Privacy Policy

How BrightChamps collects, uses, processes, stores, and protects your personal information

1. Introduction and Scope

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").

This Privacy Policy should be read together with the Terms of Service, Refund and Cancellation Policy, Cookie Policy, Community Guidelines, and any additional notices, disclosures, or supplemental privacy terms made available in connection with specific Services.

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.

If you are a Parent or Guardian accessing or using the Services on behalf of a Student or minor, you acknowledge and agree that you are providing consent on behalf of such Student or minor to the extent permitted under Applicable Laws.

If you do not agree with this Privacy Policy or are not authorised to provide consent where required, you must discontinue use of the Services.

BrightChamps may update, modify, or revise this Privacy Policy from time to time to reflect changes in legal requirements, business practices, technologies, or Services. Any updated version will become effective upon posting or otherwise communicating the revised Privacy Policy through the Services, unless otherwise required under Applicable Laws. Continued use of the Services following such updates constitutes acknowledgment of the revised Privacy Policy.

2. Information We Collect

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.

a. 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.

Where required under Applicable Laws, certain information may be collected from a Parent or Guardian instead of directly from a Student or minor.

b. Parent and Guardian Information

Where the Services are used by or for minors or Students, BrightChamps may collect information relating to Parents or Guardians, including:

  • Parent or Guardian name;
  • contact information;
  • relationship to the Student;
  • billing and payment details;
  • consent and authorisation records;
  • communication preferences;
  • participation history and support interactions.

BrightChamps may use Parent or Guardian information for account administration, student safety, parental consent verification, communications, customer support, billing, compliance, and related operational purposes.

c. Student Information

In connection with providing educational Services, BrightChamps may collect limited information relating to Students or minors, including:

  • first name or display name;
  • age, grade level, or learning profile;
  • class participation and attendance data;
  • assignments, projects, assessments, and educational submissions;
  • learning progress, performance metrics, and educational feedback;
  • interaction history within the Platform;
  • audio, video, images, or recordings created during participation in the Services.

BrightChamps does not knowingly collect more personal information from children than is reasonably necessary for the educational and operational purposes of the Services.

Where required under Applicable Laws, BrightChamps obtains consent from Parents or Guardians prior to collecting personal information from children or minors.

d. 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.

Such information may be collected using cookies, pixels, software development kits (SDKs), local storage, analytics tools, and similar technologies, subject to Applicable Laws and cookie or consent requirements.

e. Usage, Activity, and Platform Interaction Data

BrightChamps may collect information relating to how Users interact with the Services, including:

  • pages viewed and features accessed;
  • class participation and engagement;
  • clickstream and navigation activity;
  • course enrollments and completion data;
  • session duration and interaction metrics;
  • user preferences and settings;
  • searches and content interactions;
  • communications and participation history.

This information may be used for platform administration, analytics, service improvement, safety, fraud prevention, personalisation, troubleshooting, and operational purposes.

f. Class Recordings and Educational Content

BrightChamps may record, monitor, review, store, and process live classes, sessions, communications, and educational interactions conducted through the Platform or associated tools ("Class Recordings").

Such recordings may include:

  • audio and video;
  • chat communications;
  • screen sharing activity;
  • assignments or classroom interactions;
  • usernames, profile information, and participation details.

Class Recordings may be used for:

  • educational delivery and replay functionality;
  • safeguarding and safety monitoring;
  • instructor training and quality assurance;
  • dispute resolution;
  • customer support;
  • legal and compliance obligations;
  • internal operational purposes.

Where required under Applicable Laws, BrightChamps will not record or not obtain appropriate consent prior to recording sessions.

g. 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;
  • payment status and billing records.

BrightChamps generally does not store full payment card information unless permitted and secured in accordance with applicable payment processing and security standards.

Payment processing may be handled by authorised third-party payment processors subject to their respective privacy policies and contractual obligations.

h. Communications and Support Information

BrightChamps may collect and maintain records of communications and interactions with Users, including:

  • emails;
  • chat messages;
  • customer support requests;
  • feedback and survey responses;
  • call recordings where permitted;
  • complaint and dispute records;
  • communications with instructors or support teams.

Such information may be used for support, training, quality assurance, dispute handling, compliance, and service improvement purposes.

i. Marketing and Promotional Information

BrightChamps may collect information relating to marketing preferences and interactions, including:

  • subscription to newsletters or promotional communications;
  • participation in campaigns, events, surveys, contests, or referrals;
  • interactions with advertisements or marketing materials;
  • communication preferences and consent choices.

