Privacy Policy

Last Updated 25 November 2025
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WELCOME

Thank you for choosing to play Brain Candy and for visiting our website at https://nx10.me. Your privacy matters to us, and we want to be completely transparent about how we handle data when you use our game and visit our website.

This privacy policy explains what data we collect, how we use it, and – importantly – what we don't collect. We've written this in plain language because we believe privacy policies should be clear and easy to understand.

1. WHO WE ARE

We are NX10.ME LTD, a company registered in England and Wales under company number 13746822. Our registered office is at 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN.

NX10.ME LTD is the data controller responsible for your personal data when you use our game and visit our website. This means we are responsible for making sure your data is handled properly and in line with data protection laws.

If you have any questions about this privacy policy or how we handle your data, please contact us at:

Data Protection Officer: privacy@nx10.me
Postal address: NX10.ME LTD, 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN

2. AGE RESTRICTIONS

Our game is intended for users aged 18 and over. By using the game, you confirm that you are at least 18 years old.

We do not knowingly collect data from anyone under 18. If we discover that we have inadvertently collected data from someone under 18, we will delete it promptly.

3. WHAT MAKES OUR APPROACH DIFFERENT

Before we get into the legal details, we want to explain our philosophy:

We genuinely do not know who you are. We have designed our game so that all data is anonymised from the moment it is collected. You do not create an account, you do not log in, and we do not ask for your name, email, or any personal details. Each device gets a random ID token that cannot be traced back to you.

This is not just good practice – it is fundamental to how we have built our game. Your privacy is protected by design, not as an afterthought.

Our website at https://nx10.me is primarily informational. Unlike our game, the website does not collect neurometric data or use sensors. The website may use cookies and standard analytics tools to understand how visitors use our site, which is explained in more detail in the Website Data Collection section below.

4. DATA COLLECTION - GAME VS WEBSITE

We collect different types of data depending on whether you're using our game or visiting our website. Here's what you need to know about each:

A. GAME DATA COLLECTION - YOUR DATA, YOUR CONTROL

We do not access or analyse the content of your communications, app usage, or personal files. Instead, we focus solely on the external form – patterns of touch, timing, motion, and interaction dynamics – captured via built-in phone sensors like the touchscreen, accelerometer, and gyroscope.

This means:

We never access or store messages, emails, images, or content from your apps
We measure how your fingers move, not where they move to
We do not access your contacts, photos, or any other personal content
We cannot and do not track what you do outside of our game

Minimal, Ethical Data Use

We practise minimal data collection. We only collect what is essential to develop insights into cognitive and emotional states through neurometrics.

This includes:

Touch interaction dynamics (pressure, speed, rhythm of taps)
Phone motion patterns (from the accelerometer and gyroscope)
Device metadata (e.g., phone model, OS version—for calibration only)
Responses to in-game prompts and questions
Timing data related to gameplay patterns

We do NOT collect:

We do NOT collect through the game:

GPS location data
Contacts or phone numbers
User-generated content outside the game
Browsing history or activity in other apps
Your name, email address, or any personally identifiable information through the game

Note: If you voluntarily subscribe to our newsletter through our website, we will collect your email address as described in section C above. This is separate from game data collection and is entirely optional.

B. WEBSITE DATA COLLECTION

Our website (https://nx10.me) is informational and does not collect the neurometric data described above. When you visit our website, we may collect standard information that most websites collect, including:

Technical data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
Usage data: Information about how you use our website, including pages visited, time spent on pages, and navigation paths
Cookie data: Information collected through cookies and similar technologies (included in this Cookie Policy)

We use this website data to:

Administer and improve our website
Understand how visitors use our website
Ensure website security
Analyse website performance and make improvements

We may use analytics services such as Google Analytics to help us understand website traffic and usage. These services may collect information about your use of our website and other websites.

The legal basis for processing website data is our legitimate interests in operating and improving our website and understanding how it is used.

C. NEWSLETTER SUBSCRIPTION (OPTIONAL)

If you choose to subscribe to our newsletter through the subscription form on our website, we will collect and process your email address.

