Privacy Policy Brain Tool Kit App

  • BRAIN TOOL KIT APP — PRIVACY POLICY 

    Brain Tool Kit Inc. 
    600 Sherbourne Street, Suite 601 
    Toronto, Ontario M5R 0E3, Canada 
    Email: hello@braintoolkit.ca 
    Last Updated: September 30, 2026 

    Short Version 

    Everything you enter into the Brain Tool Kit App stays on your device. Brain Tool Kit Inc. does not receive, see, or store your results, symptoms, or health information on our servers. 

    If you choose to share your results, for example by emailing a report to your clinician, that information leaves your phone. Sharing works like sending an email, and it is not fully secure. 

    WHAT WE COLLECT 

    ✗ No name or email 
    ✗ No health or medical information is sent to us 
    ✗ No usage tracking 
    ✗ No analytics from Brain Tool Kit Inc. 
    ✗ No advertising or attribution tracking 

    The only information that leaves your device is the limited purchase information described in "Purchases and Subscriptions" below. 

    HOW YOUR DATA IS STORED 

    On your device. All information you enter into the app is stored on your phone or device. This includes activity results, performance history, and symptom scores. It is not sent to our servers, and Brain Tool Kit Inc. cannot access it. 

    Device backups. If you back up your phone, app data may be included in that backup, depending on your device settings. This applies to iCloud Backup, Google Backup, or a backup to your computer. iCloud and Google backups are stored in your Apple or Google account and are governed by their privacy policies. Brain Tool Kit Inc. cannot access any of your backups. You can manage backups in your device settings. 

    If you delete the app. Deleting the app removes its data from your device. It does not remove app data from existing device backups. It also does not remove reports or screenshots you have already shared or saved elsewhere. 

    SHARING YOUR DATA 

    The app lets you create a report of your results and share it using your phone's built-in share options, such as email, text message, WhatsApp, or AirDrop. 

    When you share, your information is sent through the app or service you choose, not through Brain Tool Kit Inc. 

    Sharing is like sending an email or a screenshot. Once information leaves your phone: 

    • it may be stored on the servers of the service you used, or on the recipient's device 

    • these methods are not fully secure 

    • Brain Tool Kit Inc. cannot see, retrieve, or delete it 

    • the privacy practices of the service you used, such as your email provider, apply 

    Before you share, the app will remind you of this and ask you to confirm. Only share with people you trust, such as your clinician. 

    PURCHASES AND SUBSCRIPTIONS 

    Purchases and subscriptions are processed by Apple or Google. We never receive your payment details. 

    To confirm your purchase and unlock BTK Pro features, we use a service called RevenueCat. RevenueCat receives only: 

    • an anonymous app user ID, which is not linked to your name or email 

    • your purchase receipt from Apple or Google 

    • your device type and operating system version 

    • the date the app last checked your purchase 

    • your approximate country, based on your IP address 

    RevenueCat does not receive any of your results, symptoms, or health information. For more information, see RevenueCat's privacy policy at revenuecat.com/privacy. 

    WHAT APPLE AND GOOGLE COLLECT 

    The app is distributed through the Apple App Store and Google Play Store. Apple and Google may collect information such as: 

    • when you installed or updated the app 

    • your device type and operating system 

    • app crashes or technical issues 

    Brain Tool Kit Inc. does not control what Apple and Google collect. Please review their policies: 

    • Google Privacy Policy: policies.google.com/privacy 

    YOUR RIGHTS 

    Because your app data stays on your device, you control it. You can view it in the app. You can delete it by deleting the app and managing your device backups. 

    For questions about the limited purchase information described above, contact us at the email below. 

    For information you have shared outside the app, contact the service you used or the person you shared it with. 

    LEGAL COMPLIANCE 

    Brain Tool Kit Inc. is based in Canada. This policy is designed to meet the requirements of Canadian privacy law, including PIPEDA and Quebec's Law 25. 