Where required under Applicable Laws, marketing communications will be sent only with appropriate consent or other lawful basis, and Users may opt out of such communications at any time.

j. Information from Third Parties

BrightChamps may receive information from third parties, including:

  • schools or educational partners;
  • Parents or Guardians;
  • social login or authentication providers;
  • analytics providers;
  • payment processors;
  • advertising and marketing partners;
  • customer support vendors;
  • publicly available sources where permitted under Applicable Laws.

Any such information will be handled in accordance with this Privacy Policy and Applicable Laws.

k. Sensitive Personal Information

BrightChamps does not intentionally collect sensitive personal information unless reasonably necessary for the provision of the Services, legal compliance, safety, accessibility, or educational accommodation purposes and permitted under Applicable Laws.

Where sensitive personal information is collected or processed, BrightChamps will implement additional safeguards and obtain any consent required under Applicable Laws.

3. Information Collected from Children

a. Commitment to Children's Privacy

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, including, where applicable:

  • Children's Online Privacy Protection Act ("COPPA");
  • General Data Protection Regulation ("GDPR");
  • the UK GDPR;
  • the Digital Personal Data Protection Act, 2023 (India);
  • the Family Educational Rights and Privacy Act ("FERPA"), where applicable;
  • and other applicable international privacy and child protection laws.

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

b. Collection of Children's Information

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;
  • audio, video, chat, and classroom interaction data;
  • device and technical information;
  • learning progress and performance information.

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.

BrightChamps does not knowingly require children to disclose more information than is reasonably necessary to participate in the Services.

c. Parental Consent and Authorisation

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.

By registering a child for the Services, creating a Student account, enrolling in classes, accepting the Terms of Service or this Privacy Policy, or otherwise permitting a child to access or use the Services, the Parent or Guardian represents and warrants that:

  • they are legally authorised to provide consent on behalf of the child;
  • they consent to BrightChamps' collection, use, processing, storage, disclosure, and handling of the child's information as described in this Privacy Policy and the Terms of Service;
  • they consent to the child's participation in the Services, including live classes, communications, educational activities, recordings, and related interactions conducted through the Platform.

Where required or deemed appropriate under Applicable Laws, BrightChamps may implement additional parental consent or verification mechanisms.

d. Use of Children's Information

BrightChamps may use children's information for purposes including:

  • providing and operating the Services;
  • enabling participation in classes and educational activities;
  • maintaining Student accounts and profiles;
  • facilitating educational progress tracking and reporting;
  • providing customer support and communications;
  • improving educational content, platform functionality, and user experience;
  • ensuring safety, security, safeguarding, and compliance;
  • preventing fraud, abuse, misuse, or unlawful activity;
  • complying with legal, regulatory, and contractual obligations.

BrightChamps does not knowingly use children's personal information for unlawful behavioural advertising or profiling prohibited under Applicable Laws.

e. Sharing and Disclosure of Children's Information

BrightChamps may share children's information only as reasonably necessary for the operation of the Services and in accordance with Applicable Laws, including with:

  • instructors, educators, and authorised service providers;
  • Parents or Guardians;
  • schools or educational partners authorised by Parents or applicable institutions;
  • technology, hosting, analytics, security, and payment providers;
  • professional advisors, auditors, or legal representatives;
  • governmental, regulatory, child protection, or law enforcement authorities where legally required or permitted.

BrightChamps does not knowingly sell children's personal information where prohibited under Applicable Laws.

f. Parental Rights

Subject to Applicable Laws and verification requirements, Parents or Guardians may have the right to:

  • review the child's personal information;
  • request correction or updating of information;
  • request deletion of the child's information;
  • withdraw consent for certain processing activities;
  • restrict or object to certain uses of information;
  • request discontinuation of further collection of the child's personal information;
  • manage account settings and permissions associated with the child's use of the Services.

BrightChamps may take reasonable steps to verify the identity and authority of any individual making such requests before responding.

Certain information may be retained where required or permitted under Applicable Laws, safeguarding obligations, dispute resolution requirements, educational record obligations, security purposes, or legitimate business needs.

g. Retention of Children's Information

BrightChamps retains children's personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, the Terms of Service, operational and educational purposes, safeguarding obligations, legal compliance, dispute resolution, enforcement, and other legitimate business purposes permitted under Applicable Laws.

