerns about how your data is being processed by our website or questions about your right to restrict processing (where applicable), please contact us as outlined in number seven below.
- Right to Access: You have a right to access the information that BrainCo stores through our website. Most of this information can be viewed by logging into the application itself. Should you require additional information about what BrainCo is storing, please contact us as outlined in number seven below.
- Right to Data Portability: Users of our website have a right to request any data that is directly connected to them and generated through the application to be provided when requested. Please contact us as outlined in number seven below.
- Right to Rectify: If the user of our website feels that any data that is stored is incorrect and they cannot make corrections on their own, please contact us as outlined in number seven below.
- Right to be Forgotten: Should a user of our website no longer wish to have data previously submitted through the application to be stored by BrainCo, please contact us as outlined in number seven below.
7. Contacting BrainCo
Questions about how personal data is processed, used, and stored can be directed to email@example.com or
120 Beacon Street Ste 300, Somerville MA, 02143 USA