Privacy Policy

This Privacy Policy ("Privacy Policy") describes how BrightChamps, its affiliates, subsidiaries, and related entities ("BrightChamps," "Company," "we," "us," or "our") collect, use, process, store, disclose, transfer, and otherwise handle personal information in connection with the websites, mobile applications, online platforms, products, educational programs, live classes, workshops, support services, and related offerings provided by BrightChamps (collectively, the "Services").

This Privacy Policy applies to all Users of the Services, including Students, Parents, Guardians, educators, instructors, schools, visitors, customers, and other individuals who access, interact with, register for, purchase, or use the Services in any manner, regardless of geographic location.

BrightChamps is committed to protecting the privacy, security, and confidentiality of personal information and aims to process such information in accordance with applicable privacy, data protection, consumer protection, and children's privacy laws, including, where applicable:

• the Digital Personal Data Protection Act, 2023 (India);
• the General Data Protection Regulation ("GDPR");
• the UK GDPR and UK Data Protection Act;
• the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA");
• the Children's Online Privacy Protection Act ("COPPA");
• and other applicable international privacy and data protection laws ("Applicable Privacy Laws").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where required under Applicable Privacy Laws, you consent to the collection, use, disclosure, storage, transfer, and processing of your information as described herein.

BrightChamps may collect, receive, generate, store, process, and otherwise handle different categories of information in connection with the Services, depending on how Users interact with the Platform, applicable legal requirements, and the nature of the Services used.

BrightChamps seeks to collect only such information as is reasonably necessary, relevant, proportionate, and appropriate for the purposes described in this Privacy Policy and Applicable Privacy Laws.

Account and Registration Information

We may collect information provided directly by Users, Parents, Guardians, Students, schools, or authorised representatives when registering for, enrolling in, purchasing, or using the Services, including:

• full name;
• username or account credentials;
• email address;
• telephone number;
• country, city, or region;
• date of birth or age range;
• educational grade or learning level;
• account preferences and settings;
• profile photographs or avatars where voluntarily provided.

Device, Technical, and Log Information

When Users access or interact with the Services, BrightChamps may automatically collect certain technical and device-related information, including:

• IP address;
• browser type and version;
• device identifiers;
• operating system;
• language preferences;
• network and connectivity information;
• application version;
• access timestamps;
• referring URLs;
• crash reports, diagnostics, and performance data.

Payment and Transaction Information

When Users purchase or subscribe to Services, BrightChamps and its authorised payment providers may collect payment and transaction-related information, including billing name and address, payment method details, transaction identifiers, subscription and purchase history, and payment status and billing records.

BrightChamps recognises the importance of protecting the privacy and safety of children and minors who use the Services. BrightChamps is committed to handling children's personal information responsibly and in compliance with applicable children's privacy and data protection laws.

BrightChamps designs its Services with safeguards intended to protect children's privacy, safety, and educational experience.

BrightChamps may collect limited personal information relating to children or Students in connection with providing the Services, including first name or display name, age, grade level, or learning profile, account and login information, class participation and attendance data, assignments, projects, assessments, and educational submissions.

BrightChamps seeks to limit the collection of children's personal information to information that is reasonably necessary, proportionate, and appropriate for educational, operational, safety, legal, and service-related purposes.

Where required under Applicable Laws, BrightChamps obtains consent from a Parent or Guardian prior to collecting, using, processing, or disclosing personal information relating to a child.

BrightChamps may collect, use, process, store, analyse, disclose, and otherwise handle personal information for legitimate educational, operational, contractual, security, compliance, and business purposes in accordance with this Privacy Policy and Applicable Laws.

• Providing and Operating the Services: Create, maintain, and manage User accounts; provide access to classes, educational content, and learning tools; operate, administer, and maintain the Platform and Services.
• Conducting Educational Activities and Classes: Conduct live classes, workshops, mentorship sessions, and educational activities; facilitate communications between Students, Parents, Instructors, and support personnel.
• Personalisation and User Experience: Recommend courses, programs, or educational content; tailor learning experiences and class participation; improve accessibility, usability, and platform functionality.
• Customer Support and Communications: Respond to inquiries, complaints, requests, or disputes; provide technical support and troubleshooting; send transactional, administrative, operational, or service-related communications.
• Analytics, Research, and Service Improvement: Analyse usage trends, engagement, and performance metrics; conduct internal research, quality assurance, testing, and diagnostics; improve educational content, curriculum design, and teaching methodologies.
• Safety, Security, and Safeguarding: Maintain the safety and integrity of the Platform and Services; monitor compliance with policies, guidelines, and legal obligations; detect, investigate, prevent, and address fraud, abuse, harassment, misuse, security incidents, or unlawful activity.
• Legal and Compliance Purposes: Comply with Applicable Laws, regulatory requirements, governmental requests, legal processes, and court orders; enforce the Terms of Service, policies, and contractual rights; establish, exercise, or defend legal claims.
• Marketing and Promotional Activities: Send newsletters, promotional messages, educational updates, offers, surveys, or event invitations; administer contests, scholarships, referral programs, promotions, and campaigns.

