FocusCalm Privacy Notice - FocusCalm

BrainCo FocusCalm Website Privacy Policy Notice

A BrainCo Marketing Interface

Version: 1.0 dated April 26, 2021

BrainCo develops applications and devices that collect data to improve learning processes and/or train attentive relaxation abilities both at home and school. Our Focus Calm introduces our you to our brain-sensing 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 communicate to us whether you would like to get further information in the near term or whether you would like to get continual updates. It also allows you to make purchases.

This privacy notice provides information on how our website processes data and is organized into eight sections:

  1. Purpose of Data Processing
  2. How We Get Data
  3. Data We Process
  4. Legal Basis for Data Processing
  5. Use of Data After Processing
  6. Rights of the Individual
  7. Contacting BrainCo
  8. Updates to this Privacy Policy Notice

1. Purpose of Data Processing

We want our website to meet our site vistor’s needs. As a result we collect information that tells us about how you use our website, we do this through cookies. Also, we have forms where you can provide us information for us to contact you. We also have features where we can chat with you in realtime and for you to make purchases of our products.

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 sites performance and cookie based information is shared for a visitor each time they visit.
  • Through direct entry by you as the visitor

3. Data We Process

CategoryDirect/Indirect Personal DataDescriptionPurpose
Third Party Processors
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.
CookiesIndirectThis 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 InformationDirectWe collect information such as name, and contact information (first name/ last name/ 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.
ChatDirect and IndirectWe 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.
PurchasesDirectWe 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 QuestionnaireIndirectThis 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

  • All of the data that we collect on our website requires the consent of the visitor.
    • We ask for you to allow us to use cookies when you visit our site.
    • We ask for your permission to use data that you provide us through the submission of forms.
    • We ask your permission to engage in a chat
    • We require you to authentication your identity when making a purchase.
  • Our website is geared to audiences age 18 and above. For those under the age of 18, data is not collected directly and is not intended to be collected indirectly.

5. Use of Data After Processing

The data retained through the data collection methods above vary from a month to an a period of fifteen years. Data for chats and saved for about a month where as form information that you provide is kept longer to continue to provide information as you have consented for us to do. Purchase information is retained as a proof of purchase as required by the laws of location of the customer making the purchase.

6. Commitment to the Non-Sale of Data

BrainCo does not sell your data to anyone.

7. 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.

8. Contacting BrainCo

Questions about how personal data is processed, used, and stored can be directed to the Data Protection Officer:

9. Updates to this Privacy Policy Notice

BrainCo reserves the right to change this privacy policy notice as needed. Notification of changes will be posted on our website www.focuscalm.com

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