BrightChamps Children's Privacy Notice
(COPPA Notice)

This Notice applies to personal information collected from or about children who participate in BrightChamps educational programs, classes, courses, activities, events, assessments, communications, or other services.

For purposes of this Notice, "Child" means a user under the age of 13 in the United States or any other age threshold established under applicable children's privacy laws.

BrightChamps complies with the Children's Online Privacy Protection Act ("COPPA"), applicable U.S. state privacy laws, the General Data Protection Regulation ("GDPR"), the UK GDPR, India's Digital Personal Data Protection Act, 2023 ("DPDP Act"), and other applicable laws relating to children's privacy and protection.

BrightChamps does not knowingly collect more personal information from children than is reasonably necessary to provide educational services, maintain platform functionality, ensure safety, comply with legal obligations, and support educational outcomes.

Participation in BrightChamps services is not conditioned upon a child disclosing more personal information than is reasonably necessary for participation in the applicable educational activity.

Depending on the services used, BrightChamps may collect the following categories of information:

Student Account Information

• Student name or display name;
• Username or account identifier;
• Age, grade level, learning preferences, or educational information;
• Parent or guardian association information.

Educational Information

• Class participation records;
• Assignments, projects, assessments, and educational submissions;
• Attendance records;
• Learning progress and performance information.

Audio, Video, and Communication Information

• Classroom recordings;
• Audio and video participation during live sessions;
• Chat messages and classroom communications;
• Educational interactions with instructors.

Device and Usage Information

• IP address;
• Device identifiers;
• Browser and operating system information;
• Log information;
• Platform usage and activity data.

Support and Safety Information

• Communications relating to support requests;
• Reports of misconduct, safeguarding concerns, or policy violations;
• Investigation and compliance records.

BrightChamps may use children's information for the following purposes:

• Providing educational services and classes;
• Facilitating participation in learning activities;
• Managing student accounts and profiles;
• Delivering educational content and assessments;
• Supporting instructors and educational operations;
• Ensuring platform safety, safeguarding, and security;
• Monitoring compliance with policies and legal obligations;
• Preventing fraud, abuse, misuse, and unauthorized activity;
• Improving, maintaining, and developing educational services;
• Responding to support requests;
• Complying with legal, regulatory, and contractual obligations.

BrightChamps does not use children's personal information for interest-based advertising or behavioral advertising without obtaining any consent required under applicable law.

Where required by applicable law, BrightChamps obtains verifiable parental consent before collecting, using, or disclosing a child's personal information.

Parents or legal guardians may provide consent through methods approved by BrightChamps and permitted under applicable law, including consent obtained during enrollment, account creation, purchase, registration, or other authorized verification processes.

BrightChamps may also seek additional consent, confirmations, or authorizations when required for specific activities, recordings, communications, or disclosures.

BrightChamps may share children's information only as reasonably necessary to provide services, comply with legal obligations, protect users, or operate the platform.

Recipients may include:

• Instructors, educators, and service providers involved in delivering educational services;
• Technology, hosting, cloud, analytics, and platform providers;
• Customer support and operational service providers;
• Payment and transaction service providers;
• Professional advisors, auditors, insurers, and compliance providers;
• Law enforcement agencies, courts, regulators, child protection authorities, or governmental authorities when required or permitted by law;
• Corporate affiliates, successors, or acquirers in connection with a business transaction.

BrightChamps does not sell children's personal information.

Certain classes, sessions, communications, or activities may be recorded or monitored for:

• Educational purposes;
• Student support;
• Quality assurance;
• Instructor training;
• Safeguarding and child protection;
• Compliance and dispute resolution;
• Security and fraud prevention.

Recordings may contain a child's image, voice, chat messages, participation, educational submissions, and other information shared during the session.

BrightChamps retains recordings only for as long as reasonably necessary for the purposes described in this Notice, the Privacy Policy, applicable agreements, and applicable law.

Subject to applicable law, parents and legal guardians may:

• Review personal information collected about their child;
• Request correction of inaccurate information;
• Request deletion of their child's personal information;
• Withdraw consent previously provided;
• Request that BrightChamps discontinue further collection or processing where permitted by law;
• Obtain information regarding BrightChamps' processing of their child's information.

Certain requests may be subject to verification procedures and legal, operational, educational, safeguarding, security, or record-retention requirements.

BrightChamps implements commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect children's personal information against unauthorized access, use, disclosure, alteration, or destruction.

However, no method of transmission over the Internet or electronic storage system can be guaranteed to be completely secure.

BrightChamps retains children's personal information only for as long as reasonably necessary to provide services, support educational activities, maintain records, comply with legal obligations, resolve disputes, enforce agreements, protect users, and fulfill the purposes described in this Notice.

Information may be retained for longer periods where required or permitted by applicable law.

BrightChamps operates globally and may process information in countries other than the country in which the child resides.

Where required by applicable law, BrightChamps implements appropriate safeguards designed to protect personal information transferred internationally.

BrightChamps may update this Children's Privacy Notice from time to time. Any updates will become effective upon posting the revised Notice unless otherwise required by applicable law.

Where required, BrightChamps will provide additional notice or obtain consent before material changes become effective.