Privacy Policy

Effective: June 19, 2019

Please also refer to our Terms and Conditions.

Introduction

Brain Power, LLC, including its affiliates, partners, research collaborators, and subcontractors (“Brain Power”, “we”, “our”, “us”) is a research-driven company with the core mission of applying the newest in neuroscience research and leading-edge technology to alleviate the burden and empower the lives of differently-abled people with challenges related to their power minds or minds.

Brain Power’s products and services such as those from time to time known as The Brain Power Autism System, Empower Me, Empowered Brain, PRISMS, REGAIN, Brain Buddy, Brain Guard, Learning Eye, Fidgetology, BodyMetrics, Bodyprint, Mind Power, Brain Cloud, Meducation, Augmental, Interactome, and others* (collectively, the “Platform”) are sets of software and accompanying hardware, comprising apps for wearable devices, apps for mobile / portable devices, algorithms, web data portals, and/or data stores. Brain Power also operates world wide web sites including my.brain-power.comwww.brain-power.com, related sites, and newsletters or mailings to those who visit these sites (collectively, the “Site”).

 We are committed to the privacy and security of your personal data. This document (the “Agreement”) is a statement of our Privacy Policy governing the use of the Site and the Platform by you. The Agreement outlines the types of information we collect from you, how such information is analyzed and used by Brain Power, and how it is shared with other third parties, including, but not limited to, research institutions, universities, and affiliated entities (“Partners”).  For the purposes of the Agreement, you (“you”, “the user”) may be a natural person or a group of natural persons of any age. You may also be an entity or affiliation-group that includes persons of any age, such as a school, classroom, clinic, family, marital community, church, parents’ group, meetup group, support group, advocacy group, therapy group, employer, corporation, research community, veterans’ group, or other group or entity.

By accessing or using the Site or the Platform, you agree to the policies stated in this Agreement. If you register on the Site or with the Platform you thus become a “Member”, and in addition to the policies that are applicable to all users of the Site or Platform, the policies that apply only to Members shall apply to you. You agree to obtain consent to the policies in the Agreement by persons in your group or beyond who may be impacted by your use of the Site or Platform, including where data about them may be gathered by the Site or Platform.

 Brain Power researchers may use the Site or Platform to create collective knowledge about brain development, education, behavior, health, technology, assessments, diagnostics, or treatments. We fundamentally believe that success in achieving these goals depends on a shared belief between Brain Power and you in working together to develop new strategies for improving the livelihood of all users present and future. In this Agreement, we strive to outline some of the benefits and risks associated with using the Site and Platform, including those related to privacy.

If you do not accept the terms of this Agreement, you may not use the Site or the Platform.

We reserve the right to modify this policy at any time, without prior notice, by posting an amended Privacy Policy and Terms on this website. We encourage you to review this policy periodically for any updates. 

* All product and service names listed herein are trademarks of Brain Power.

 

What kind of information we collect – Restricted Data

Some of the information that your may enter when registering or using the Site or Platform will not be shared as broadly (“Restricted Data”). The type of Restricted Data that you may submit in the Platform may include:

• Name, e.g. collected as part of registration or in a Member’s Account Information

• Email address, e.g. collected and verified as part of registration or in a Member’s Account Information

• Password, e.g. stored as part of registration or in a Member’s Account Information

• Mailing address, e.g. collected via email, forms, or private message to complete shipments or provide other support

• Date of birth

• Private messages

Personal Information such as name, email, password, physical address, and date of birth, when entered as part of registering to be a Member or maintaining your account information, shall be treated at Restricted Data. 

What kinds of information we collect – Shared Data

Some of the information that you provide about yourself through the use of the Site or the Platform may be shared with Brain Power (“Shared Data”). Examples of Shared Data include:

• Biographical information, e.g. photograph, biography, gender, age, location (city, state and country), and general notes

• Condition/disease information, e.g. diagnosis date, first symptom date, symptom list, and family history

• Treatment information, e.g. treatment start dates, stop dates, dosages, side effects, and treatment evaluations

• Symptom information, e.g. severity and duration

• Images and video, e.g. photographs, video recordings, audio recordings, 3-dimensional and multidimensional records, and other likenesses

• Primary and secondary outcome measures, e.g. ADOS, ABC, SRS-2, SCQ, other clinical behavioral assessments, quality of life, etc.

• Progress in the games and applications, e.g. game scores, achievements, levels

• Movement sensor information, e.g. macroscopic movements and gestures, microscopic movements, and repetitive or oscillatory movements, for instance as detected by accelerometers, gyroscopes, magnetometers, and other related sensors. 

• Physiological measures, e.g. heart rate, heart rate variability, breathing dynamics, eye blink dynamics, etc

• Location, as detected by use of devices on networks

• Genetic information, e.g. information on individual genes and/or entire genetic scans

• Individual and aggregated survey responses

• Information shared via free-text fields, e.g. the forum, treatment evaluations, surveys, annotations, journals, feeds, adverse event reports

• Connections to other people on the Site or Platform, e.g. invited care team member, mentors, feeds, subscriptions.

In the course of using the Site or Platform, you may share information that could be used to reasonably identify you (“Personal Information”), including name, photograph, video, phone number, and email address. When you choose to share Personal Information via a web form or similar input method (e.g. comments field in a sign-up form for our website or mailing list, free-test field in a sign-up or application form on our Site, technical support forum, treatment evaluations, document annotations, feeds, or adverse event reports), the information shall be treated as Shared Data.

