1. Data Controller
Brain Core Sàrl — RC Valais: CHE-113.424.769
Route de l’Île-au-Bois 3, 1870 Monthey, Switzerland
Contact: info@braincore.ch
2. Data Collected
We collect only the data necessary to provide you with a reliable and personalized service:
- Identification data: first name, last name, email address, login credentials, date of birth.
- BrainCore test data: answers, scores, cognitive profile, reliability index.
- Virtual Coach (AI) data: personalized learning paths, recommendations, feedback, and progress history.
- Navigation data: IP address, connection logs, technical cookies.
- Contractual and billing data: subscription and payment information, where applicable.
3. Purposes of Processing
- Create and manage your account.
- Administer BrainCore tests and generate your personalized reports.
- Provide and improve recommendations through our AI-based Virtual Coach, which analyzes your results to adjust your progression.
- Monitor your progress over time and continuously improve the scientific and pedagogical quality of our services (data anonymized or pseudonymized where possible).
- Ensure platform security and integrity.
- Comply with legal and regulatory obligations (invoicing, archiving).
4. Legal Basis
In accordance with the GDPR:
- Performance of a contract: account creation/management, test delivery, report generation, access to the Virtual Coach.
- Consent: personalization by the Virtual Coach, processing of sensitive data where applicable, optional cookies/analytics. You may withdraw consent at any time by writing to info@braincore.ch.
- Legitimate interests: security, fraud prevention, continuous improvement (on anonymized/pseudonymized data), internal analytics.
- Legal obligations: retention of contractual and billing data.
5. Profiling and Personalized Recommendations
Our Virtual Coach uses algorithmic processing to analyze your results, generate a cognitive profile, propose tailored recommendations/exercises, and adjust your path. These processes do not produce legal or similarly significant effects.
You may request information on the general logic and ask for human review if you contest recommendations. BrainCore’s models and methodology remain confidential as essential intellectual property.
6. Data Retention
- Account and test data: up to 3 years after your last activity.
- Anonymized data: may be kept without time limit as it no longer allows identification.
- Contractual and billing data: 10 years in compliance with Swiss law.
7. Data Recipients and Processors
- Authorized Brain Core Sàrl staff.
- Technical providers (hosting/security): Hetzner Online GmbH, servers located in Germany and Finland (EU).
- Certified BrainCore coaches, only for the users they support and within their contractual relationship.
- Scientific/educational partners, only on anonymized or pseudonymized data with a specific agreement.
No personal data is sold or used for advertising purposes.
8. Hosting and International Transfers
Data is hosted within the European Union (Germany and Finland). If transferred outside the EU or Switzerland, recognized safeguards are applied (Standard Contractual Clauses, adequacy decisions).
9. Your Rights
- Access your data and obtain a copy.
- Rectify inaccurate data.
- Request erasure (subject to legal obligations).
- Restrict or object to processing.
- Request portability (readable export).
- Withdraw consent at any time by contacting info@braincore.ch.
- Request human review if you contest AI recommendations.
We will respond within 30 days.
10. Data Portability and Export
You may request an export of your data in CSV or JSON for personal use or transfer to another provider. Partner institutions may request pseudonymized, aggregated exports for statistical purposes. Requests are processed within 30 days.
11. Data Security
- Encryption in transit (TLS) and at rest (AES).
- Pseudonymization and environment separation.
- Role-based access control with periodic review.
- Logging and auditing of sensitive operations.
- Secure backups and restoration tests.
- Incident response plan with notification within 72 hours in case of data breach.
12. Users Under 18
Access is reserved for users aged 12 or older. For minors under 18, parental consent is required. In a school context, the institution obtains and stores consents.
14. Account Deletion
You may request account deletion by writing to info@braincore.ch. Where the account is linked to an employer or institution, deletion cannot be performed automatically via the user interface.
Deletion results in immediate anonymization of test results and permanent erasure of personal data within 6 months, unless legal obligations require otherwise.
15. Changes
In case of material changes, we will notify users at least 60 days in advance. The most recent version is always available on our website.
16. Governing Law and Authorities
This policy is governed by Swiss law (FADP). For EU/EEA residents, GDPR also applies. Supervisory authority: Swiss Federal Data Protection and Information Commissioner (FDPIC) or your national authority.
In case of any discrepancy between language versions, only the French version of this Privacy Policy shall prevail.
17. Contact
Publisher: Brain Core Sàrl — RC Valais: CHE-113.424.769 — Route de l’Île-au-Bois 3, 1870 Monthey (Switzerland).
E-mail: info@braincore.ch