Privacy Policy
BrainCo FocusCalm Website Privacy Policy Notice
A BrainCo Marketing Interface
Version: 2.0 dated September 7, 2025
BrainCo develops applications and devices that collect data to improve learning processes and/or train attentive relaxation abilities. Our FocusCalm introduces our you to our headband and app that helps you learn how to control your mindset in just a few minutes per day. Our website is interactive and allows you to request further information, subscribe to continual updates, or make purchases.
This privacy policy notice (“Notice”) provides information on how our website 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
- Updates to this Notice
Please refer to our FocusCalm App Privacy Policy regarding how the FocusCalm application processes data.
1. Purpose of Data Processing
We want our website to meet visitors’ needs. Accordingly, we collect information that tells us about how you use our website, primarily through cookies. We also collect information you provide directly, such as through forms, chat, or purchase activities.
2. How We Get Data
Data from the website is received in two general ways:
- By automation. When a visitor comes to our site, data related to the site performance and cookie-based information is shared automatically for a visitor each time they visit.
- By direct entry. Visitors may also provide information directly through forms, chat, or purchases.
3. Data We Process
| Category | Direct/Indirect Personal Data | Description | Purpose |
|---|---|---|---|
All of our website data processes are done by third parties that BrainCo has entered into a contract with to collect, process, and store data on its behalf. The information is stored within these third parties’ platforms. Links to their privacy policy notices are provided. |
|||
| Cookies | Indirect | This is a piece of information that is shared with the server hosting the website by your computer. It allows us to know the type of operating system you are using; the browser used, etc. What is not collected is information directly connected to you as an individual. You will have been prompted at the beginning of your website visit whether you would allow us to collect information through cookies. Third Parties: Google Analytics, Amazon Lightsail |
Cookies allow us to review the performance of the website and know our general audience a little better. |
| Form Information | Direct | We collect information such as name, and contact information ( email/address/phone number) Third Party: Salesforce |
We do this to be able to reach back out to you as you requested when providing us this information for a specific purpose. (Each form declares this purpose). Examples include wanting to get more information or participating in a webinar. |
| Chat | Direct and Indirect | We offer a chat interface on our website to interact with visitors in real time. The information you provide in the chat is retained and is linked to any form-based data that you may provide us. Chats are not used to discuss any personal information other than using your name. Third Party: Salesforce |
We answer product information questions and get you in contact with a member of the team if that interest you to talk further. It is our way to add a more personal touch to your visit to our website. |
| Purchases | Direct | We process information through our third party that includes billing information credit card, name, address, phone, email etc. This information is not combined with our other data that we collect through the website. Third Party: Shopify |
This allows us to process orders for those visitors who wish to purchase our products. |
| Perceived Stress Questionnaire | Indirect | This questionnaire processes data within your web browser and transmits the same aggregate score you see at the end of the assessment to BrainCo. No other information is linked to this assessment aggregate score and BrainCo cannot tell who took the questionnaire or not, nor can we tell if a person takes the questionnaire multiple times. | This allows us to interact with you and pose some questions to think about how our products can help you. |
4. Legal Basis for Data Processing
BrainCo collects and processes personal data from its website visitors only with their consent or as otherwise permitted by applicable law.
- Cookies: When you visit our site, we ask for your consent before placing cookies or similar tracking technologies on your device.
- Forms: When you submit a form, we request your consent to collect and use the information you provide for the stated purpose (e.g., responding to inquiries, sending updates).
- Chat: When you use our chat feature, we request your consent to collect the information you choose to share in order to provide real-time support.
- Purchases: When you make a purchase, we collect and process billing and authentication information as necessary to complete the transaction, comply with applicable financial and consumer protection laws, and prevent fraud.
- Our website is intended for individuals aged 18 and older. We do not knowingly collect personal data from children under 18. If we become aware that data has been inadvertently collected from a person under 18, we will take steps to delete it promptly.
5. Use of Data After Processing
The retention period for data collected through the methods described above depends on the type of information and the purpose for which it is processed. All data is retained only for as long as necessary to fulfill the purposes described in this notice, after which it is securely deleted or anonymized.
- Data for chats is generally retained for approximately a month.
- Form information that you provide is retained for as long as necessary to respond to your requests or to provide ongoing updates, consistent with the consent you have given.
- Purchase-related information, including billing records, is retained as long as required by applicable laws and regulations in the customer’s jurisdiction (e.g., for tax, accounting, and consumer protection purposes).
6. Commitment to the Non-Sale of Data
BrainCo does not sell your data to any third parties. We also do not share personal data for cross-context behavioral advertising or other purposes that would be considered a “sale” under applicable privacy laws. Any data we share with service providers is limited to what is necessary for them to perform services on our behalf, and such providers are contractually obligated to protect your information and use it only for authorized purposes.
7. Rights of the Individual
- Right to Know: You have the right to be informed about how your personal data is collected, used, shared, and stored. BrainCo will keep you informed of any material changes to this Notice. You may also contact us at any time with questions regarding our data practices.
- Right to File a Complaint: If you have any concerns about how your personal data is being processed by our website, or questions about your ability to restrict processing where applicable, you may contact us at any time.
- Right to Access: You have the right to request access to the personal data that BrainCo maintains through our website about you. Much of this information can be reviewed directly by logging into the FocusCalm application. Should you require additional information about what BrainCo is storing, please contact us at any time.
- Right to Data Portability: You may request a copy of the personal data that is directly associated with you in a portable format, to the extent feasible and required under applicable law.
- Right to Rectification: 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. Where possible, you may also update certain information directly within the FocusCalm application.
- Right to be Forgotten: You may request the deletion of personal data you have previously provided, subject to applicable legal and contractual obligations.
8. Contacting BrainCo
Questions about how personal data is processed, used, and stored can be directed to the Data Protection Officer:
- Email: general@brainco.tech
- Address: 120 Beacon St, STE 201, Somerville, MA, 02143 USA
9. Updates to this Privacy Policy Notice
BrainCo reserves the right to change this Notice as needed. Notification of changes will be posted on our website www.focuscalm.com