What we collect:

Your email address (voluntarily provided by you)

Why we collect it:

To send you our newsletter with updates and information about NX10
To communicate with you about our products and services

How we process it:

Your email address is processed and stored by HubSpot, our newsletter service provider
HubSpot is located in the United States and complies with appropriate data transfer safeguards
You can unsubscribe from the newsletter at any time by clicking the unsubscribe link in any email we send you

Legal basis: Your consent. By submitting your email address through the subscription form, you consent to receiving our newsletter. You can withdraw this consent at any time by unsubscribing.

Data retention: We will retain your email address until you unsubscribe from the newsletter or request deletion of your data.

For more information about how HubSpot processes your data, please see HubSpot's privacy policy at: https://legal.hubspot.com/privacy-policy

5. ANONYMITY BY DESIGN

All data collected is anonymised at source. Each device is associated with a randomised identifier that is not passed into our data analytics engine.

6. LEGAL BASIS FOR PROCESSING YOUR DATA

Under UK data protection law (UK GDPR and the Data Protection Act 2018), we need a legal basis to process your data. We rely on the following legal bases:

Legitimate Interests (Article 6(1)(f) UK GDPR): We have a legitimate interest in conducting research to advance understanding of human cognitive and emotional states through neurometrics. We have carefully balanced this interest against your rights and freedoms, and the anonymised nature of the data we collect means there is minimal impact on your privacy.

Consent (where applicable): By continuing to use the game after being informed of our data practices, you provide your consent for us to collect and process anonymised data. You can withdraw this consent at any time by uninstalling the game.

7. HOW WE USE YOUR DATA

We use data collected from the game and website for different purposes:

Game Data Usage:

Research and development: To develop insights into cognitive and emotional states through neurometrics
Product improvement: To improve the game experience and develop new features
Scientific research: To contribute to scientific understanding of human behaviour and wellbeing
Academic collaboration: Aggregated and anonymised findings may be published in academic papers or shared with research partners

Our mission is to better understand human behaviour through form – not content. Anonymised data may be used in scientific research or product development to help people live better lives, but always in a way that protects your identity.

Website Data Usage:

We use website data for the following purposes:

Website administration: To operate and maintain our website
Analytics and improvement: To understand how visitors use our website and make improvements
Security: To protect our website from security threats and ensure proper functioning
Communication: If you contact us through the website, to respond to your enquiries

8. SHARING YOUR DATA WITH THIRD PARTIES

We may share data collected from our game and website with the following types of third parties:

Service providers: We use trusted third-party service providers for cloud storage, data analytics, data processing, and website hosting/analytics (e.g., Google Analytics). Game data shared with these providers is anonymised. Website data may include technical and usage data. All providers are contractually obligated to maintain appropriate data protection standards.

We do NOT:

Sell your data to third parties
Share your data for marketing purposes
Share personally identifiable information (because we do not collect it)

9. CONSENT AND TRANSPARENCY

We believe in explicit, informed consent. Before any data is collected, we clearly explain:

What data is collected
Why it is needed
How it is used

You are always in control. You can stop the collection of new data at any time by uninstalling the game.

10. SECURE AND COMPLIANT

We take the security of your data very seriously. All data is:

Encrypted in transit and at rest using industry-standard encryption
Processed securely using cloud-based infrastructure with strict access controls
Handled in full compliance with UK GDPR, the Data Protection Act 2018, and other applicable privacy regulations
Never sold to third parties
Retained only for as long as necessary for our research purposes (up to 10 years)

We continuously monitor and improve our data protection policies, working alongside privacy experts to exceed best-practice standards.

We have procedures in place to deal with any suspected data breach and will notify you and the Information Commissioner's Office (ICO) if we are legally required to do so.

11. DATA RETENTION

We retain different types of data for different periods:

Game data: Anonymised data collected through the game will be retained for up to 10 years or until it is no longer necessary for our research purposes, whichever comes first.
Website data: Website analytics and technical data will be retained for up to 26 months (in line with Google Analytics defaults) or as long as necessary for website improvement and security purposes.