When children's information is no longer reasonably necessary, BrightChamps will take reasonable steps to securely delete, anonymise, or de-identify such information in accordance with Applicable Laws and internal retention practices.

h. Unauthorized Collection of Children's Information

If BrightChamps becomes aware that personal information has been collected from a child in a manner inconsistent with Applicable Laws or without appropriate parental consent where required, BrightChamps will take reasonable steps to investigate the matter and, where appropriate, delete such information or restrict further processing in accordance with Applicable Laws.

4. How We Use Information

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.

Depending on the nature of the Services and the User's interaction with the Platform, BrightChamps may use information for the following purposes:

a. Providing and Operating the Services

BrightChamps may use information to:

  • create, maintain, and manage User accounts;
  • provide access to classes, educational content, and learning tools;
  • operate, administer, and maintain the Platform and Services;
  • facilitate enrollment, scheduling, attendance, assessments, and participation;
  • provide educational progress tracking, reports, and related features;
  • process transactions and manage subscriptions or purchases.

b. Conducting Educational Activities and Classes

BrightChamps may use information to:

  • conduct live classes, workshops, mentorship sessions, and educational activities;
  • facilitate communications between Students, Parents, Instructors, and support personnel;
  • review assignments, projects, assessments, and educational submissions;
  • maintain class recordings and educational history where permitted;
  • support educational delivery, classroom management, and learning continuity.

c. Personalisation and User Experience

BrightChamps may use information to personalise and improve the Services, including by:

  • recommending courses, programs, or educational content;
  • tailoring learning experiences and class participation;
  • remembering preferences, settings, and interactions;
  • customising communications, dashboards, and user interfaces;
  • improving accessibility, usability, and platform functionality.

d. Customer Support and Communications

BrightChamps may use information to:

  • respond to inquiries, complaints, requests, or disputes;
  • provide technical support and troubleshooting;
  • send transactional, administrative, operational, or service-related communications;
  • communicate updates relating to classes, subscriptions, billing, policies, or account activity;
  • provide customer care, onboarding assistance, and account management support.

e. Analytics, Research, and Service Improvement

BrightChamps may use information to:

  • analyse usage trends, engagement, and performance metrics;
  • conduct internal research, quality assurance, testing, and diagnostics;
  • improve educational content, curriculum design, and teaching methodologies;
  • develop, maintain, optimise, and enhance the Services and Platform;
  • evaluate effectiveness, safety, operational efficiency, and user experience.

BrightChamps may use aggregated, anonymised, pseudonymised, or de-identified information for research, analytics, benchmarking, and business improvement purposes to the extent permitted under Applicable Laws.

f. Safety, Security, and Safeguarding

BrightChamps may use information to:

  • 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;
  • protect Students, Users, Instructors, personnel, and the public;
  • conduct safeguarding reviews, investigations, and incident response activities.

g. Legal and Compliance Purposes

BrightChamps may use information to:

  • 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;
  • maintain records required for tax, accounting, auditing, child protection, dispute resolution, or regulatory compliance purposes.

h. Marketing and Promotional Activities

Subject to Applicable Laws and required consent requirements, BrightChamps may use information to:

  • send newsletters, promotional messages, educational updates, offers, surveys, or event invitations;
  • administer contests, scholarships, referral programs, promotions, and campaigns;
  • measure the effectiveness of marketing and outreach activities;
  • provide information regarding products, services, features, or programs that may be of interest.

Users may opt out of marketing communications at any time using the unsubscribe mechanisms provided or by contacting BrightChamps.

BrightChamps does not knowingly send unlawful direct marketing communications to children where prohibited under Applicable Laws.

i. Artificial Intelligence, Automation, and Product Improvement

BrightChamps may use information, including aggregated, anonymised, de-identified, or appropriately minimised information, to develop, test, improve, support, and enhance educational technologies, automated systems, artificial intelligence-enabled tools, safety systems, analytics capabilities, recommendation systems, and Platform functionality.

BrightChamps does not knowingly use children's personal information for unlawful profiling, solely automated decision-making producing legal or similarly significant effects, or prohibited behavioural advertising practices where restricted under Applicable Laws.

Where required under Applicable Laws, BrightChamps will implement additional safeguards, notices, consent mechanisms, or limitations relating to automated processing technologies.

j. Business Operations and Corporate Activities

BrightChamps may use information for legitimate business and operational purposes, including:

  • internal administration and reporting;
  • financial management and accounting;
  • auditing and compliance reviews;
  • insurance and risk management;
  • mergers, acquisitions, investments, restructuring, financing, or corporate transactions;
  • business continuity, disaster recovery, and operational management.

k. Other Disclosed or Permitted Purposes

BrightChamps may use information:

  • for any purpose disclosed at the time of collection;
  • as directed or authorised by the User, Parent, or Guardian;
  • with consent where required;
  • or as otherwise permitted or required under Applicable Laws.

6. Sharing and Disclosure of Information

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.

a. Instructors, Educators, and Service Providers

BrightChamps may share limited personal information with instructors, educators, mentors, tutors, evaluators, or authorised educational personnel solely to the extent reasonably necessary to:

  • conduct classes, workshops, mentorship sessions, or educational activities;
  • communicate with Students or Parents regarding the Services;
  • evaluate participation, assignments, attendance, or educational progress;
  • provide support, moderation, safeguarding, or safety-related functions;
  • comply with legal, educational, or operational obligations.

Instructors and educational personnel are contractually or operationally required to handle personal information in accordance with confidentiality, privacy, safeguarding, and applicable legal obligations.

b. Vendors, Processors, and Technology Providers

BrightChamps may share personal information with third-party vendors, contractors, processors, consultants, hosting providers, analytics providers, communication platforms, customer support providers, authentication providers, cloud service providers, infrastructure providers, and similar service providers that assist in operating, securing, maintaining, improving, or delivering the Services.

Such third parties may process information only on behalf of BrightChamps and subject to appropriate contractual, confidentiality, security, and data protection obligations, where required under Applicable Laws.

c. Payment Processors and Financial Service Providers

Payment transactions may be processed through third-party payment gateways, processors, financial institutions, subscription management providers, and fraud prevention partners.

BrightChamps does not generally store full payment card details except as permitted through secure payment providers and Applicable Laws.

The collection and processing of payment-related information may additionally be governed by the applicable privacy policies and terms of the relevant payment providers.

d. Analytics, Security, and Platform Improvement Providers

BrightChamps may share information with analytics, performance monitoring, fraud detection, cybersecurity, crash reporting, debugging, and platform optimisation providers to:

  • maintain platform functionality and security;
  • detect misuse, fraud, abuse, or technical issues;
  • analyse usage trends and engagement;
  • improve user experience, platform performance, and educational offerings;
  • support internal research, product development, and operational analytics.

Where reasonably possible, BrightChamps may use aggregated, anonymised, pseudonymised, or de-identified information for analytics, research, safety, and improvement purposes.

e. Legal, Regulatory, and Safety Disclosures

BrightChamps may disclose personal information where reasonably necessary to:

  • comply with Applicable Laws, legal obligations, subpoenas, court orders, governmental requests, regulatory inquiries, or law enforcement requests;
  • protect the rights, property, safety, integrity, or security of BrightChamps, Users, Students, Parents, instructors, or the public;
  • investigate fraud, abuse, policy violations, safeguarding concerns, or security incidents;
  • establish, exercise, or defend legal claims;
  • enforce the Terms, policies, or contractual rights;
  • comply with child safety, safeguarding, reporting, or educational obligations under Applicable Laws.

BrightChamps may also preserve and disclose information where required to prevent imminent harm, illegal activity, exploitation, abuse, or threats to safety.

f. Business Transfers and Corporate Transactions

Personal information may be disclosed, transferred, or assigned as part of an actual or proposed:

  • merger;
  • acquisition;
  • financing;
  • restructuring;
  • sale of assets;
  • corporate reorganisation;
  • bankruptcy;
  • change of control transaction;
  • investment transaction; or
  • transfer of all or part of BrightChamps' business or operations.

In such cases, BrightChamps may transfer personal information subject to applicable confidentiality, contractual, and legal protections.

g. Parent, Guardian, and Student Access

Parents or Guardians may access, review, manage, correct, or request deletion of certain Student information associated with their accounts, subject to Applicable Laws, educational obligations, verification requirements, and platform functionality.

BrightChamps may also share information between linked Parent and Student accounts where reasonably necessary for educational administration, account management, support, safeguarding, or operation of the Services.

h. With User Direction or Consent

BrightChamps may share personal information:

  • where Users or Parents expressly request or authorise such sharing;
  • where necessary to provide requested features, integrations, or services;
  • where consent has been obtained under Applicable Laws.

Users acknowledge that information voluntarily shared in public, community, collaborative, or interactive areas of the Services may be visible to others depending on platform functionality and account settings.

i. International Transfers of Information

BrightChamps may process, store, transfer, or access personal information in jurisdictions outside the User's country of residence where BrightChamps, its affiliates, vendors, processors, or service providers operate.

Where required under Applicable Laws, BrightChamps shall implement reasonable safeguards for cross-border data transfers, including contractual protections, data processing agreements, adequacy mechanisms, standard contractual clauses, or equivalent safeguards recognised under applicable data protection laws.

j. Aggregated and De-Identified Information

BrightChamps may use, process, disclose, transfer, publish, or otherwise utilise aggregated, anonymised, statistical, or de-identified information that does not reasonably identify an individual for lawful business, educational, research, analytics, security, operational, marketing, or product improvement purposes, to the extent permitted under Applicable Laws.

7. International Data Transfers

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.

Accordingly, 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;
  • adequacy decisions recognised by competent authorities;
  • technical, organisational, and security safeguards;
  • confidentiality and access control measures;
  • lawful consent mechanisms where required.

BrightChamps may also rely on lawful transfer bases recognised under Applicable Laws, including where transfers are:

  • necessary for performance of the Services or contractual obligations;
  • based on User or parental consent;
  • necessary for important public interest reasons;
  • required for establishment, exercise, or defence of legal claims;
  • necessary to protect vital interests;
  • otherwise permitted under Applicable Laws.

Where required under Applicable Laws, BrightChamps shall take commercially reasonable steps to ensure that recipients of personal information provide an adequate level of protection consistent with applicable privacy and data protection requirements.

However, Users acknowledge that no method of electronic transmission, cross-border transfer, storage, or processing can be guaranteed to be completely secure, and BrightChamps cannot guarantee absolute security of information transferred through international networks or third-party infrastructure.

Users accessing the Services from jurisdictions with specific international data transfer requirements acknowledge and agree that BrightChamps may transfer and process personal information internationally as reasonably necessary to provide the Services, maintain platform operations, ensure security and support, conduct educational activities, comply with legal obligations, and operate its global business functions.

8. Data Retention

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;
  • legal, tax, accounting, audit, regulatory, or reporting obligations;
  • dispute resolution, enforcement, fraud prevention, or security purposes;
  • contractual commitments;
  • technical and operational requirements;
  • User requests, account settings, or consent preferences;
  • Applicable Laws and regulatory guidance.

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.

Class recordings, support interactions, communications, and platform activity logs may be retained for quality assurance, safeguarding, dispute resolution, training, compliance, fraud prevention, security, and operational purposes for periods determined by BrightChamps in accordance with Applicable Laws and legitimate business needs.

BrightChamps may also retain and preserve information where reasonably necessary to:

  • comply with Applicable Laws;
  • comply with legal processes, subpoenas, court orders, or governmental requests;
  • establish, exercise, or defend legal claims;
  • investigate fraud, abuse, safeguarding incidents, policy violations, or security incidents;
  • enforce contractual rights, policies, or agreements;
  • maintain business continuity, backups, archives, audit trails, or disaster recovery systems;
  • protect the safety, rights, property, or integrity of BrightChamps, Users, Students, Parents, instructors, or third parties.

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 may also retain anonymised, aggregated, de-identified, or non-identifiable information for analytics, research, security, operational, educational, product improvement, and lawful business purposes to the extent permitted under Applicable Laws.

8.a Children's Information Retention

BrightChamps takes reasonable measures to retain personal information collected from children only for as long as reasonably necessary to fulfill the purposes for which the information was collected, provide the Services, comply with safeguarding and legal obligations, resolve disputes, enforce agreements, maintain security, or otherwise comply with Applicable Laws.

Where required under Applicable Laws, including COPPA and applicable child privacy laws, BrightChamps will delete or de-identify children's personal information when retention is no longer reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted under Applicable Laws.

Parents or Guardians may request deletion of a Student's personal information in accordance with Applicable Laws, subject to verification requirements, legal obligations, safeguarding requirements, dispute resolution needs, technical limitations, and lawful retention rights retained by BrightChamps.

9. Cookies and Tracking Technologies

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.

a. Types of Tracking Technologies We Use

BrightChamps may use the following categories of Tracking Technologies:

i. Essential and Functional Technologies

These technologies are used to:

  • operate and maintain the Services;
  • authenticate Users and maintain secure sessions;
  • enable account login and platform functionality;
  • remember preferences and settings;
  • support accessibility, navigation, and user experience;
  • protect against fraud, abuse, and security threats.

Certain essential technologies may be necessary for the Services to function properly.

ii. Analytics and Performance Technologies

BrightChamps may use analytics and performance tools to:

  • understand usage trends and engagement;
  • analyse traffic, features, and platform performance;
  • identify technical issues and errors;
  • improve educational content, features, and user experience;
  • measure effectiveness of communications and platform operations.

Analytics providers may include services such as:

  • Google Analytics;
  • Firebase Analytics;
  • crash reporting and diagnostics tools;
  • product analytics and performance monitoring providers;
  • internal analytics systems.

These providers may collect device information, IP address, browser type, session information, interactions, and usage-related data in accordance with their own privacy practices and Applicable Laws.

iii. Communication and Support Technologies

BrightChamps may use Tracking Technologies to:

  • support customer service and troubleshooting;
  • enable communications and notifications;
  • improve support interactions and response quality;
  • maintain security and operational integrity.

iv. Advertising and Marketing Technologies

Where permitted under Applicable Laws and applicable consent requirements, BrightChamps may use advertising, remarketing, audience measurement, and marketing technologies to:

  • provide promotional communications;
  • measure campaign effectiveness;
  • understand user engagement;
  • personalise marketing and outreach activities;
  • deliver relevant advertisements relating to BrightChamps services.

Such technologies may include services provided by:

  • Google;
  • Meta;
  • LinkedIn;
  • YouTube;
  • advertising and marketing partners;
  • attribution and campaign measurement providers.

These technologies may use cookies, pixels, device identifiers, and similar technologies to collect information regarding interactions with the Services and online activities across websites or platforms.

BrightChamps does not knowingly use behavioural advertising technologies directed toward children where prohibited under Applicable Laws, including COPPA or applicable children's privacy laws.

b. Browser and Device Controls

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;
  • opt out of certain analytics or marketing technologies.

However, disabling certain Tracking Technologies may affect the availability, functionality, performance, or user experience of portions of the Services.

c. Do Not Track Signals

Some browsers may transmit "Do Not Track" ("DNT") signals. Because there is currently no universally accepted standard governing DNT signals, BrightChamps may not respond to all such signals unless required under Applicable Laws.

d. Third-Party Technologies

Third-party providers that integrate with or support the Services may independently use cookies or Tracking Technologies in accordance with their own terms, privacy policies, and practices.

BrightChamps does not control third-party technologies or third-party data practices and encourages Users to review the applicable privacy policies of such providers.

e. Consent and Legal Compliance

Where required under Applicable Laws, BrightChamps will seek consent for the use of non-essential cookies or Tracking Technologies and provide Users with choices regarding certain categories of tracking and data processing.

Users may withdraw or modify consent preferences where such rights are available under Applicable Laws.

BrightChamps may also use aggregated, anonymised, pseudonymised, or de-identified information collected through Tracking Technologies for analytics, operational, educational, security, research, product development, and lawful business purposes to the extent permitted under Applicable Laws.

10. Communications and Marketing

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.

a. 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;
  • educational progress, assignments, reports, and participation;
  • platform changes, maintenance, outages, or operational notices;
  • legal, regulatory, or compliance-related matters.

Such communications may be delivered through:

  • email;
  • telephone calls;
  • SMS or text messages;
  • WhatsApp or similar messaging platforms;
  • in-platform notifications;
  • push notifications;
  • communication tools integrated with the Services.

Users acknowledge that certain service-related communications may be necessary for the provision, administration, security, or lawful operation of the Services and may continue even where marketing preferences are modified or withdrawn.

b. 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;
  • new features, products, or services;
  • surveys, feedback requests, and research initiatives;
  • marketing campaigns and brand engagement activities.

Marketing communications may be sent through email, SMS, WhatsApp, social media platforms, push notifications, digital advertising channels, or other lawful communication methods.

Where required under Applicable Laws, BrightChamps shall obtain appropriate consent before sending marketing communications.

c. Opt-Out and Communication Preferences

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;
  • replying with recognised opt-out instructions where applicable;
  • contacting BrightChamps support.

BrightChamps will process opt-out requests within a commercially reasonable period and in accordance with Applicable Laws.

Opting out of marketing communications does not prevent BrightChamps from sending necessary service-related, transactional, security, educational, legal, or administrative communications.

d. WhatsApp, SMS, and Automated Communications

Where permitted under Applicable Laws and subject to applicable consent requirements, Users consent to receive communications from BrightChamps through SMS, WhatsApp, automated messaging systems, prerecorded messages, or similar communication technologies using the contact details provided to BrightChamps.

Message frequency may vary depending on account activity, Services used, and communication preferences. Standard carrier, messaging, or data charges may apply.

