Brain Tool Kit Inc.

600 Sherbourne Street, Suite 601

Toronto, Ontario M5R 0E3, Canada

Email: hello@concusionrehab.ca

Last Updated: July 11, 2026

1. INTRODUCTION AND SCOPE

Brain Tool Kit Inc. ("Brain Tool Kit," "we," "us," "our," or "Company") is committed to protecting your privacy and ensuring you have a positive experience on our website and mobile applications. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at braintoolkit.ca (the "Website") and use our mobile applications (the "App"), collectively referred to as our "Services."

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Services. By accessing and using our Website or App, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy applies to personal information collected by Brain Tool Kit Inc. and is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) at the federal level, and the Personal Health Information Protection Act, 2004 (PHIPA) in Ontario, where applicable.

2. PERSONAL INFORMATION WE COLLECT

2.1 Information You Provide Directly

Contact Form Submissions: When you use the "Contact Us" form on our Website, we collect the following information:

●      Your name

●      Your email address

●      Any message content you submit

This information is collected only when you voluntarily submit the form and is used solely to respond to your inquiry.

Website Visitors: If you browse our Website without submitting a form, we do not collect your name, email, or other identifying information through the Website itself.

2.2 Information Collected Automatically

Google Analytics: Our Website uses Google Analytics, a service provided by Google LLC, to analyze Website traffic and user behavior. Google Analytics collects certain information automatically, including:

●      Your Internet Protocol (IP) address

●      Browser type and version

●      Operating system

●      Pages visited and time spent on each page

●      Referring website

●      Device type and screen resolution

This data is collected through cookies and similar tracking technologies. Google processes this data according to Google's Privacy Policy and may use this data for its own purposes.

Cookies: Our Website may use cookies and similar tracking technologies to enhance your experience. These include:

●      Session cookies (used during your visit)

●      Persistent cookies (remain after you leave)

●      Analytics cookies (to measure Website usage)

You can control cookie settings through your browser preferences.

2.3 Information About Your Use of the App

IMPORTANT — NO DATA COLLECTION BY BRAIN TOOL KIT:

The Brain Tool Kit App does not collect, store, transmit, or access any personal information. The App operates entirely offline on your mobile device. This means:

●      No personal data is sent to our servers

●      No data about your usage is tracked by Brain Tool Kit Inc.

●      No names, emails, health information, or user activity are collected

●      All data you enter into the App stays exclusively on your device

●      Deleting the App removes all data associated with it from your phone

This privacy protection applies globally — whether you use the App in Canada, the United States, Europe, or anywhere else.

The App is distributed through the Apple App Store and Google Play Store. Apple and Google may collect information about the app installation itself (such as download date, device identifier, or app version). Please refer to the privacy policies of Apple and Google regarding their collection of technical information about app installations, updates, and device analytics.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information we collect for the following purposes:

●      To Respond to Your Inquiries: We use your name and email address to respond to questions, concerns, or requests submitted through our Contact Us form.

●      To Improve Our Services: We use analytics data to understand how visitors use our Website and App, identify trends, and improve user experience.

●      To Comply with Legal Obligations: We may use personal information to comply with applicable laws, regulations, and legal proceedings.

●      To Prevent Fraud or Harm: We may use information to detect, prevent, or address fraud, security issues, or other harmful activities.

4. RETENTION OF PERSONAL INFORMATION

4.1 Contact Form Submissions

●      Content Retention: We retain the content of your message indefinitely to maintain a record of your inquiry and our response.

●      Contact Information Retention: We delete your name and email address within 30 days of receiving your submission, unless you have opted into ongoing communications.

●      Opted-In Communications: If you opt into receiving communications from us, we retain your name and email address for as long as you remain subscribed. You may unsubscribe at any time by clicking the unsubscribe link in any communication or by contacting us directly.

4.2 Analytics Data

Google Analytics data is retained according to Google's data retention policies, which may vary. You can adjust your Google Analytics retention settings through your Google Account.

4.3 App Data

No personal data is retained by Brain Tool Kit Inc. regarding App usage. Data remains on your device unless you choose to delete the App.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

We do not sell, trade, or rent your personal information to third parties. However, we may disclose your information in the following circumstances:

5.1 Third-Party Service Providers

We use third-party service providers to support our operations, including:

●      Squarespace: Hosts our Website and provides the contact form functionality. Contact form submissions are transmitted from Squarespace to our email inbox. See Squarespace's Privacy Policy for details.

●      NameCheap Private Email: Stores and hosts contact form submissions received via our contact form. Your name and email address are retained in this email inbox according to the retention schedule outlined in Section 4.1. See NameCheap's Privacy Policy for details on their data handling practices.

●      Google Analytics: Analyzes Website traffic. See Google's Privacy Policy for details.

●      Apple App Store and Google Play Store: Distribute our App. See their respective privacy policies for details on their data collection practices.

Note on Future Changes: If we integrate additional email platforms (such as email marketing services like Mailchimp, Klaviyo, or similar) in the future, we will update this Privacy Policy to reflect those changes and disclose any new third-party processors. You will receive notice of material changes before your information is used in a materially different manner.