Where required under applicable data protection laws, including the General Data Protection Regulation ("GDPR") and the UK GDPR, BrightChamps relies on one or more lawful bases for collecting, using, processing, storing, transferring, and otherwise handling personal information.

Depending on the nature of the information and the purpose of processing, BrightChamps may rely on the following legal bases:

• Consent: BrightChamps may process personal information based on consent provided by the User, Parent, Guardian, school, or other authorised individual.
• Contractual Necessity: BrightChamps may process personal information where necessary to provide the Services requested by Users; create and manage accounts; conduct classes, educational activities, and support services.
• Legitimate Interests: BrightChamps may process personal information where necessary for legitimate business, operational, educational, security, or commercial interests.
• Compliance with Legal Obligations: BrightChamps may process personal information where necessary to comply with Applicable Laws, legal obligations, regulatory requirements, court orders, governmental requests, or child protection obligations.
• Protection of Vital Interests: In limited circumstances, BrightChamps may process personal information where necessary to protect the vital interests, safety, health, or security of a User, Student, child, Parent, Instructor, or another individual.
• Educational and Public Interest Purposes: Where permitted under Applicable Laws, BrightChamps may process certain information in connection with educational activities, safeguarding responsibilities, research, accessibility, or other purposes recognised under applicable education or public interest laws.

BrightChamps may share, disclose, transfer, or make available personal information in accordance with this Privacy Policy, the Terms, Applicable Laws, and legitimate business, educational, operational, safety, and compliance requirements.

BrightChamps does not sell children's personal information and does not knowingly disclose children's personal information for behavioural advertising purposes where prohibited under Applicable Laws.

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 operates globally and may process, access, store, transfer, or disclose personal information in multiple jurisdictions where BrightChamps, its affiliates, service providers, educational personnel, vendors, contractors, cloud infrastructure providers, or technology partners operate.

Personal information may be transferred to, stored in, or accessed from countries outside the User's state, province, or country of residence, including jurisdictions that may have data protection laws different from those in the User's jurisdiction.

By accessing or using the Services, Users and, where applicable, Parents or Guardians acknowledge and understand that personal information may be transferred internationally in connection with the operation and provision of the Services, subject to this Privacy Policy and Applicable Laws.

BrightChamps takes reasonable and appropriate measures designed to safeguard personal information transferred across borders and, where required under Applicable Laws, may implement appropriate transfer mechanisms and safeguards, including contractual data protection obligations, data processing agreements, standard contractual clauses or equivalent approved transfer mechanisms, and adequacy decisions recognised by competent authorities.

BrightChamps retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, the Terms, educational and operational requirements, contractual obligations, legitimate business purposes, and Applicable Laws.

The retention period applicable to personal information may vary depending on factors including the nature and sensitivity of the information, the purpose for which the information was collected or processed, educational, safeguarding, and student support requirements, and legal, tax, accounting, audit, regulatory, or reporting obligations.

BrightChamps may retain different categories of information for different periods of time, including account information, class participation records, communications, support records, recordings, payment records, safety-related records, and technical or usage information.

Where deletion is requested, BrightChamps may retain certain information for a reasonable period where retention is required or permitted under Applicable Laws, legitimate legal interests, compliance obligations, fraud prevention purposes, safeguarding obligations, dispute resolution, technical limitations, backup systems, or internal recordkeeping requirements.

BrightChamps and its authorised service providers may use cookies, pixels, tags, software development kits (SDKs), local storage objects, web beacons, APIs, device identifiers, analytics tools, and similar tracking technologies ("Tracking Technologies") to operate, secure, maintain, personalise, analyse, and improve the Services.

These Tracking Technologies may collect information relating to Users' devices, browsers, interactions, usage patterns, preferences, sessions, and engagement with the Services.

Types of Tracking Technologies We Use

• Essential and Functional Technologies: Operate and maintain the Services; authenticate Users and maintain secure sessions; remember preferences and settings; support accessibility, navigation, and user experience.
• Analytics and Performance Technologies: Understand usage trends and engagement; analyse traffic, features, and platform performance; identify technical issues and errors; improve educational content, features, and user experience.
• Communication and Support Technologies: Support customer service and troubleshooting; enable communications and notifications; improve support interactions and response quality.
• Advertising and Marketing Technologies: Provide promotional communications; measure campaign effectiveness; understand user engagement; personalise marketing and outreach activities; deliver relevant advertisements.