Users are responsible for ensuring that contact information provided to BrightChamps is accurate and authorised for use.

e. Social Media and Community Engagement

BrightChamps may engage with Users, Parents, Guardians, educators, or communities through social media platforms, community forums, webinars, events, or interactive digital channels.

Users who interact with BrightChamps through social media platforms acknowledge that:

  • such interactions may be governed by the applicable platform's terms and privacy policies;
  • information voluntarily shared publicly may be visible to others;
  • BrightChamps may repost, feature, reference, or engage with publicly available content relating to the Services, subject to Applicable Laws and platform permissions.

BrightChamps may also use social media, audience matching, advertising, analytics, or campaign measurement tools provided by third-party platforms, subject to Applicable Laws and applicable consent requirements.

f. Advertising, Analytics, and Personalisation

BrightChamps may use analytics, attribution, advertising, and marketing technologies to:

  • measure campaign performance and engagement;
  • improve communications and user experience;
  • personalise educational recommendations, communications, or promotions;
  • better understand usage trends and user interests;
  • conduct lawful business analytics and research.

BrightChamps does not knowingly use children's personal information for behavioural advertising, interest-based advertising, profiling, or targeted marketing where prohibited under Applicable Laws.

Where required under Applicable Laws, BrightChamps shall obtain separate parental consent before using children's personal information for marketing, advertising, or related optional processing activities.

Parents or Guardians may withdraw such consent or manage communication preferences at any time in accordance with Applicable Laws.

g. Communication Records

BrightChamps may monitor, record, retain, review, or analyse communications, interactions, support requests, messages, calls, or related correspondence for purposes including:

  • quality assurance;
  • safeguarding and safety;
  • fraud prevention and security;
  • dispute resolution;
  • training and operational improvement;
  • compliance with Applicable Laws;
  • enforcement of the Terms and policies.

Such records shall be handled in accordance with this Privacy Policy, Applicable Laws, and lawful business and operational requirements.

11. Class Recordings and Monitoring

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.

a. Purposes of Recordings and Monitoring

BrightChamps may create and use Class Recordings and related monitoring activities for purposes including:

  • 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;
  • technical troubleshooting and platform support;
  • legal, regulatory, audit, and compliance purposes;
  • enforcement of the Terms, policies, and community standards;
  • protection of Users, Students, Parents, instructors, BrightChamps personnel, and the Platform.

b. Scope of Information Captured

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;
  • technical logs and metadata associated with the session.

BrightChamps may also collect and retain records relating to support communications, moderation actions, safeguarding reviews, and investigations associated with the Services.

c. Safeguarding and Child Safety

BrightChamps may monitor classes, communications, and interactions for safeguarding, safety, moderation, abuse prevention, fraud detection, policy enforcement, and compliance purposes.

Where reasonably necessary, BrightChamps may review, investigate, preserve, or disclose recordings or communications to:

  • investigate potential misconduct, abuse, exploitation, harassment, or safety concerns;
  • comply with Applicable Laws or safeguarding obligations;
  • respond to legal requests, regulatory inquiries, or law enforcement requirements;
  • protect the safety, rights, or welfare of Students, Parents, instructors, Users, or the public.

BrightChamps may also take moderation, disciplinary, safety, or enforcement actions based on information identified through recordings or monitoring activities.

d. Retention of Recordings

Class Recordings and monitoring-related information may be retained for periods determined by BrightChamps based on:

  • educational and operational requirements;
  • safeguarding and safety considerations;
  • dispute resolution and complaint handling needs;
  • legal, audit, tax, and regulatory obligations;
  • fraud prevention and security purposes;
  • technical and backup requirements;
  • Applicable Laws and lawful business interests.

Retention periods may vary depending on the nature of the recording, applicable legal obligations, internal policies, technical limitations, or the existence of disputes, investigations, or legal proceedings.

e. Access and Disclosure

Access to Class Recordings and monitoring information may be restricted to authorised personnel, instructors, service providers, moderators, compliance teams, legal advisors, auditors, or authorised third parties with a legitimate operational, educational, safeguarding, legal, or compliance-related need.

BrightChamps may disclose recordings or related information where reasonably necessary for legal compliance, safety, safeguarding, dispute resolution, enforcement, or protection of rights and interests in accordance with Applicable Laws.

f. User Restrictions

Users may not independently record, reproduce, distribute, publish, stream, screenshot, share, or otherwise exploit classes, recordings, communications, or interactions conducted through the Services except where expressly authorised by BrightChamps or permitted under Applicable Laws.