How and Why Shared Data are Used

In addition to serving the individual needs of our Members, Brain Power is interested in better understanding the end-user experience and improving our services and understanding of the brain, for everyone. For example, we may address research questions such as, “Do certain applications work better for some groups of individuals versus others?” or “Which method of feedback or reward best reduces your signs of anxiety such as heart rate, shallow breathing, and words that relate to stress?” or “What are the data-driven subtypes of autism?” or “How stressful is eye contact for certain groups of people, and can predictable, engaging games help reduce the stress to a comfortable level?”, as illustrative examples of research questions. Brain Power may use Shared Data or at times Restricted Data for internal scientific research in order to address such questions.  Brain Power may provide Shared Data, in individual and aggregate format, to Partners and other third parties for use in scientific research and market research. When providing this information, Brain Power provides Shared Data not data collected as Restricted Data.  

Brain Power may also periodically ask Members to complete short surveys about their experiences (including questions about products and services). Survey responses may be analyzed, combined with Members’ Shared Data, and shared with and/or provided to Partners. Member participation in these surveys is not required, and refusal to do so will not impact a Member’s experience on the Site or with the Platform.

How and Why Restricted Data are Used

Restricted Data will not be automatically shared with, sold to, or displayed for other Members or Partners.

Illustrative instances where Restricted Data may be used include, but are not limited to, the following:

• If we have your permission, your email address will be used to send you a variety of notifications, including research-study invitations, newsletters, and direct messages. You may change this setting by clicking the unsubscribe link at the bottom of emails sent to large groups, or in some cases by changing settings in your account if you are registered as a Member.

• If you explicitly opt in for this, we may share your Restricted Data with a Partner (for instance, co-registration with a non-profit organization, or cross-registration for a scientific research study at a local university)

• If you agree to participate in a media interview (as arranged by Brain Power), Brain Power will share your contact information (e.g. name, email, telephone) with the reporter for the purpose of conducting an interview.

• Restricted data may be used to guide our scientific research and our development of new products and services that may assist you or others similar to you, though the Restricted Data will not be distributed as part of those products and services.  

External Publication of Data

Brain Power was founded by a scientific researcher with a doctoral degree (PhD) in neuroscience, and we continue to have a focus on scientific research – more so than most education companies.

Importantly, at Brain Power we believe in conducting research for reasons that include producing evidence-based products that serve our customers, as well as producing general knowledge that can serve all people. The general knowledge may for instance relate to how the brain works, how our minds can sometimes struggle, and how we can best surmount these struggles. 

In order to produce this type of general knowledge, we follow the best practices of the professional research community, for instance the biomedical research community.  

Brain Power publishes some of our research in peer-reviewed research journals, including open-access (freely accessible online) journals. You can read more at www.Brain-Power.com/Research.

The research that we publish in peer-reviewed journals is conducted under strict ethical and regulatory guidelines and supervision of an internationally compliant and accredited supervisory body known as an Institutional Review Board or IRB. Brain Power research controlled by an IRB is continuously reviewed and controlled by strict application process and subsequent audit. Control includes all aspects of the research, study design, recruitment procedures for human participants, informed consent of human participants, data privacy and security, record-keeping, reporting, and publication. Our research data and records are kept permanently under data retention and protection procedures that are stipulated under IRB and related regulations, and are reviewed every year by full-time and certified staff members of the IRB organization during on-site audit visits. In these ways, data destined for publication in peer-reviewed journals are acquired and kept under strict, international ethical regulations. 

Brain Power does not conduct any animal research or any research involving non-human animals. 

Other Security issues

Brain Power cannot guarantee the identity of any Member with whom you may interact in the course of using the Site or Platform, or who may have access to your Shared Data by using the Site or Platform. Additionally, we cannot guarantee the authenticity of any data that Members may provide about themselves.

Brain Power will cooperate with police to the extent required by law. However, if the data we collect indicate or suggest the commission of a crime, we cannot guarantee that the crime will be investigated by the police or by us.

Brain Power takes commercially reasonable technical precautions to help keep your data secure. Your privacy and data security are extremely important to us, and we take them very seriously. We practice data security and privacy procedures that are reasonable in our field. 

Risks and benefits

While our goal is to help better understand how people’s brains and minds develop and flourish, there are no guaranteed benefits to using this Site or Platform. However, keeping track of personal well-being, treatments, and symptoms has been shown to be helpful in improving overall health.

There are also no known significant risks to using the Site or Platform. There is a possibility that you may feel uncomfortable sharing information. In using the Site or Platform, you are free to skip any non-required questions or data fields that make you feel uncomfortable. You are also free to stop using the Site or Platform at any time. If a Member chooses to deactivate her/his account, Brain Power will not display the data from that account after the date of deactivation. However, the Member’s data will remain in the system for auditing purposes and future research; and research conducted prior to the deactivation of the account will still include the Member’s data.

You Have No Obligation to Use our Site or Platform, or to Be a Member

Using the Site or Platform is elective and optional, as is becoming a Member. Brain Power is committed to assisting and empowering those with challenges of the brain or mind and our actions are intended to assist current and future users and Members. However, if you are not comfortable with our Privacy policy, Terms, or other policies at any time, you are free to decline to use our Site or Platform, and/or to withdraw from Membership. We would of course be interested to hear from you if you care to share your reasons since we are committed to adding value and improving how we empower people, but you have no obligation to communicate with us in this way.  

Questions about the Privacy Policy

If you have questions or comments about our Privacy Policy, please let us know by email at privacy@brain-power.com, or by postal mail at:

Brain Power, LLC
Attn: Privacy Issues
245 Main Street, 11th Floor
Cambridge, MA 02142

 

Thank you, and as always, Stay Empowered!

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