FocusCalm Privacy Notice - FocusCalm

BrainCo FocusCalm Privacy Policy Notice

BrainCo FocusCalm Privacy Policy Notice

A BrainCo Digital Application

Version: 2.0 dated December 7, 2020 

At A Glance

Privacy Notice Content

What is personal data?

Information that can be used to identify someone or can be used with other information to identify someone. 

Do you collect personal data?


Do you store personal data?


Do you process personal data?


Do you sell personal data?


Is data involved in a sales activity with a third party?


Do you recognize that I have rights regarding my data?



In Detail

BrainCo develops applications and devices that collect and process data to improve a user’s ability to concentrate, increase productivity and enhance skills to aide in relaxation. 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 (user).

This privacy policy notice provides information on how the FocusCalm application processes data and is organized into nine sections:

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

The FocusCalm application processes data retrieved through a BrainCo headband and calculates the levels of attentiveness of the user. These attentiveness levels, collected through gaming activity, helps to improve the user’s ability to concentrate, increase productivity and enhance skills to aide in relaxation.  

    1. How We Get Data

The FocusCalm application collects data in two ways:

      • BrainCo proprietary EEG reading headbands
      • Data entered into the FocusCalm application by the user


    1. Data We Process

Data is processed within FocusCalm on the user’s smart device and on our servers. The categories of data that we collect, and process are outlined in the table below. The table is organized into four parts: 

      • Category: This tells the type of data that we are collecting
      • Direct/Indirect: There are generally two ways that the data collected in each category are associated with a person, either directly or indirectly. Directly related means that the data collected, by itself, can identify the user as an individual. Indirectly related means that the data collected are related to a user as an individual but would only be able to be connected to that user if other direct identifiers were also present. 
      • Description: Details regarding the category of data collected are provided.
      • Purpose: An explanation as to the reason why we need to collect this data is provided.






Profile Information


We collect information about the individual using the application. Examples are a nickname the user assigns themselves, email addresses, mobile phone and  (connected to user ID), and profile pictures. 

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 interacting with the application.

EEG Data

Electroencephalogram (EEG)


EEG data received from the BrainCo headband is transmitted to the FocusCalm application. All EEG data remains in the FocusCalm application within the user 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 attention.

Programs and Games


Information is collected as the user plays games within FocusCalm to obtain their attentiveness score. After playing the game the user will see a score with the number of questions answered correctly and the corresponding relaxation level. Games can be played in isolation or as part of a curated Program. Games played within programs have composite scores that show progress across games within the program.

To provide feedback too the user about their attentiveness, and try to identify the users feeling of calm.

Team Portal Info


Two user groups exist witin FocusCalm, standard user and team leader. Team leaders have the additional capability to invite standard users to join a team. This team is managed through the team portal. Standard users are able to grant or remove permission to team leaders and fellow members of a team from seeing their data.

To allow users to build a team based community to help motivate one another and benchmark progress with others.

Third Party Processors

FocusCalm uses third parties to assist with identity verification and management as well as monitoring application performance. Links to Third Party Vendor Privacy Policies Notices are included below. 

Identity Verification


A user can establish a FocusCalm account by using their email. When signing-up this provided email address will be authenticated and verified using the third party vendor: SendGrid. 

Verification of users prior to using Focus Calm for the first time. 

Identity Management


We provide users the ability to use Apple, Facebook, and

Google to login to FocusCalm. The information that these authorizers share with us include a unique code used for authentication and a username. A user provides consent for these authorizers to send data to FocusCalm. 

To make logging into FocusCalm seamless and verify that the user is who they should be. 

Using-Mobile Phone-SMS


A user may sign-up to use FocusCalm using their Mobile Phone Number. Each login by the user will generate and send a secure passcode provided by our third party vendor: Twilio. 


Verification of users prior to using Focus Calm for the first and each subsequent login.

Application Usage


Separate from the data that we use to verify a user’s identity and to process data while using FocusCalm, there is a collection of data regarding the application’s technical performance. Similar to how a website’s performance is monitored, we are doing this for FocusCalm as an application. This data is stored and processed completely separate from user data.

FocusCalm uses the Firebase Applications Crashlytics and Performance to determine the continual security and utility of FocusCalm.

We want to make sure that the user experience is the best one can expect when using FocusCalm. This data collection activity allows us to do this. In the event of a malfunction, we will get information that will tell us how the application failed. We also will get feedback on what aspects of our application is used the most through performance monitoring. This allows us to continually strive for our best to make new features available in the future.

    1. Legal Basis for Data Processing for FocusCalm’s (Consumer) 
      • BrainCo processes data through the FocusCalm application for users 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 application to function.
      • FocusCalm is not meant for use for those under the age of 13. Our data processing activity does not intend to process data for anyone under the age of 13 years of age. 
    2. Location of Data

All data processed by FocusCalm is located in the United States. BrainCo does not transfer data from our Amazon hosted data centers to any other entity worldwide. 

    1. Use of Data After Processing
      • FocusCalm data collected and processed for each user is retained for the purposes of providing histoircal trends for the user to monitor their own progress. 
      • BrainCo does not sell or involve subcontractors in the processing of FocusCalm data.
      • FocusCalm user data is retained for an extended period of time. This retention period allows us to make improvements and maintain a secure environment. 
      • BrainCo anonymizes FocusCalm user data to make application improvements and to study how our customers are utilizing our application. Anonymization of user data involves taking a sample of the user data stored in our cloud-based environment. All of the personal data that directly connects a specific user to this data set is removed so that no one using the data set can identify FocusCalm users directly, creating a non-identifiable data set for use.  
    2. Rights of the Individual
      • Right to Know: This privacy policy notice provides the user an overview of how your data is collected, used, and stored. 
      • Right to File Complaint: If the user has any concerns about how their data is being processed by the FocusCalm application or questions about your right to restrict processing (where applicable), please contact us as outlined in number eight below. 
      • Right to Access: The user has a right to access the information that BrainCo stores through the FocusCalm application. 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 eight below. 
      • Right to Data Portability: Users of FocusCalm have a right to request any data that is connected to them and generated through the application to be provided when requested. Please contact us as outlined in number eight below. 
      • Right to Rectify: If the user of FocusCalm feels that any data that is stored is incorrect and they cannot make corrections on their own, please contact us as outlined in number eight below. 
      • Right to be Forgotten: Should a user of FocusCalm no longer wish to have data previously submitted through the application to be stored by BrainCo, please contact us as outlined in number eight below. 
    3. Contacting BrainCo

Questions about how personal data is processed, used, and stored can be directed in writing to 120 Beacon St, STE300, Somerville, MA, 02143 USA or

    1. 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 the FocusCalm website: