Privacy Policy

1. What is the purpose of this privacy statement?

BrainCo develops applications and devices that collect data to improve learning processes and/or train attentive relaxation abilities both at home and school. In order for our applications and devices to best serve our customers, it is necessary that personal data is collected from each customer in order 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.

Given that personal data is collected, it is important to us to provide this privacy statement that outlines the types of personal data collected, the purpose for collection, how we protect the information that you provide us, as well as, how these pieces are utilized and how to contact us with any questions or concerns you may have regarding the collection of personal data.

2. In general, what are the main ideas outlined in this privacy statement?

  • BrainCo’s devices and applications collect personal data.
  • We collect data from any given person using our devices and applications, including people under the age of 18.
  • BrainCo does not sell personal data collected through our devices or applications to third parties.
  • BrainCo’s devices and applications are not intended to be used in a medical setting, for medical purposes, or for medical diagnosis. All devices and applications are general wellness products as defined by the United States Food and Drug Administration.
  • This privacy statement is intended for our United States based customers.

3. What personal data is collected?

The personal data collected by BrainCo occurs through the use of our devices and/or applications. For individual purchases, the acceptance of our terms of service requires the customer’s consent in order to collect personal data to facilitate the functions provided by our products. Personal data collected includes data elements that are directly and indirectly related to the customer.

  1. Directly Related Personal Data
    1. Provide: The data is used to provide the function and utility of the device/application for the user.
    2. Manage: This data allows BrainCo to monitor, maintain and improve our services.
    3. Create: This data allows BrainCo to create new services.
    4. Data
      Data Element Provide Manage Create
      Age
      Attention Level
      City, State, Country  
      Course ID  
      District ID  
      Dominate Hand
      EEG raw data
      Gender
      Grade Level  
      Head movements
      Impedence  
      Sequence Number  
      Student Name    
      Teacher ID    
      Teacher Name    
      Teacher Presentation
      Teacher’s voice    
      Time stamps    
  2. b. Indirectly Related Personal Data
    1. Provide: The data is used to provide the function and utility of the device/application for the user.
    2. Manage: This data allows BrainCo to monitor, maintain and improve our services.
    3. Create: This data allows BrainCo to create new services.

4. How is personal data collected and where is it stored?

  1. All personal data is collected with the user’s consent, or the consent of the parent/guardian when an individual user is less than 18 years of age. Consent is obtained through the terms of service agreement. The terms of service agreement first appear when a user interacts with our applications for the first time. In some cases where entities, such as school districts purchase our products, an enterprise terms of service agreement may be executed between the entity and BrainCo that outlines how consent will be attained especially for those users who are under the age of 18. No personal data will be collected without the informed consent of an individual or their parent/guardian (in the case where a user is under the age of 18).
  2. Personal data is collected by:
    1. direct input by the user:
      1. at the time of registering their device or accessing an application platform for the first time
      2. when using the device/application
    2. the device itself to perform the functionality outlined in the terms of service.
  3. All personal data collected through, or by using, devices within the United States are stored on servers located within the United States. No individual personal data from the United States will be transferred internationally. Aggregated information generated from sets of personal data may be used in reports and analysis produced by BrainCo. These reports, that contain aggregate information and have been statistically checked to insure the non-identification of any individual user, may be shared with BrainCo’s international network of offices as well as third parties. Any transfer of aggregated information will require a review process to ensure that all laws related to the transfer of aggregate data, if applicable, are accounted for.

5. Are BrainCo’s devices/applications medical devices/applications?

No. As stated in our terms of service, our devices/applications are considered to be “general wellness” devices by the United States Food and Drug Administration. They were not designed to, nor should they, be used as a medical device. No personal health information is collected and none of the data analysis provided by our devices/applications should be interpreted in any fashion as medical advice.

6. What special provisions are in place to protect the personal data of children?

As is outlined in number three of this document, BrainCo considers any user under the age of 18 as a minor requiring the consent of their parent/guardian to be able to use the product. The process for gaining this consent is embedded in our terms of service for each device and application for household-based use. For a school district or other entity that purchase our product for use with groups of users under the age of 18, the enterprise terms of service agreement formed will outline how consent will be obtained from the parent/guardian. Any enterprise-based agreement will include specific safeguards that insure that personal data will not be used or collected for medical reasons.

7. Who will you share user personal data with?

  1. Personal data will be shared with third parties that are under contract with BrainCo to perform a service or function on behalf of BrainCo.
  2. Aggregate data that was generated from personal data and has been statistically reviewed to insure non-identification through its use, may be shared and used by BrainCo with third parties not under contract.
  3. Under no circumstances will personal data be sold to a third party.
  4. Personal data may be required to be disclosed to other parties when required by law or as necessary to protect BrainCo services.
    1. We may disclose personal data to third parties in order to protect the legal rights, safety, and security of BrainCo, our affiliates, business partners, and users of our services.
    2. We may share personal information to enforce our terms of use, resolve claims or complaints, prevent fraud or for risk management purposes.
    3. Personal information may be shared to comply with or respond to law enforcement or legal processes or a request for cooperation from a government or other entity, whether or not legally required.

8. How often will this privacy statement be updated?

We reserve the right to modify this privacy statement at any time by posting revisions to our website. Continued use of BrainCo devices/applications after any modification to the privacy statement constitutes your acceptance of the new terms and conditions.

9. How can I contact BrainCo about questions and concerns related to personal data collected?

BrainCo has established a data protection officer (DPO)for United States based device and application use. The DPO’s role is to ensure that all regulatory and applicable laws related to personal data collection are followed. The DPO, or their designee, serves as the point of contact for our customers to raise questions pertaining to this privacy statement or more specific questions related to personal data collected through our products. Please direct your written questions to:

Mr. Max Newlon, Data Protection Officer

120 Beacon St. STE 201, Somerville, MA, 02143privacy@brainco.tech

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