Last Modified: APRIL 21, 2017


Home Base Impairment Company, Inc. (a company also doing business as RC21X) ("HBIC" or "we" or our) knows that your privacy is very important to you; and as such, we are committed to providing you with a safe and secure user experience. This Privacy Policy ("Policy") applies to your use of our mobile-based brain performance monitoring application currently being marketed as the "Roberto App", as well as to your use of the Roberto App website (the "Roberto Site"). The Roberto App is available on iOS and Android platforms and can be found on the application stores for these platforms (e.g., Google Play, iTunes, the Apple Store, etc.), as well as on the Roberto Site. This Policy describes how we collect, use, secure, and share information of those individuals (collectively "you") who access and/or use the Roberto App and the Roberto Site. This Policy also describes how to access, update, and correct your personal information, as well as the choices available to you regarding the same. If for any reason you do not agree to the terms of this Policy, you must not use, and/or immediately stop using, the Roberto App and the Roberto Site.


1.     Information We Receive From Your Access and/or Use of the Roberto Site and the Roberto App


In order to be able to use the Roberto App, you will need to register by either using your email or your social media (e.g., Facebook) account. If you register by using your email, in addition to providing that particular information, you will also need to provide at least the following: your name, date of birth, and a password. If, however, you register by using your social media account, we will use that service to authenticate you. We may also receive other information that you have agreed may be provided by that particular social media account (e.g., your username, name, e-mail address, date of birth, gender, etc.). We receive and collect this information so that it can be used for the purposes explained in this Policy.


In addition to the information you provide to us during registration, when you use the Roberto App or the Roberto Site, you may automatically submit information about your computer, mobile device, or other devices used to access the same and/or about how they are being used. We would do this to improve the services and marketing we offer you.

From time to time, we may use push notifications in our mobile applications to send you messages about your account, our company, other products or services offered by our company, and/or add-ons to the Roberto App. If such notifications are offered, you will also be offered with the opportunity to opt out from receiving them.


o    Our Use of Cookies. Like many other companies, we and third parties that we work with may use cookies and other web and mobile tracking technologies. We would use these technologies for authentication, to store your preferences or progress, for analytics, and/or to help us advertise our company and/or the products and services that we offer. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We would also use cookies for authentication and preserving settings on the Roberto App as well as across your visit to the Roberto Site. You can control the use of cookies at the browser level. If you reject cookies, while you may still use the Roberto App and the Roberto Site, your ability to use some features may be limited.


o    Mobile Analytics. We use mobile analytics tools to better understand the functionality of our Roberto App. These tools may record information about your usage, including how often you use it, the events that occur within the application, and from where the application was downloaded. We may also link the information recorded in analytics software to personal information you submit to us.


2.     How We Use Your Personal Information


We use your information to improve the look and operation of the Roberto Site and/or the Roberto App. This includes, but is not limited to, the following:


o    Authenticating your login

o    Personalizing your experience

o    Allowing you to monitor your performance and progress in the Roberto App

o    Customizing and delivering information about our products and services by email

o    Providing customer support and sending confirmations about your account(s)

o    Protecting our intellectual property or other rights

o    Managing and improving our business, our websites, and our products

o    Processing payments, if any.


You can opt out of receiving marketing emails by navigating to your Email Notifications page or by following the unsubscribe instructions included in each email. Please note you may not opt out of certain transactional emails, such as when we email you to confirm transactions, address account issues, or communicate about customer support.

From time to time, we may provide you the opportunity to participate in contests or surveys, and accessing those opportunities may require that you provide additional personal information or other demographic information. Please note that your participation in these surveys or contests is completely voluntary; and you may decline to provide such information.


We also reserve the right to use non-personal information (e.g., de-identified or aggregate data) for any purpose. For example, we may choose to show aggregate performance measures to users to allow them to evaluate their performance against other Roberto App users. Also, we may choose to disclose non-personal performance statistics to university/research collaborators to evaluate, study, and improve the effectiveness of our Roberto App. In these situations, all data that will be disclosed to such third parties will either be provided in an aggregate form, or in a form where all information that can be used to personally identify has been removed. In addition, when we work with such third parties, we will contractually prohibit them from attempting to re-identify individuals from data that has been de-identified.