    QUESTIONS AND CONTACT 

    Brain Tool Kit Inc. 
    Email: hello@braintoolkit.ca 
    Address: 600 Sherbourne Street, Suite 601, Toronto, Ontario M5R 0E3, Canada 
    Website: braintoolkit.ca 

    We will respond within 30 days. 

    For our privacy policy covering our website and contact form, visit braintoolkit.ca/privacy. 

    PRIVACY OFFICER 

    Brain Tool Kit Inc. designates Melissa Biscardi, CEO, as responsible for privacy compliance. Contact us using the information above. 

    This Privacy Policy is effective as of September 30, 2026 and replaces all previous versions. 

     

    Apple App Store privacy label 

    In App Store Connect, go to App Privacy, then Edit. 

    1. "Do you or your third-party partners collect data from this app?" Change this to Yes. RevenueCat counts as a third-party partner. 

    1. Purchases → Purchase History. Select this. Set the purpose to App Functionality only. 

    1. Linked to the user's identity: No. There is no account, name, or email. 

    1. Used for tracking: No. 

    1. Everything else, including Health & Fitness: leave unselected. Data that stays on the device, or goes into the user's own backups, doesn't count as "collected" under Apple's definition. 

    Google Play Data safety form 

    In Play Console, go to App content, then Data safety. 

    1. Does your app collect or share user data? Yes. 

    1. Financial info → Purchase history. Mark it as collected, not shared. Sending data to a service provider like RevenueCat isn't "sharing" under Google's definition. Set the purpose to App functionality, and mark it as processed, not optional. 

    1. Encrypted in transit: Yes. RevenueCat uses HTTPS. 

    1. Deletion requests: say users can request deletion by emailing hello@braintoolkit.ca. 

    1. Health and fitness: leave unselected, for the same on-device reason as on Apple. 

    Three items to confirm before you submit 

    1. Anonymous user ID. Apple has a "User ID" category, and Google has "Device or other IDs." It's debatable whether RevenueCat's anonymous ID belongs in either. RevenueCat publishes a guide for filling in both forms, so check it and follow what it says for anonymous IDs. 

    1. Country from IP address. Check the same RevenueCat guide on whether this needs to be disclosed as "Coarse Location." If you're unsure, disclosing it is the safer choice, and it's already covered in the policy. 

    1. Publish both labels the same day you publish the policy. That way the labels and the policy never contradict each other. 

    1. Country from IP address. Check the same RevenueCat guide on whether this needs to be disclosed as "Coarse Location." If you're unsure, disclosing it is the safer choice, and it's already covered in the policy.----disclose this 

    Drafting privacy label settings for coarse location sharing. 

    Here's how to add it on each platform. The policy already covers it in the Purchases and Subscriptions section, so no policy changes are needed. 

    Apple App Store privacy label (App Store Connect → App Privacy → Edit) 

    1. Location → Coarse Location. Select this. 

    1. Purpose: App Functionality only. 

    1. Linked to the user's identity: No. 

    1. Used for tracking: No. 

    Google Play Data safety form (Play Console → App content → Data safety) 

    1. Location → Approximate location. Mark it as collected, not shared. 

    1. Purpose: App functionality. 

    1. Processing: processed, not optional. 

    1. Encrypted in transit: Yes. 

    Your full label set is now: 

    1. Purchase History: App Functionality, not linked, no tracking. 

    1. Coarse / Approximate Location: App Functionality, not linked, no tracking. 

    1. Anonymous user ID: pending your check of RevenueCat's guide. 

    1. Health & Fitness and everything else: not collected. 

    Now can you re create the entire privacy policy from top to bottom so I can just cut and paste? 

    Here's the full policy, ready to paste: 

     

    BRAIN TOOL KIT APP — PRIVACY POLICY 

    Brain Tool Kit Inc. 
    600 Sherbourne Street, Suite 601 
    Toronto, Ontario M5R 0E3, Canada 
    Email: hello@braintoolkit.ca 
    Last Updated: September 30, 2026 

    Short Version 

    Everything you enter into the Brain Tool Kit App stays on your device. Brain Tool Kit Inc. does not receive, see, or store your results, symptoms, or health information on our servers. 