We regularly review our data retention practices to ensure we do not retain data longer than necessary.

Because the data is anonymised and cannot be linked back to individual users, we cannot delete data relating to a specific user upon request. However, you can stop the collection of new data at any time by uninstalling the game.

12. INTERNATIONAL DATA TRANSFERS

Data from both our game and website may be transferred to, stored, and processed in countries outside the United Kingdom (for example, if we use cloud services or analytics providers with servers in other countries). When we transfer data internationally, we ensure appropriate safeguards are in place in accordance with UK data protection laws.

These safeguards include:

Standard contractual clauses approved by the UK authorities
Adequacy decisions recognising that the destination country provides adequate protection
Other legally recognised transfer mechanisms

13. YOUR RIGHTS UNDER UK DATA PROTECTION LAW

Under UK data protection law, you have the following rights:

Right to be informed: You have the right to be told how your data is being used (which this policy addresses)
Right of access: You can request information about the data we hold
Right to rectification: You can ask us to correct inaccurate data
Right to erasure: You can request that we delete your data
Right to restrict processing: You can ask us to stop processing your data
Right to data portability: You can request your data in a portable format
Right to object: You can object to our processing of your data
Rights related to automated decision-making: You have protections against solely automated decision-making

Because our data collection is completely anonymised and not linked to any personally identifiable information, we cannot identify which data belongs to a specific individual. This means that while we respect all the rights listed above, exercising certain rights (such as access, rectification, or erasure of your specific data) may not be technically possible once the data has been anonymised.

If you wish to exercise any of these rights or have questions, please contact us at privacy@nx10.me.

You can find more information about your rights at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

14. AUTOMATED DECISION-MAKING

We may use automated processing of anonymised data for research purposes. This automated processing is not used to make decisions that produce legal effects concerning you or similarly significantly affect you.

15. DEVICE PERMISSIONS

The game will request access to the following device features:

Touchscreen: To enable gameplay and measure touch interaction dynamics
Accelerometer: To detect device motion patterns
Gyroscope: To detect device orientation and rotation
Internet access: To transmit anonymised data securely to our servers

The game will NOT request access to your camera, microphone, contacts, location services, photo library, or any other personal data.

16. HOW TO COMPLAIN

We hope that we can resolve any concerns you have about how we handle your data. Please contact us first at privacy@nx10.me and we will do our best to help.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. You can contact them at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk

17. THIRD-PARTY LINKS

Our game does not include links to third-party websites or apps. The only external links you may encounter within the game are to our own Privacy Policy and Terms & Conditions.

We use third-party service providers on the back end for cloud storage, data analytics, and processing, but you will not interact with these services directly through the game. These providers are contractually bound to protect your data as described in Section 8 of this policy.

18. COOKIES AND SIMILAR TECHNOLOGIES

Our game does not use cookies. However, our website (https://nx10.me) may use cookies and similar technologies to improve your browsing experience and help us understand how visitors use our site.

For more detailed information about the cookies we use on our website, please see our separate Cookie Policy at https://www.nx10.me/privacy-policy contact us at support@nx10.me.

19. CHANGES TO THIS PRIVACY POLICY

We may update this privacy policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons.

When we make changes, we will update the "last updated" date at the top of this policy. If we make significant changes that affect your rights, we will notify you through the game or by other appropriate means.

We encourage you to review this privacy policy periodically to stay informed about how we are protecting your data.

20. APP STORE TERMS

If you download the game from the Apple App Store or Google Play Store, your use of the game is also subject to the applicable app store terms and conditions and privacy policies. We recommend reviewing those documents as well.

21. CONTACT US

If you have any questions, concerns, or requests regarding this privacy policy or our data practices for the game or website, please do not hesitate to contact us:

Data Protection Officer: privacy@nx10.me

or by writing to:

Data Protection Officer
NX10.ME LTD
9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN

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YOUR TRUST IS THE FOUNDATION OF NX10

We are committed to being transparent, accountable, and respectful—every step of the way. Thank you for trusting us with your data when you play our game and visit our website. We take that responsibility seriously.