3.     Minor's Privacy


We believe that protecting the privacy of minor children under the age of 18 - or under the age of majority in their jurisdiction of residence (collectively "Minors") is extremely important. Although the Roberto Site and the Roberto App may be used by Minors, including by a child under the age of thirteen, neither the Roberto Site nor the Roberto App are designed to attract such Minors, especially those under the age of thirteen. It is our intent and directive to comply with all laws pertaining to the protection of a Minor's privacy, including, without limitation, the Children's Online Privacy Protection Rule (16 CFR 312). Regarding the privacy of all Minors who access the Roberto Site and/or who use the Roberto App, it is the responsibility of that Minor's parent or guardian to consent to such access or use and/or to monitor how it is being used and any results being generated.


4.     No Disclosure of Your Personal Information to Third Parties for Marketing Purposes


We believe in protecting your privacy; and therefore, we will not provide your personal information to third parties for their marketing purposes.


5.     When We Share Your Personal Information with Third Parties


If we choose to share your personal information with third parties, we will only do so in the following ways and with the following safeguards:


o    Service Providers and Agents. We may share limited personal information with certain third parties selected by us to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer support requests. In addition, we may also share limited personal information to third parties that help us market or advertise our company and our products and services. These third parties may have access to some of your information only for purposes of performing these tasks on our behalf; and we will contractually require them to protect your information consistent with this Policy.


o    Affiliates. We may share limited personal information with our corporate affiliates, such as entities under common ownership or control.


o    Business Transfers. We may sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, business transaction, or in the event of bankruptcy. In such scenarios, your information may be one of the assets transferred. We will post a notice or otherwise notify you and collect your consent, as may be required by law, before the information is transferred and becomes subject to a different privacy policy.


o    Compliance with the Law and with Law Enforcement Requests and the Protection of Our Rights. We may disclose your information when we have a good faith belief we are required to do so by law, or in response to a subpoena, court order, or other legal mechanism. We may also disclose your information when we have a good faith belief that disclosure may prevent fraud and abuse of our company and/or our company's products or services protect our property rights and/or the rights of other individuals who use the Roberto App or the Roberto Site.


o    Consent. We may disclose your information when we believe we have your consent to do so, such as when you contact customer support and ask us about your account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your account. If you have expressly agreed to participate in a research study with us or with a third party that incorporates your personal information collected by HBIC from the Roberto Site or the Roberto App, we also may disclose your information for the purpose of facilitating the research to which you have consented.


6.     Accessing, Reviewing, and Deleting Your Information


You may access, review, correct, and/or delete your registration information through your account page on the Roberto App. You may also access and/or delete the personal information we have collected about you by contacting us at the contact information listed below and requesting the same. While we will make reasonable efforts to accommodate your requests, we reserve the right to impose certain requirements and restrictions on such requests, such as limiting our production of information to certain formats and not deleting information that is no longer identifiable. We will retain your information for as long as your account is active, or we think you may return as a user, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


7.     Security of Personal Information


We have implemented and maintain reasonable security practices to protect against the unauthorized access, use, modification, destruction, and/or disclosure of your personal information. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission or storage is completely secure; and as such, we cannot guarantee absolute security.


8.     Outside the United States Consent to Processing and Transfer of Information


If you access the Roberto App or the Roberto Site outside of the United States, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection and processing of such personal information in the United States.


9.     Additional Information


o    Links to Third Party Websites. The Roberto Site and the Roberto App may include links to other sites that may collect personal information, and whose privacy practices may differ from those set out in this Policy. If you have any concern or questions regarding the privacy policies of these other sites, we encourage that you review the privacy policies of those sites.


o    Social Media Widgets. The Roberto Site and/or the Roberto App may also include social media features (e.g., Facebook and Twitter buttons, etc.). Your use of such features may result in the collection of your IP address and information about the page you are visiting. This use may also set cookies on your device to function properly. Your interactions with these features are governed by the privacy policies of the company providing them.


10.  Changes to the Policy


We have the right to update this Policy from time to time. If we make material changes thereto, we will provide a notice to you by email, by posting a notification on the Roberto Site and/or of the Roberto App, or by posting an updated privacy policy on the Roberto Site at least 30 days in advance of its effective date. Please note that, for existing users, unless otherwise provided by applicable law, your continued use of the Roberto App and the Roberto Site following the effective date of any Policy change means that you agree with, and consent to be bound by, the updated Policy.


11.  Contact Information


We welcome inquiries or comments about our Policy by emailing our Service Center. You may also send a letter to the following address:



Director of Privacy - RobertoApp

425 Mill Street / Suite 1

Coraopolis, PA 15108