Data Policy

1. User Information and Data Protection Policy
This privacy policy outlines how Auto Train Brain, Inc., a company registered in the United States, ensures compliance with the California Consumer Privacy Act (CCPA), Federal Trade Commission (FTC) guidelines, and other relevant regulations regarding the collection, processing, storage, and sharing of personal data. By using our services, you agree to the terms outlined in this policy.

2. Personal Data We Collect
Depending on the type of service provided, we may collect the following personal data:

• Username: An alphanumeric identifier that does not disclose personal identity.
• Date of Birth: For age verification purposes.
• Gender: To personalize user experience.
• Email Address: For communication purposes.

3. How We Collect Your Data
Personal data is collected through:

• Direct Interactions: Information voluntarily shared with us (e.g., forms, emails, or in-app data entries).
• Automated Technologies: Usage data, device information, and cookies collected when interacting with our application (see Section 6 for cookie details).

4. Purpose of Data Processing
Your data will be processed for the following purposes:

• Service Delivery: To provide neurofeedback services and perform EEG measurement analysis.
• Legal Obligations: To comply with U.S. laws and FTC regulations.
• Legitimate Interests: To improve services, protect legal rights, or defend in legal proceedings.
  Personal data will be processed for as long as necessary to achieve the specified purpose or as required by law.

5. Sharing Your Data with Third Parties
We may share your personal data in the following cases:

• Healthcare Providers: Anonymized EEG data may be shared with medical professionals for the research and development of new treatments for brain health.
• Data Storage: Personal data may be stored and processed by AWS (Amazon Web Services) in the U.S.
• Third-Party Service Providers: For technical support, cloud storage, or payment processing services.

6. International Transfer of Personal Data
Your personal data may be transferred and processed outside the United States, particularly in Turkey. These transfers are conducted in compliance with U.S. data protection laws. By using our services, you consent to this international data transfer.

7. Your Rights Under U.S. Law
To comply with CCPA and other relevant regulations, you have the following rights regarding your personal data:

• Right to Access: Request information on the collection, use, and disclosure of your personal data.
• Right to Rectify: Request the correction of inaccurate or incomplete data.
• Right to Erasure: Request the deletion of your personal data, except where required by law or ongoing services.
• Right to Opt-Out of Sale: Opt-out of the sale of your personal data to third parties.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

8. Cookie Policy
Details on cookies are as follows:

• Essential Cookies: Required for the website to function.
• Analytical Cookies: Help improve functionality by tracking user interactions.
• Functional Cookies: Remember your preferences for future visits.
• Targeting/Advertising Cookies: Provide personalized advertisements.

9. Data Security
We implement reasonable and appropriate measures such as encryption, access controls, and regular security assessments to protect your personal data. However, no system is entirely secure, so we recommend safeguarding your passwords and personal information.

10. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy as necessary. Any changes will be communicated via our website or email.

11. Contact Information
If you have any questions about this policy or your personal data, please contact us:

• Email: info@autotrainbrain.com
• Address: Auto Train Brain Inc., Delaware, USA