Privacy Policy
Last updated: June 13, 2024
This Privacy Policy applies to Zentopia products, services and websites (the “Platform” or “Zentopia”), which include OxyZen, FocusZen devices and other applicable Zentopia-related devices (collectively the “Zentopia Device”) and associated applications, websites, software and related services accessed via any platform or device that link to this Privacy Policy. The Platform is provided and controlled by BrainCo Inc. (“BrainCo”, “we” or “us”). We are committed to protecting and respecting your privacy. Please read our Privacy Policy below, which explains how we collect, use, share, and otherwise process the personal information of users, especially the highlighted or bold contents.
If you have any questions or concerns, we can be reached by our contact information below.
Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service.
We may collect information from and about you, including information that you provide, information from other sources, and automatically collected information (the “Information We Collect”).
When you create an account, upload content, contact us directly, or otherwise use the Platform, you may provide some or all of the following information:
· Account information, such as account identifier, username, password, email, phone number, CAPTCHA, and social media account information.
· Personal profile information, such as nickname, age, date of birth, gender, and profile image. Factors like age and gender are used to improve and customize your user experience.
· Zentopia data, including but not limited to sensor data, processed data and activity data. Sensor data is collected through Zentopia Devices, such as electroencephalogram (EEG) data, neural response data, and EEG meditation data. Processed data means data such as heart rate, heart rate variability (HRV), and breath rate which is generated by processing sensor data. Activity data, such as progress, trends, achievements over time, and session start and end times collected by us via Zentopia Devices based on your activity. This information is collected to ensure the functioning of Zentopia.
· Information, including text, images, and videos, found in your device’s clipboard, with your permission. For example, if you choose to initiate information sharing with a third-party platform, or paste content from the clipboard onto the Platform, we access this information stored in your clipboard in order to fulfill your request.
· Your choices and communication preferences.
· Information to verify an account such as proof of identity or age.
· Information in the correspondence you send to us, including when you contact us for support.
· Information you share through surveys or your participation in challenges, research, promotions, marketing campaigns, events, or contests such as your gender, age, likeness, and preferences.
· To provide you with the Service, we need to access the Internet and require the following permissions: Camera (to take photos or sweeping shots, and to participate in Platform activities with your authorization), Storage (to store photos and read photos from the local storages), Notification (to access reminder for training), Bluetooth (to enable connectivity of Zentopia applications and devices), Location (to better connectivity of Zentopia applications and devices) and Phone (to ensure the uniqueness of CID (Personal Push message push SDK target ID)). You can manage the permissions on your device by going to app Permissions under system Settings.
We may receive the information described in this Privacy Policy from other sources, such as:
· If you choose to sign-up or log-in to the Platform using a third-party service such as Google or Apple, or link your Zentopia account to a third-party service, we may collect information from the service. For example, your public profile information (such as nickname), email.
· Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your Zentopia account.
· We may obtain information about you from certain affiliated entities within our corporate group, including information about your activities on their platform.
· We may receive information about you from others, including where you are included or mentioned in direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us.
· We may also collect or receive information about you from organizations, businesses, people, and others, including, for example, publicly available sources, government authorities, professional organizations, and charity groups.
We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your IP address, geolocation-related data, unique device identifiers, browsing and search history (including content you have viewed in the Platform), and Cookies.
· Usage Information. We collect information about how you engage with the Platform, including information about the content you view, the duration and frequency of your use, your engagement with other users, your search history and your settings.
· Device Information. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we will be able to use information such as your device ID and user ID to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.
· Location Data. We collect information about your approximate location, including location information based on your SIM card and/or IP address. We may need to access your Location Data during its use in order to enable Bluetooth connectivity; however, we do not store this Location Data.
· Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences, for example, to keep the Platform safe, for content moderation and, where permitted, to serve you personalized ads based on your interests.
· Cookies. We, our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, provide you with advertising, and measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.
We may link your contact or account information with your activity on and off our Platform across all your devices, using your email or other log-in or device information. We may use this information to display advertisements on our Platform tailored to your interests, preferences, and characteristics.
WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF OUR SERVICE PROVIDERS AND BUSINESS PARTNERS, AND THE INFORMATION PRACTICES OF THESE SERVICE PROVIDERS AND BUSINESS PARTNERS ARE NOT COVERED BY THIS PRIVACY POLICY.