5.2 Legal Requirements

We may disclose your personal information if required by law, including:

●      Court order or legal process

●      Law enforcement request

●      Protection of public safety

●      Enforcement of our Terms of Use or other agreements

5.3 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your personal information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

6. SECURITY OF YOUR PERSONAL INFORMATION

We employ commercially reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6.1 Website Security

Our Website is hosted on Squarespace, which implements industry-standard security measures. Please refer to Squarespace's security information for details.

6.2 App Security

The Brain Tool Kit App does not transmit personal data to our servers. Data security depends on your device's security settings and any encryption applied by your device's operating system.

7. YOUR PRIVACY RIGHTS

Under PIPEDA and PHIPA, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request access to your personal information held by Brain Tool Kit Inc. We will provide you with a copy of your information within 30 days of your request, subject to certain exemptions under applicable law.

7.2 Right to Correction

You have the right to request correction of inaccurate, incomplete, or outdated personal information. We will correct your information and notify any third parties (where applicable) within a reasonable timeframe.

7.3 Right to Deletion

You have the right to request deletion of your personal information, subject to legal and business obligations to retain certain records. Once deleted, we will confirm deletion within 30 days and notify third-party service providers where applicable.

7.4 Right to Withdraw Consent

If you have consented to receive communications from us, you may withdraw that consent at any time by:

●      Clicking the unsubscribe link in any email communication

●      Contacting us directly at hello@braintoolkit.ca

7.5 Right to File a Complaint

If you believe your privacy rights have been violated, you may file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H8

Phone: 1-800-282-1376

Website: www.priv.gc.ca

For PHIPA-specific matters in Ontario, you may also contact the Information and Privacy Commissioner of Ontario (IPC).

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Types of Cookies We Use

●      Essential Cookies: Required for basic Website functionality.

●      Analytics Cookies: Track Website usage and performance (Google Analytics).

●      Preference Cookies: Remember your settings and preferences.

8.2 Managing Cookies

You can control cookies through your browser settings:

●      Chrome: Settings > Privacy and security > Cookies and other site data

●      Firefox: Preferences > Privacy & Security > Cookies and Site Data

●      Safari: Preferences > Privacy > Manage Website Data

●      Edge: Settings > Privacy > Clear browsing data

Disabling cookies may affect your ability to use certain Website features.

8.3 Do Not Track

Some browsers include a "Do Not Track" feature. Our Website does not currently respond to Do Not Track signals, but you can use browser settings to control tracking.

9. THIRD-PARTY LINKS AND SERVICES

Our Website and App may contain links to third-party websites and services. This Privacy Policy applies only to our Services. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party services before providing your personal information.

10. CHILDREN'S PRIVACY

Our Services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete such information and terminate the child's use of our Services. If you believe a child has provided us with personal information, please contact us immediately at hello@braintoolkit.ca.

11. INTERNATIONAL USERS

11.1 Data Storage and Location

Our Services are operated in Canada. However, due to our use of third-party service providers:

●      Contact form data submitted through our Website may be stored on servers operated by Squarespace and NameCheap, which may be located in the United States or other jurisdictions.

●      Analytics data is processed by Google, which may store data globally according to Google's practices.

●      App data remains on your device only and is not transferred internationally or to our servers.

If you are accessing our Services from outside Canada, please be aware that your information may be transferred to, stored in, and processed in jurisdictions where privacy laws may differ from those in your country of residence. By using our Services, you consent to the transfer of your information in accordance with this Privacy Policy.

11.2 California Consumer Privacy Act (CCPA) and State Privacy Laws

For Residents of California and Other US States with Privacy Laws:

If you are a resident of California or another state with privacy laws (such as Virginia, Colorado, Connecticut, Utah, or others), you may have additional rights regarding your personal information, including rights to:

●      Know what personal information is collected and how it is used

●      Delete personal information collected from you

●      Opt-out of the sale or sharing of personal information

●      Non-discrimination for exercising your privacy rights

Current Status: Brain Tool Kit Inc. does not currently sell or share personal information for purposes that would trigger these laws. Our app collects no personal data. Our website contact form collects minimal information (name and email) used solely to respond to your inquiry.

If You Have a Privacy Request: US residents with privacy requests should contact us at hello@braintoolkit.ca with the subject line "Privacy Request" and specify:

●      The type of request (access, deletion, opt-out)

●      Your jurisdiction (state)

We will respond within applicable legal timeframes (typically 30-45 days depending on jurisdiction).

12. DATA RETENTION SUMMARY

Information Type

Retention Period

Conditions

Contact Form Content

Indefinite

Retained as inquiry record

Contact Form Name/Email

30 days

Deleted unless opted into communications via email

Opted-In Email Address

Until unsubscribe

Retained while subscribed to communications

Analytics Data

Per Google policies

Controlled by Google, not retained by BTK

App Data

Device-only

No data retained by BTK

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated Privacy Policy on our Website with a revised "Last Updated" date. Your continued use of our Services after such changes constitutes your acceptance of the updated Privacy Policy.

14. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Brain Tool Kit Inc.

Email: hello@concussionrehab.ca

Address: 600 Sherbourne Street, Suite 601, Toronto, Ontario M5R 0E3, Canada

We will respond to your inquiry within 30 days of receipt.

15. PRIVACY OFFICER

Brain Tool Kit Inc. designates Melissa Biscardi, CEO, as responsible for overseeing privacy compliance. Questions about this Privacy Policy can be directed to the above contact information.

This Privacy Policy is effective as of July 11, 2026 and supersedes all previous privacy policies.