What happens to your data.

Brain Trails is provided for informational and wellness purposes. Unless Lumentis Analytics Inc. says otherwise in writing, it is not a medical device and is not intended to diagnose, treat, cure, prevent or monitor any disease or medical condition. It does not provide medical advice.

Do not make medical decisions based on it. Talk to a qualified health-care professional about symptoms, diagnosis or treatment.

Lumentis Analytics Inc. is responsible for the personal information processed through Brain Trails.

Lumentis Analytics Inc., Attn: Privacy Officer
329 Howe Street, Unit 272, Vancouver, British Columbia V6C 3N2, Canada
privacy@lumentis.ca

Your account. Your email address, your password (stored only as a hash, never as text we can read), and an account identifier we generate.

What you tell us about yourself. Your name, year of birth and handedness, and — if you choose to give them — details such as sex at birth, sleep, caffeine, medications, and neurological or psychiatric conditions. Several of these are health-related and sensitive. Only the few that make a recording interpretable are required, none of them at sign-up, and the rest are offered and never demanded.

Your recordings. The EEG captured during a session, signal-quality and device information, your responses and timings during an exercise, and everything derived from them: features, metrics, projections, visualisations and reports.

EEG recordings and what we derive from them may be sensitive personal information. Depending on the context they may be treated as health-related or biometric information.

Technical information. Ordinary server logs, browser and device type, IP address, and the session cookie that keeps you signed in.

We use it to run the service: to keep your account, to receive and process your recordings, to compute the analyses and reports you asked for, to show you your history, to keep the service secure and working, and to answer you when you write to us.

Improving Brain Trails itself. We use recordings and derived data to check and improve the accuracy and reliability of what Brain Trails does — whether a reading is sound, whether a metric behaves, why something failed. This is part of running the service you are using.

Broader research — only if you say yes. Separately, and only with the optional consent you can give at sign-up and change at any time on your account page, we may keep and use your pseudonymised recordings and derived data for scientific research going beyond running and improving this service. Saying no changes nothing about your account, your recordings or your results. If you withdraw, we stop using your data for research from that point; we cannot undo research already done, or recover data that has been irreversibly anonymised.

We do not sell your personal information, your recordings or anything derived from them, and we do not use them for advertising or behavioural tracking of any kind.

We ask for two things separately. The first is consent to process your recordings and account data in order to provide Brain Trails at all — without it there is no service to give you. The second is the optional research consent above.

You can withdraw the optional one at any time from your account page. You can withdraw the first by deleting your account, also from your account page, or by writing to us. Withdrawing does not undo processing already carried out.

Your recordings and everything derived from them are stored against a randomly generated identifier rather than your name or your email, and the files themselves carry no identifying detail in their names or their contents. Your identity lives in a separate database.

That is a real protection, and it is not anonymity. While we can reconnect an identifier to you — and through our own account system, we can — the data is still personal information, and this note treats it as such throughout. We will not describe anything as anonymous unless it has been processed so that a person is no longer reasonably identifiable from it.

Lumentis Analytics Inc. is a Canadian company. Recordings, files and the application database are stored in Frankfurt, Germany. The application itself is served by Vercel, whose network is global, so requests may be handled outside that region even though the data at rest is not.

Authorised Lumentis personnel may access the data from Canada and Italy, where necessary to run, maintain and support the service.

Some of what protects your data comes from the platforms we build on, by default and without us configuring anything:

• Files are encrypted at rest. Amazon S3 applies AES-256 server-side encryption to every new object as a baseline that cannot be switched off (AWS documents this).
• The database is encrypted at rest and reached over TLS; see Neon’s security overview.
• Traffic between your browser and us travels over HTTPS.

And some of it is our own doing:

• Passwords are stored only as Argon2 hashes. We cannot read them.
• Your files are never public. They are reached through links that are generated for one file and expire within minutes.
• Access to the systems holding recordings is limited to the small number of people who run the service.
• Identity is kept in a different place from the recordings, as described in section 6.

Linking to those pages tells you what our providers do; it is not a claim that everything on our side is configured perfectly. No system is completely secure, and we cannot promise that yours will never be breached. What we can promise is that we will investigate anything we suspect and tell you where the law requires it — and, for something this sensitive, where it does not but you would obviously want to know.

We keep your account and your recordings while your account exists and this prototype is running. We have not set a fixed retention period yet and we are not going to invent one here: you can export or delete everything yourself, at any time, from your account page.

Because this is a prototype, data may also be removed when we reset an environment. We will give you notice before doing that deliberately.

When you delete your account, we delete your personal information: your recordings and the files behind them, the analyses and reports derived from them, your profile — including any health-related answers you gave — and the account itself.

One narrow exception. We keep a minimal record that consent was given and later withdrawn or deleted, so that we can show we asked properly and honoured your request. That record contains no EEG data, no health information, no name and no email address — only an account identifier, which version of this note was agreed to, and when. Once your account is deleted, that identifier no longer points to anything we hold.

Backups are not edited by hand. Copies of data held in backups disappear as those backups expire on their normal cycle.

We do not sell your personal information and we do not share it for advertising. It is disclosed only to the providers who host and run the service on our behalf under contract — today our cloud storage, database, hosting and email providers — to professional advisers where genuinely necessary, where the law or a valid legal process requires it, to protect people from harm, in connection with a business transaction subject to privacy law, and to anyone you ask us to share it with.

Two of these you can exercise yourself, right now, from your account page: export everything we hold about you, and delete your account. You can also grant or withdraw the optional research consent there.

For anything else — access, correction, restricting or objecting to particular processing, or asking what we have disclosed — write to privacy@lumentis.ca. A person reads that address. We may need to confirm who you are before we act.

If you are not satisfied with how we have handled something, you can complain to the Office of the Privacy Commissioner of Canada, or to the Office of the Information and Privacy Commissioner for British Columbia.

We use one cookie, to keep you signed in, and browser storage for small preferences such as whether you chose the light or the dark theme. No advertising cookies, no third-party analytics, no tracking pixels. If you block the session cookie you will not be able to sign in.

A session cookie or a stored identifier does not make your recordings anonymous. If an identifier lets us find your data, that data is still personal information.

Brain Trails is for people aged 18 and over. We do not knowingly open accounts for anyone younger. If you believe someone under 18 has created an account, write to us and we will delete it.

Brain Trails works with a Muse EEG headband, which is made and supported by another company under its own privacy policy. The same goes for the infrastructure providers named above. We encourage you to read their notices.

When we change this note in a way that matters, we will publish a new version and ask you to read and agree to it the next time you sign in. The version is at the top of this page and is recorded against your account when you agree, so there is always a record of what you actually agreed to.

Questions, requests or complaints: privacy@lumentis.ca, or Lumentis Analytics Inc., Attn: Privacy Officer, 329 Howe Street, Unit 272, Vancouver, British Columbia V6C 3N2, Canada.