We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.
As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.
We generally use the Information We Collect:
· To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
· To customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you have liked or interacted with.
· To send promotional materials from us or on behalf of our affiliates and trusted third parties.
· To improve and develop our Platform and conduct product development.
· To measure and understand the effectiveness of the advertisements we serve to you and others and to deliver advertising, including targeted advertising, to you on the Platform.
· To make suggestions and provide a customized ad experience.
· To understand how you use Zentopia, including via Zentopia Devices or across your devices.
· To infer additional information about you, such as your age, gender, and interests.
· To help us detect abuse, fraud, and illegal activity on the Platform.
· To promote the safety and security of the Platform, including by scanning, analyzing, and reviewing messages for violations of our Terms of Service, or other conditions and policies.
· To verify your identity in order to use certain features to ensure that you are old enough to use the Platform (as required by law), or in other instances where verification may be required.
· To communicate with you, including to notify you about changes in our services.
· To enforce our Terms of Service and other conditions and policies.
· Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.
· To train and improve our technology, such as our machine learning models and algorithms.
· To combine all the Information We Collect or receive about you for any of the foregoing purposes.
· To facilitate sales, promotion, and purchases of goods and services and to provide user support.
· For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
We are committed to maintaining your trust, and while we do not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising where restricted by applicable law, we want you to understand when and with whom we may share the Information We Collect for business purposes.
We share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes, including research, payment processing and transaction fulfillment, database maintenance, administering contests and special offers, technology services, deliveries, sending communications, advertising and marketing services, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, and data processing. These service providers and business partners may include:
· Payment processors and transaction fulfillment providers, who may receive the Information We Collect but who do not receive your message data.
· Customer and technical support providers, who may receive the Information We Collect.
· Researchers who may receive the Information We Collect but would not receive your payment information or message data.
· Advertising, marketing, and analytics vendors, who may receive the Information We Collect but would not receive your payment information or message data.
· Other wellness applications: We may provide you with the option of integrating Zentopia with applications such as Apple Health or Google Fit in order to help you track your progress. If you direct us to connect Zentopia to applications such as Apple Health or Google Fit, we will access and import certain data from such applications (in accordance with your privacy settings in such applications) such as meditation minutes and heart rate, and we will transfer certain data to such applications, including Zentopia Data, session reminders, and your meditation goals. You can turn off the connection to such applications at any time in the settings of our Products. WE RECOMMEND THAT YOU REVIEW THE PRIVACY POLICY OF THE THIRD-PARTY PROVIDER OF THE APPLICATION AS THIS WILL, AMONGST OTHER THINGS, COVER WHAT HAPPENS TO ANY INFORMATION THAT IS SHARED WITH THE PROVIDER OF THE APPLICATION AFTER THE CONNECTION IS TURNED OFF.
As a global company, the Platform is supported by certain entities within our corporate group, which are given limited remote access to Information We Collect as necessary to enable them to provide certain important functions.
We may share all of the Information We Collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy.
Some of the information that you share with us or that we collect about you may not by itself identify you to us or be personally identifiable and therefore may not be considered personal information. We may also remove personal identifiers from your information to render such personal information non-identifiable. This includes Zentopia Data and in-app surveys. We maintain and use it as de-identified data, and may combine such de-identified data with other information to generate aggregated data. We use such de-identified and/or aggregated information to help us improve our product and service offerings, and may also provide de-identified and/or aggregated data to researchers in connection with research programs.
We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, researchers, copyright holders, or other third parties if we have good faith belief that it is necessary to:
· Comply with applicable law, legal process or government requests, as consistent with internationally recognized standards,
· Protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
· Investigate potential violations of and enforce our Terms of Service, or any other applicable terms, policies, or standards, or
· Detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.
We may share your information for other purposes pursuant to your consent or at your direction.
We partner with third-party services (such as Google, Apple) to offer you a seamless sign-up, log-in, and content-sharing experience. We may share information about you with these third-party services if you choose to use these features. For example, the services may receive information about your activity on the Platform and may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.
