Brightn Children’s Privacy Policy

Brightn Inc. and its subsidiaries and affiliates (“Brightn,” “us,” or “we”) is committed to protecting the privacy of children who use our mobile applications, websites, or other products or services (collectively, the “Services”). This Children’s Privacy Policy (“Policy”) is a part of our general Privacy Policy. Consistent with the requirements of the Children's Online Privacy Protection Act of 1998 and its rules, as amended ("COPPA"), this Policy informs parents and legal guardians (collectively referred to as, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 in the United States.

Personal Information We Collect

For the purposes of this Policy, “personal information” is any information that, either alone or in combination with other information, identifies, relates to, or can be used to contact a particular individual.

The types of personal information we collect from or about a child can be categorized as follows:

• Contact information. The child’s first and last name, date of birth, email address.
• Parental information. A parent’s name, email address, telephone number, and mailing address.
• Account Information. If a child registers an account with us, the child’s student identification number, the child’s emergency contact information, as well as a password and other authentication-related information. We may request additional information from a child when creating an account, but this information is optional and we specify whether information is required or optional when we request it.

To the extent inferred from a child’s interactions with our Services, or when a parent or child chooses to provide such information as part of the child’s account profile, or when a child or parent otherwise chooses to provide the information, we collect the following:

• Demographic information. The child’s gender, race or ethnicity, preferred pronouns, or sexual orientation.
• Health information. Information about the child’s physical or mental health status, condition, or diagnosis, including treatments the child is receiving, medications the child is taking, the type of care the child is seeking, medical or health-related interventions the child received or is interested in, the child’s health and wellness goals, and information related to the child’s receipt of medical and health services, in each case, to the extent applicable.
• Fitness information. Information regarding dietary habits and activities the child engages in, such as the food and drinks they consume and purchase, fitness level, activity, and goals, nutritional preferences, lifestyle information (e.g., sleeping data), body measurements (e.g., height, weight), and other related information the child chooses to capture in notes or other fields within the Services.
• Behavioral Data.  Information about the child’s behaviors and habits, such as frequency of activity completion and engagement with wellness plans.

In addition, we collect the following personal information from children –

• User content. When a child engages with the chat or journal features of the Services, we collect all such content provided by the child. This could include the child’s personal reflections or other creative expressions. It also includes mood check-ins or other emotion reporting features within the Services.
• Communication information. When a child sends or responds to emails, messages, chats, or other communications from Brightn, we may collect the child’s email address, name, and any other personal information the child chooses to include in the body content of their communications.
• Support information. When a child submits a support request or otherwise engages with our support team, we collect the information the child provides during that interaction. We also utilize live chat and/or chatbot technology, which allows the child to communicate directly with our automated customer service system and/or customer service representatives via a chat window about our Services. Text entered into any chat form or functionality is collected instantly and simultaneously by Brightn and the vendors who make the technology available. It may be retained and used by Brightn for our business purposes, including by our customer service and other personnel and service providers.
• Usage information. We collect device information, which includes data from the device used to access our services, such as device type, operating system, and mobile network information. We also gather log information that details how our services are used, including access times, pages viewed, and interactions with our content. Additionally, we collect location data, which consists of geographical location information collected from the user’s device to provide location-based services. We may collect information about the communication interfaces used for data transmission between user devices and our servers. Additionally, we collect data generated from user interactions with our mobile application, including user inputs, preferences, and settings.

If information has been de-identified, in accordance with applicable laws, then it no longer qualifies as “personal information.” Brightn will ensure that any de-identified information is not capable of being re-identified and that any downstream recipients of the data also agree to not re-identify, or attempt to re-identify, the information.

Sources of Personal Information

We may collect personal information from a child’s school system in connection with facilitating enrollment in and use of the Services, if the school system is a sponsor of our Services.

We collect the above-described personal information when a child accesses, uses, or navigates our Services, fills in forms on our Services, requests information from us, communicates with us (including by phone, email, chat, or otherwise), interacts with any chatbot or similar features available in our Services, visits or engages with our social media pages, participates in surveys or sponsored activities, or otherwise provides us with personal information.

We also use various technologies to automatically collect information about users when they access and navigate our Services. Those technologies include cookies, log files, pixels, tags, web beacons, click-tracking technologies, and analytics tools. The information collected through these technologies may be combined with personal information or aggregated with other information collected from or about the child via our Services. Please also review the child’s browser or device settings to disable collection via certain unnecessary technologies.