Most browsers and devices allow Users to manage or control cookies and Tracking Technologies through browser settings, device settings, consent tools, or privacy controls. Users may generally choose to block or disable cookies, delete stored cookies, restrict certain tracking technologies, manage advertising preferences, or opt out of certain analytics or marketing technologies.

BrightChamps may communicate with Users, Parents, Guardians, Students, and prospective users in connection with the Services, accounts, educational activities, support, operations, safety, legal compliance, promotions, and related business purposes, subject to Applicable Laws.

Service and Administrative Communications

BrightChamps may send service-related, transactional, operational, educational, or administrative communications that are necessary for the operation and delivery of the Services, including communications relating to account creation and authentication, enrollment, scheduling, reminders, and class updates, payment confirmations, invoices, renewals, and billing matters, support responses and technical assistance, security alerts, safeguarding notices, or policy updates, and platform changes, maintenance, outages, or operational notices.

Marketing and Promotional Communications

Subject to Applicable Laws and applicable consent requirements, BrightChamps may send communications relating to educational programs, courses, workshops, and events, promotions, discounts, referral programs, and offers, newsletters, updates, and announcements, and new features, products, or services.

Users may opt out of receiving marketing or promotional communications at any time by using unsubscribe or opt-out links, adjusting account or communication preferences, or contacting BrightChamps support.

BrightChamps may record, monitor, review, retain, analyse, and store live classes, tutoring sessions, workshops, mentorship sessions, assessments, communications, support interactions, and other activities conducted through the Services or connected communication platforms ("Class Recordings").

By accessing or using the Services, Users and, where applicable, Parents or Guardians acknowledge and consent to such recording, monitoring, review, storage, and processing in accordance with this Privacy Policy, the Terms, and Applicable Laws.

Class Recordings and monitoring activities may include audio and video recordings, chat messages and interactive communications, shared screens, whiteboards, assignments, or presentations, user participation and attendance information, classroom interactions and activities, and technical logs and metadata associated with the session.

Purposes of Recordings and Monitoring include delivery and operation of the Services, educational continuity and class administration, safeguarding, child safety, and trust and safety investigations, quality assurance and service improvement, instructor training, supervision, and performance evaluation, dispute resolution and complaint handling, fraud prevention, abuse detection, and security monitoring, and legal, regulatory, audit, and compliance purposes.

Subject to Applicable Laws, Users and, where applicable, Parents or Guardians may have certain rights and choices regarding the collection, use, disclosure, processing, retention, and handling of personal information by BrightChamps.

Such rights may vary depending on the User's jurisdiction, relationship with BrightChamps, nature of the information involved, and applicable legal or regulatory requirements.

Where provided under Applicable Laws, Users may have the right to:

• Request access to personal information processed by BrightChamps;
• Request correction, updating, or rectification of inaccurate or incomplete information;
• Request deletion or erasure of personal information;
• Request restriction or limitation of certain processing activities;
• Object to certain processing activities, including certain marketing or legitimate interest-based processing;
• Withdraw consent previously provided for processing activities based on consent;
• Request portability of certain personal information in a structured, commonly used, and machine-readable format where technically feasible;
• Lodge complaints with applicable supervisory authorities, regulators, or data protection authorities where permitted under Applicable Laws.

BrightChamps shall process requests in accordance with Applicable Laws and may limit or deny requests where permitted or required under Applicable Laws.

BrightChamps implements commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, disclosure, misuse, alteration, loss, destruction, or other unlawful processing.

Such safeguards may include measures relating to access controls and authentication procedures, encryption and secure transmission technologies where appropriate, network, application, and infrastructure security measures, monitoring, logging, and fraud-prevention systems, role-based access restrictions, vendor and service provider oversight, data minimization and retention controls, employee, instructor, and contractor confidentiality obligations, and incident response and security management procedures.

Notwithstanding the foregoing, no method of transmission over the Internet, electronic storage system, or security measure can be guaranteed to be completely secure, uninterrupted, or error-free. Accordingly, BrightChamps cannot guarantee absolute security of any information transmitted to, through, or stored on the Services.

Users are responsible for maintaining the confidentiality and security of their account credentials, devices, authentication methods, and access information, and for preventing unauthorized access to their Accounts. Users should promptly notify BrightChamps of any suspected unauthorized access, compromise, misuse, or security incident relating to their Account or personal information.