You may submit a request to know, access, correct or delete the information we have collected about you at by sending your request to the email address provided in the “Contact Us” section below. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. You may also exercise your rights to know, access, correct, delete, or appeal by sending your request to the email address provided in the “Contact Us” section below. You can also update your account information directly through your in-app settings, as well as request to deactivate or delete your account. If you request to delete your full account, click Terms and Conditions on Deletion of Zentopia Account for detailed instructions. Your right to know includes what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom we share the personal information, and the specific pieces of personal information we have collected about you. We do not discriminate based on the exercise of any privacy rights that you might have.
You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.
If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. To submit a request, contact us by sending your request to the email address provided in the “Contact Us” section below.
While some of the information that we collect and use may constitute sensitive personal information, we only process such information in order to provide the Platform and within other exemptions under applicable law.
· You may be able to control some of the Information We Collect through your device browser settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you. Without this information, we are not able to provide you with all of the requested services.
· You may have certain rights with respect to our processing of your personal information. Subject to applicable law, you may have the right to: (1) request access to the information we hold about you; (2) request that we update, correct, or amend your information; (3) request that we erase your information; or (4) request the restriction of our use of your personal information. In addition, and subject to applicable law, you may receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us about you with your consent or based on a contract with us. In appropriate circumstances, you have the right to have this information transmitted to another company, where it is technically feasible. You also may object at any time to the use of your personal information, on grounds relating to your particular situation, where we use that information based on our legitimate interests as described above. You also may withdraw any consent you previously provided to us, e.g., by deleting any user account you have in connection with Zentopia or by contacting us by sending your request to the email address provided in the “Contact Us” section below. If you do so, this will not affect the lawfulness of our use of your information based on your consent before its withdrawal. Please note that if you revoke your consent to use certain data, you may not be able to use Zentopia or certain features or functionality of Zentopia. If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and provide you with the requested information. If you are located in the EEA, please include “GDPR” in the subject line of your communication with us to help us direct your inquiry. We will respond to your request within a reasonable time and at minimal or no cost to you in accordance with applicable laws.
· If you have registered for an account, you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.
We use reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. PLEASE NOTE THAT INFORMATION COLLECTED BY THIRD PARTIES MAY NOT HAVE THE SAME SECURITY PROTECTIONS AS INFORMATION YOU SUBMIT TO US, AND WE ARE NOT RESPONSIBLE FOR PROTECTING THE SECURITY OF SUCH INFORMATION.
We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.
The retention periods are different depending on various criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service or other conditions or policies, we may remove your profile immediately, but we may keep other information about you to process the violation.
Your personal information may be collected, used, processed, transferred, and retained by us, our affiliates and our service providers in multiple countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside the EEA and Switzerland which have not been recognized by the European Commission as providing for such a level of protection. In all such cases, we will only transfer your personal information if we have put in place appropriate safeguards in respect of the transfer, including by selecting U.S. service providers that are certified to the EU-U.S. and/or Swiss-U.S. Privacy Shield frameworks or by executing data transfer agreements with our service providers based on the European Commission’s Standard Contractual Clauses in accordance with Articles 45 and 46 of the EU General Data Protection Regulation (GDPR) respectively. You may obtain a copy of the safeguards we use in respect of such transfers by contacting us by sending your request to the email address provided in the “Contact Us” section below.
We understand the importance of safeguarding the personal data of children, whom we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction (“Children”).
The Platform otherwise is not directed at Children. We do not knowingly collect or solicit any personal identifiable information from Children except in compliance with any applicable laws and regulations (such as the Children’s Online Privacy Protection Act, “COPPA”). Children are prohibited from using the Services or creating an Account unless they are doing so with parental consent or with the consent of a teacher, school, or district who is providing such consent in compliance with COPPA. If we become aware that we have unknowingly collected personal information on the Platform from a Child, we will delete this information and terminate the Child’s account. If you believe there is a user who is below the age of 13, please contact us by sending your request to the email address provided in the “Contact Us” section below.
We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.
If this Privacy Policy is translated in a language other than English, to the extent of any conflict between the English version and the translated version, the English version will prevail.
Questions, comments and requests regarding this Privacy Policy should be addressed to:
· Email: general@brainco.tech
· Mailing Address: 120 Beacon St, STE 201, Somerville, MA, 02143 USA