The Services do not permit the child to make any information publicly available but we do provide personal information to the child’s school and/or law enforcement (in the event of threat to safety of self or others, or otherwise mandatory reporting required by law), or to other registered users (in the case of information the child chooses to make available).

How We Use Personal Information

We (or vendors acting on our behalf) use the personal information identified above for the following purposes:

• Verifying if a child is under the age of 13.
• Communicating with a parent regarding the collection, use and disclosure of a child’s information and the parent’s related consent.
• Creating the child’s account for the Services and allowing the child to access their account.
• Tailoring content, recommendations, and wellness plans to meet individual child’s needs, and tracking the child’s performance in such activities.
• Analyzing usage patterns to improve the performance and features of our Services.
• Conducting research and developing new features, including those based on aggregated information and analytics.  
• Processing the information so that it no longer identifies a child and becomes “anonymized” or “de-identified” information, in accordance with applicable laws.
• Sending notifications, updates, and relevant information to children, such as reminders.
• To provide and optimize our Services, including the delivery of content and interactive features.
• To communicate with a child regarding our Services, including updates or changes.
• To provide a child with customer support, answer their questions or requests for information, or handle their complaints.
• To process payment, manage a parent’s orders, and account for applicable sales taxes.
• To inform schools, if applicable, about the child’s registration and other information they require regarding the child’s use of the Services.
• To fulfill our obligations under any contract that we may have with a parent or a school.
• To protect ourselves and others, prevent fraud and other unlawful or unauthorized activity, and create and maintain a trusted, secure, and reliable online environment.
• To comply with our legal obligations, including meeting regulatory compliance obligations, responding to subpoenas, court orders, or other legal processes.
• To establish or exercise our legal rights or defend against legal claims.
• For other new or additional purposes which we may disclose to a parent, and with the parent’s consent.

Data Retention

We retain personal information collected online from or about a child for only as long as is reasonably necessary to fulfill the specific purpose(s) for which the information was collected. Personal information collected online from or about a child will not be retained indefinitely. When such information is no longer reasonably necessary for the purposes for which it was collected, we delete the information using reasonable measures to protect against unauthorized access to, or use of, the information in connection with its deletion. Specifically: (a) if a child’s account is closed or a parent requests deletion, we will delete the child’s personal information within a reasonable period, unless retention is required by law; (b) for personal information collected for a one-time activity (e.g., a support request), we will delete the information promptly after the activity is completed; and (c) for personal information used for ongoing Services, we will delete the information within a reasonable period after the Services relationship ends. In all cases, we use reasonable measures to protect against unauthorized access to, or use of, the information in connection with its deletion. If we learn that we have received personal information from a child that is inconsistent with this Policy, we will delete the data. If you believe that we have received personal information from a child in error, please contact us at support@brightnapp.com to request deletion of that information.

Disclosures of Personal Information

We disclose children’s personal information to the service providers and vendors we use to support the internal operations of our business and the operation of the Services. For example, we disclose personal information to our data hosting providers, our email system provider, and the suppliers of technologies we use to log information from the Services, conduct performance analytics, and to maintain system security.

We disclose personal information to the child’s parents, to provide direct notice and when a parent exercises their right to access a child’s personal information.

We disclose children’s personal information to the child’s school system, if we have an agreement with that school system, and believe disclosure is necessary or appropriate to protect the rights, property, or safety of the child, other individuals, or the school.

We may also disclose children’s personal information -

• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• To law enforcement, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brightn, our users or others, including to: protect the safety of a child; protect the safety and security of the Services; or enable us to take precautions against liability.

In addition, Brightn may disclose children’s personal information to buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our business or some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.

Protection of Children’s Personal Information

We use appropriate administrative, technical, and physical measures to protect children’s personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect children’s information, we cannot ensure or warrant the security of any information children transmit to us and they do so at their own risk.

Accessing and Correcting Your Child's Personal Information

At any time, a parent may review their child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using their child’s personal information.

Parents can review, change, export, or delete their child's personal information by accessing the dashboard made available to parents within our application, or contacting us at the information below.

Operators and Contact Information

Brightn is the sole operator that collects and maintains information from and about children when they use our Services.

If you have any questions regarding this Policy, please contact us at:

Brightn Inc.

4221 Beverly RD SW

Cedar Rapids, IA 52404

Email: support@brightnapp.com