BrainCo FocusNow Privacy Policy Notice

A BrainCo Digital Application

Version: 1.0 dated March 31, 2020 

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 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.

This privacy notice provides information on how the FocusNow application 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

      The FocusNow application processes data retrieved through the BrainCo headband and calculates the levels of attentiveness an individual has to help improve their ability to concentrate, increase productivity and enhance skills to aid in relaxation.  

    2. How We Get Data
      • Data is received from the headband and from data that entered into the application by the user. 
      • Each time that the application is used data is retrieved from our servers to provide historical data and to make sure that a users account is accessed in a secure manner. 
    3. Data We Process
    4. Category Relation to Person Description Purpose
      Profile Information Directly We collect information about the individual using the application such as a nickname the user assigns themselves, gender, date of birth, and email address. The application will assign a userID that connects to an email address entered. We store all data in this category on both the application on the user’s smart device and in BrainCo’s cloud based servers. Users also have the option of uploading a picture to the app. This picture is stored on the local version of the app and is not sent o BrainCo’s servers. 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) Directly EEG data received from the BrainCo headband is transmitted to the FocusNow application. All EEG data remains in the FocusNow 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.
      Course and Training Plan Indirectly Information relative to the courses the user takes through the application that include: dates and times planned and engaged, the courses selected, digital awards, levels of attentiveness achieved and categores of attentiveness levels, as well as changes in attentiveness levels from one session of use to another.  


    5. Legal Basis for Data Processing
      • BrainCo processes data through the FocusNow application for clients as outlined in FocusNow terms of service.
      • By using the FocusNow application, the user is agreeing to the processing of their personal data on behalf of the user.
      • BrainCo will not process data for anyone under the age of 13 years of age.
    6. Use of Data After Processing
      • All the data collected and processed, with the exception of EEG data pictures, is stored on BrainCo’s servers.
      • BrainCo does not sell data to any individual or entity.
      • BrainCo intends to store the data processed at least 15 years.
    7. Rights of the Individual
      • Right to Know: BrainCo will keep you informed of any changes to this privacy notice and you may reach out to us 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 the FocusNow application 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 the FocusNow 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 seven below.
      • Right to Data Portability: Users of FocusNow 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 seven below.
      • Right to Rectify: If the user of FocusNow 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 FocusNow 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 or BrainCo Privacy, 120 Beacon Street, Suite 300, Somerville MA, 02143 USA

    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 the FocusNow website at