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?
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).
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.
The FocusCalm application collects data in two ways:
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:
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 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.
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.
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.
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.
PLEASE NOTE THAT IF YOUR PHONE PLAN DOES NOT INCLUDE FREE TEXT MESSAGES, YOU MAY GET CHARGED BY YOUR PHONE COMPANY
Verification of users prior to using Focus Calm for the first and each subsequent login.
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.
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.
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 firstname.lastname@example.org