BrightChamps is committed to protecting the privacy, safety, and personal information of children and students using the Services. BrightChamps complies with applicable children's privacy and data protection laws, including, where applicable, the Children's Online Privacy Protection Act ("COPPA"), the General Data Protection Regulation ("GDPR"), the UK GDPR, and other Applicable Laws relating to children's data protection and educational privacy.

The Services are intended to be accessed by Students only with the involvement, supervision, authorisation, or consent of a Parent, Guardian, school, or authorised educational institution, where required under Applicable Laws.

Where required under Applicable Laws, including COPPA and similar children's privacy laws, BrightChamps obtains or relies upon verifiable parental or guardian consent before collecting, using, processing, storing, disclosing, or otherwise handling a child's personal information in connection with the Services.

Parents and Guardians acknowledge that by registering a Student, purchasing Services, enrolling a Student in classes, creating a Student Account, authorising access to the Services, or otherwise permitting a child to use the Services, they represent and warrant that they are legally authorised to provide consent on behalf of the Student and they consent to BrightChamps' collection, use, processing, storage, transfer, disclosure, monitoring, recording, and handling of the Student's personal information in accordance with Applicable Laws, these Terms, and the Privacy Policy.

The Services may contain, integrate with, rely upon, or provide access to third-party websites, applications, platforms, tools, software, content, communication services, payment processors, authentication providers, analytics providers, advertising partners, cloud infrastructure providers, educational tools, video conferencing services, social media platforms, or other third-party products and services ("Third-Party Services").

BrightChamps does not own, operate, or control Third-Party Services and does not endorse or guarantee the availability, accuracy, legality, security, reliability, functionality, or practices of any Third-Party Services.

Users acknowledge and agree that:

• Access to or use of Third-Party Services may be subject to separate terms, licenses, privacy policies, and conditions imposed by the applicable third party;
• BrightChamps is not responsible for the content, operations, uptime, availability, security, or performance of Third-Party Services;
• BrightChamps is not responsible for any acts, omissions, failures, errors, outages, data practices, or security incidents attributable to Third-Party Services;
• Interactions, transactions, communications, or disputes between Users and third parties are solely between the applicable parties.

Where Third-Party Services process personal information on BrightChamps' behalf, BrightChamps may implement commercially reasonable contractual, organizational, or technical safeguards intended to support compliance with Applicable Laws.

BrightChamps recognizes that Users in certain jurisdictions may have specific privacy and data protection rights under Applicable Laws. Depending on the User's location and the nature of the Services provided, additional rights, disclosures, protections, or obligations may apply.

Nothing in this Privacy Policy is intended to limit or exclude any non-waivable rights available under Applicable Laws.

For Users located in the EEA, United Kingdom, or Switzerland: BrightChamps processes personal information in accordance with applicable data protection laws, including the General Data Protection Regulation ("GDPR") and the UK GDPR. Subject to applicable conditions and limitations, Users may have rights to access personal information, request correction of inaccurate information, request deletion of personal information, restrict or object to certain processing activities, withdraw consent where processing is based on consent, request portability of certain information, and lodge complaints with applicable supervisory authorities.

For Users located in California and other U.S. jurisdictions: Depending on the applicable U.S. state laws, Users may have certain rights relating to their personal information, including rights to know what categories of personal information are collected, request access to or deletion of personal information, correct inaccurate information, opt out of certain data sharing or targeted advertising activities, and receive equal service and pricing regardless of exercising privacy rights.

For Users located in India: BrightChamps seeks to process personal information in accordance with applicable Indian laws, including the Digital Personal Data Protection Act, 2023 ("DPDP Act"). Subject to Applicable Laws, Users may have rights to access information regarding processing activities, request correction or updating of personal information, request deletion of personal information, withdraw consent where processing is based on consent, and seek grievance redressal through designated mechanisms.

BrightChamps reserves the right to modify, update, revise, or amend this Privacy Policy at any time in response to changes in the Services, business operations, technologies, legal requirements, regulatory obligations, industry practices, or other operational needs.

Any updated version of this Privacy Policy shall become effective upon posting on the Platform or otherwise making it available through the Services, unless otherwise required under Applicable Laws.

Where required under Applicable Laws, BrightChamps may provide additional notice regarding material changes, including through email, in-platform notifications, website notices, account notifications, consent mechanisms, or other reasonable means of communication.

Users are encouraged to periodically review this Privacy Policy to remain informed about BrightChamps' privacy practices and any updates or modifications.

Continued access to or use of the Services following the effective date of an updated Privacy Policy constitutes acknowledgment of such updates to the fullest extent permitted under Applicable Laws.