LEGAL

Application & Platform Privacy Policy

Sensory Bridges, LLC · Effective April 24, 2026 · Last Updated April 24, 2026

This Application and Platform Privacy Policy ("App Privacy Policy") explains how Sensory Bridges, LLC handles information collected through the Brooks Band™ wearable device, the Brooks Band™ companion application, and our administrative platform used by schools, therapists, and pilot programs.

For information about our public website, see our Website Privacy Policy.

1. What The Brooks Band Does

The Brooks Band™ is a general wellness wearable that provides private haptic feedback to support voice self-regulation. It does not record audio. It does not store conversations. It measures sound level relative to a personalized baseline and delivers a gentle vibration only the wearer can feel.

2. Information We Collect

We collect only what is needed for the device and platform to function:

  • Voice volume measurements (decibel readings, not audio recordings)
  • Event timestamps and durations
  • Wellness observation data (e.g., recovery patterns)
  • Account information (administrator names, school or organization, role)
  • Aggregate usage statistics

We do not collect:

  • Audio recordings or speech content
  • Voiceprints or biometric identifiers
  • Photographs or video
  • Location data in school deployments

3. On-Device Processing

All raw audio signals are processed on the device and not stored. The device uses a rolling buffer that continuously overwrites — no audio leaves the wearer's wrist. Only derived measurements (volume levels, event counts, timestamps) are saved.

4. Data Security And Transmission

Data syncs over encrypted connections (TLS 1.3) and is stored encrypted at rest (AES-256). Access is role-based, and we maintain audit logs of who accesses what data.

5. FERPA Compliance

When used in schools, observation data is treated as an education record under FERPA, 20 U.S.C. § 1232g. The school is the data controller. Sensory Bridges acts as a "school official" under a Data Processing Agreement with the school. Parents and eligible students retain all FERPA rights.

6. COPPA Compliance

We comply with COPPA, 15 U.S.C. §§ 6501–6506 and 16 CFR Part 312 (including amendments effective June 23, 2025). When the Brooks Band™ is deployed in a school, the school may consent on behalf of parents under COPPA's school exception, solely for educational purposes. Parents retain the right to review, request deletion, and refuse further collection of their child's data at any time.

7. IDEA And Disability Data

The Brooks Band™ supports neurodivergent individuals as defined under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1401. Data collected in connection with IEP, 504, or special education services is handled in accordance with IDEA Part B confidentiality requirements (34 CFR §§ 300.610–300.626).

8. HIPAA

The Brooks Band™ is a general wellness device and is not generally subject to HIPAA. If a covered entity (such as a healthcare provider) deploys the platform in a manner that creates Business Associate obligations, we will execute a Business Associate Agreement before processing protected health information.

9. Data Retention

Data is retained only for the active service period (typically one academic year for school deployments) and is automatically purged at end of retention. Authorized adults can request earlier deletion at any time.

10. Data Sharing

We do not sell or share data with advertisers, data brokers, or third parties for marketing or commercial purposes. Service providers we use (cloud infrastructure, encrypted database providers) are bound by contracts limiting their use of data to providing services to Sensory Bridges.

We may share de-identified, aggregate data with academic and research partners under written agreements that limit use to research and product validation purposes. Identifiable data is shared with research partners only when authorized by an Institutional Review Board (IRB) approved protocol AND, where applicable, with verifiable parental consent or school authorization. Authorized adults (parents, guardians, or school administrators) may opt out of research participation at any time without affecting the availability of the underlying service. To opt out, email privacy@sensorybridges.com.

11. Breach Notification

If a breach affecting personal information occurs, we will notify affected individuals, the school or organization, and applicable regulators in accordance with state and federal breach notification laws.

12. Your Rights

Authorized adults (parents, guardians, or school administrators) can:

  • Review what data has been collected
  • Request corrections
  • Request deletion
  • Disable any sensor stream
  • Deactivate the device entirely
  • Opt out of research participation at any time

To exercise these rights, contact privacy@sensorybridges.com. We respond within 30 days.

13. SBB Wear V1 — Internal Testing Build

Effective April 29, 2026

SBB Wear V1 is a separate internal testing application and is not the production Brooks Band device. The on-device, no-audio-leaves-the-wrist architecture described in Sections 1–12 applies to the production Brooks Band. The terms below describe how the SBB Wear V1 testing build handles data, which differs from the production policy.

13.1 What The App Accesses

SBB Wear V1 may access:

  • Microphone audio for voice monitoring, calibration, and speaker verification
  • Health and sensor data such as body sensors and related biometric signals, if enabled on the device
  • Basic app usage and event timing information needed for monitoring and alerts

13.2 How Data Is Used

The app uses this data to:

  • Calibrate voice thresholds
  • Monitor voice activity
  • Support speaker verification
  • Generate in-app alerts and caregiver-facing monitoring information
  • Support biometric-based monitoring features when enabled

13.3 How Data Is Shared

If cloud speaker verification is enabled, short voice samples are sent securely to the configured SpeechBrain backend service for enrollment and verification. At this time, the backend service is hosted on Google Cloud Run for internal testing.

13.4 Data Retention

The app stores monitoring-related summaries, decisions, settings, and timestamps needed for app functionality. For internal demo use, speaker verification profile data may be stored on the backend service used for testing. Data may be deleted by removing app data from the device or by deleting backend profile data used for testing.

13.5 Security

We take reasonable steps to protect app data in transit and at rest during internal testing. However, this app is currently an internal testing build and not yet a final production release.

13.6 Third Parties

Internal testing infrastructure may use Google Cloud services to host backend functionality.

13.7 Children

This app is not intended for children.

13.8 Contact

If you have questions about this privacy policy, contact:
Sensory Bridges
Privacy@sensorybridges.com

13. General Wellness Positioning

The Brooks Band™ is a general wellness assistive technology product. It is not intended to diagnose, treat, cure, or prevent any disease or condition. It provides observational data that supports qualified professionals in their own documentation. Educational, therapeutic, and clinical decisions are made by qualified licensed professionals using their own judgment.

14. Changes To This Policy

We may update this App Privacy Policy. Material changes will be communicated to schools, organizations, and authorized adults.

15. Contact

Sensory Bridges, LLC
Privacy Team
100 Cherokee Blvd., Suite 213
Chattanooga, TN 37405
Email: privacy@sensorybridges.com