Privacy Policy Privacy Policy Last Updated: April 18, 2023

Here at Inc. (“”, “we”, or “us”), we take the privacy and security of your personal information very seriously. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information when you use our application (“App”), software, APIs, devices, products or services, visit our website located at (the “Website”), or otherwise interact with us.

OUR PRODUCTS AND SERVICES offers personalized, adaptive brain training systems that are designed to enable you to change your brain state, train your brain, improve cognitive performance, and assess your brain activity. Our headset’s sensors read your brain and heart signals while the App’s software translates these into light stimulation boosts and audiovisual cues. The neurofeedback (real-time audiovisual cues) trains your brain to learn healthy brain states. Data plays an important role in our service offering and helps us add value in three ways; - Adapt our service in real-time; - Guide future development so that we achieve our Visions of ‘A Community of Superconscious People Thriving and Doing Good in the World’; and - Advance science and neurotechnology for the future so that collectively we leave a positive legacy.


We may collect and use personal information when you: - Create an account and/or profile - Use our products or service - Visit the Website - Sign-up to receive marketing emails from us such as newsletters, offers and promotions - Enter a contest or participate in a promotion - Apply for a job at - Participate in our surveys - Contact us with a comment, question or complaint

Create an Account:

You do not have to create an account to visit or use our Website. However, to access certain services on our App and Website, you will be required to create an online account and provide personal information such as your email address and a password that you create. We use this information to create and administer your online account. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

Use our Products and Services:

When you use our services, including our App and hardware devices, we will collect your email address, password, telephone number, and demographic information including date of birth, sex, and gender. We will ask questions and record response on topics including sleep, memory, meditation experience, brain fog, attention, word, stress, agitation, and adaption to change.

Device-Specific Information:

When you use our products, such as our headsets, we will collect certain health or behavioural information such as your brain activity/engagement, levels of focus and distraction, response to stimuli and heart rate, which our software will analyze. We will also collect information about the position, orientation, and movement of the device while it is in operation. We use this information to provide our services to you, which includes adaptive brain training. Location Information: With your consent, we may also collect your location information by accessing your device’s GPS coordinates so that we can personalize your experience with You can opt-out at any time by turning off your location services for the App either within the App or in the settings of your mobile device.

Push Notifications:

If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with App updates and other relevant information such as reminders to continue on your program. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App either within the App or in the settings of your mobile device. Payment Information: If you subscribe to our services, we (or an authorized third-party payment processor) will collect information such as your first and last name, email address, phone number, mailing address, delivery address, and your payment information (including billing address, credit card number, expiry date and CVV/CVC code) in order to process transactions in connection with your subscription.

Marketing Communications:

If you sign up to receive email marketing communications, we will collect your first and last name, address, postal code, and email address on an optional basis in order to send you newsletters, offers, promotions, and the latest updates that may be tailored to your interests and preferences (including past subscriptions or orders). You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us. We may use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt out of the use of your information for such purposes, please send a request using any of the methods set forth in the Contact Us section below.

App Usage Information & Analytics:

As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on the App, to monitor and improve the App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users. We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers, to clearly disclose what, if any information is collected by the App, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google, Inc., Apple, Inc., or your third-party telecommunications carrier. We are not responsible for the actions of such third parties. You should always read and understand the policies of any third-party provider, such as Google with respect to Android apps and Apple with respect to IOS apps, and your wireless carrier, before making any purchase or downloading any app.


In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Contests and Promotions:

When you enter a contest or participate in a promotion, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you, or that you otherwise provide, including your social media handle, profile picture and public posts or comments you make about our contest on social media networks. We use this information to administer the contest or promotion. As part of a contest or promotion, we may also share or otherwise publish the content you submit. Contact Us: When you contact us with a comment, question or complaint, regarding our products, services, or otherwise through email, telephone, our App or the contact us form on our Website, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and products. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the App and our services and to improve the App and our services.


We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law. Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments, and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the US., Canada or EU.

We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, US or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business:

We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of or as part of a corporate reorganization or other change in corporate control.

Scientific and Medical Research.

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, to clinicians and researchers who are working on neurofeedback and brain health, in scientific articles or reports we produce, or as part of the benchmarking information we provide to users of our subscription services.


Visiting our Website:

In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.


Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.


We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: You can also obtain additional information on Google Analytics’ data privacy and security at the following links: - and -

Our Website may contain links to other websites that does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.


We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our App and Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our App or Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting-out of Interest-Based Advertising:

For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at

Please note that even if you opt out of interest-based advertising by a third-party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt out of each web browser on each device you use. Once you opt-out, if you delete your browser’s saved cookies, you will need to opt-out again.


We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.


As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below. To opt out of interest-based advertising, see the “Interest-Based Advertising” section above.


Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control or withdraw your consent to our collection, use and disclosure of your personal information by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.


We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.


If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to or correction of your personal information, please contact us by e-mail at or by mail using the details provided below: Unit 102 - 4369 Main Street Suite 378, Whistler, BC, , Canada