    If you choose to share your results, for example by emailing a report to your clinician, that information leaves your phone. Sharing works like sending an email, and it is not fully secure. 

    WHAT WE COLLECT 

    ✗ No name or email 
    ✗ No health or medical information is sent to us 
    ✗ No usage tracking 
    ✗ No analytics from Brain Tool Kit Inc. 
    ✗ No advertising or attribution tracking 

    The only information that leaves your device is the limited purchase information described in "Purchases and Subscriptions" below. 

    HOW YOUR DATA IS STORED 

    On your device. All information you enter into the app is stored on your phone or device. This includes activity results, performance history, and symptom scores. It is not sent to our servers, and Brain Tool Kit Inc. cannot access it. 

    Device backups. If you back up your phone, app data may be included in that backup, depending on your device settings. This applies to iCloud Backup, Google Backup, or a backup to your computer. iCloud and Google backups are stored in your Apple or Google account and are governed by their privacy policies. Brain Tool Kit Inc. cannot access any of your backups. You can manage backups in your device settings. 

    If you delete the app. Deleting the app removes its data from your device. It does not remove app data from existing device backups. It also does not remove reports or screenshots you have already shared or saved elsewhere. 

    SHARING YOUR DATA 

    The app lets you create a report of your results and share it using your phone's built-in share options, such as email, text message, WhatsApp, or AirDrop. 

    When you share, your information is sent through the app or service you choose, not through Brain Tool Kit Inc. 

    Sharing is like sending an email or a screenshot. Once information leaves your phone: 

    • it may be stored on the servers of the service you used, or on the recipient's device 

    • these methods are not fully secure 

    • Brain Tool Kit Inc. cannot see, retrieve, or delete it 

    • the privacy practices of the service you used, such as your email provider, apply 

    Before you share, the app will remind you of this and ask you to confirm. Only share with people you trust, such as your clinician. 

    PURCHASES AND SUBSCRIPTIONS 

    Purchases and subscriptions are processed by Apple or Google. We never receive your payment details. 

    To confirm your purchase and unlock BTK Pro features, we use a service called RevenueCat. RevenueCat receives only: 

    • an anonymous app user ID, which is not linked to your name or email 

    • your purchase receipt from Apple or Google 

    • your device type and operating system version 

    • the date the app last checked your purchase 

    • your approximate country, based on your IP address 

    This information is used only to confirm your purchase and provide the features you paid for. It is not used for advertising or tracking. 

    RevenueCat does not receive any of your results, symptoms, or health information. For more information, see RevenueCat's privacy policy at revenuecat.com/privacy. 

    WHAT APPLE AND GOOGLE COLLECT 

    The Brain Tool Kit App is distributed through the Apple App Store and Google Play Store. Apple and Google may collect information such as: 

    • when you installed or updated the app 

    • your device type and operating system 

    • app crashes or technical issues 

    Brain Tool Kit Inc. does not control what Apple and Google collect. For information about their practices, please review: 

    • Google Privacy Policy: policies.google.com/privacy 

    YOUR RIGHTS 

    Because your app data stays on your device, you control it. You can view it in the app. You can delete it by deleting the app and managing your device backups. 

    For questions about the limited purchase information described above, or to request its deletion, contact us at the email below. 

    For information you have shared outside the app, contact the service you used or the person you shared it with. 

    If you have concerns about Apple or Google's practices, contact them directly through their privacy portals. 

    LEGAL COMPLIANCE 

    Brain Tool Kit Inc. is based in Canada. This policy is designed to meet the requirements of Canadian privacy law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Law 25. 

    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@braintoolkit.ca 
    Address: 600 Sherbourne Street, Suite 601, Toronto, Ontario M5R 0E3, Canada 
    Website: braintoolkit.ca 

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

    For our privacy policy covering our website and contact form, visit braintoolkit.ca/privacy. 

    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 contact information above. 

    This Privacy Policy is effective as of September 30, 2026 and replaces all previous privacy policies.