Unauthorised recording, distribution, or misuse of recordings or class content may result in suspension or termination of access to the Services and may give rise to legal action.

g. Third-Party Platforms and Communication Tools

Certain classes, communications, or sessions may be conducted through or supported by third-party communication, conferencing, hosting, or collaboration tools.

BrightChamps does not control the independent privacy, security, recording, or data handling practices of such third-party platforms and Users acknowledge that use of such platforms may additionally be governed by the applicable third-party terms and privacy policies.

12. User Rights and Choices

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.

a. Rights Relating to Personal Information

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

  • request access to personal information processed by BrightChamps;
  • request confirmation regarding whether BrightChamps processes personal information;
  • 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;
  • request information regarding categories of information collected, used, disclosed, or shared;
  • request information regarding third parties or categories of recipients with whom information has been shared;
  • opt out of certain marketing communications or optional processing activities;
  • 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.

b. Parent and Guardian Rights Regarding Children's Information

Where BrightChamps processes personal information relating to children or Students, Parents or Guardians may, subject to Applicable Laws and verification requirements, have the right to:

  • review personal information relating to their child;
  • request correction of inaccurate information;
  • request deletion of their child's personal information;
  • withdraw parental consent for future collection or processing activities;
  • manage communication, privacy, or consent preferences;
  • restrict or object to certain processing activities;
  • request information regarding how their child's information is collected, used, shared, or retained.

BrightChamps may require reasonable verification of parental or guardian authority before responding to requests relating to a child's information.

Certain information may continue to be retained where required or permitted under Applicable Laws, safeguarding obligations, dispute resolution requirements, fraud prevention purposes, educational administration requirements, technical limitations, or lawful business interests.

c. Withdrawal of Consent

Where processing is based on consent, Users or Parents may withdraw consent at any time by contacting BrightChamps or using available account or privacy settings.

Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal and may not affect processing conducted on other lawful bases permitted under Applicable Laws.

Users acknowledge that withdrawal of certain consents may impact the availability, functionality, or continued provision of certain Services or features.

d. Marketing and Communication Preferences

Users may opt out of receiving marketing or promotional communications by:

  • using unsubscribe or opt-out mechanisms;
  • adjusting communication preferences;
  • contacting BrightChamps support;
  • following applicable instructions included in communications.

Even where marketing preferences are modified, BrightChamps may continue to send necessary service-related, legal, security, educational, transactional, or administrative communications.

e. Account Information and Controls

Users with registered accounts may be able to access, review, update, correct, or manage certain account information directly through account settings or platform functionality, subject to platform capabilities and Applicable Laws.

Users are responsible for ensuring that information provided to BrightChamps remains accurate and updated.

f. Verification of Requests

To protect privacy, security, and the integrity of the Services, BrightChamps may require Users, Parents, Guardians, or authorised representatives to verify identity and authority before processing requests relating to personal information.

BrightChamps may request additional information reasonably necessary to authenticate requests, confirm authority, prevent fraud, or comply with Applicable Laws.

Where permitted under Applicable Laws, BrightChamps may decline requests that are:

  • unverifiable;
  • fraudulent or abusive;
  • technically infeasible;
  • repetitive or excessive;
  • inconsistent with legal obligations;
  • likely to adversely affect the rights, safety, or freedoms of others.

g. Jurisdiction-Specific Rights

Depending on jurisdiction, Users may have additional rights under Applicable Laws, including rights under:

  • the General Data Protection Regulation ("GDPR");
  • the UK GDPR;
  • the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA");
  • the Children's Online Privacy Protection Act ("COPPA");
  • India's Digital Personal Data Protection Act ("DPDP Act");
  • other applicable privacy, consumer protection, or child protection laws.

BrightChamps shall make commercially reasonable efforts to honour applicable rights requests in accordance with Applicable Laws.

h. Complaints and Regulatory Authorities

Users may have the right to lodge complaints with applicable supervisory authorities, regulators, or data protection authorities if they believe their rights under Applicable Laws have been violated.

BrightChamps encourages Users to first contact BrightChamps so that concerns may be addressed directly and efficiently where possible.

13. Security Measures

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;
  • 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.

Where required under Applicable Laws, BrightChamps may notify affected Users, Parents, Guardians, educational institutions, regulators, or authorities regarding certain security incidents, breaches, or unauthorized disclosures in accordance with applicable legal and regulatory obligations.

BrightChamps may periodically review, update, modify, or improve its security practices and safeguards in light of evolving technologies, operational needs, threats, legal requirements, and industry practices.

14. Children's Privacy

a. Commitment to Children's Privacy

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, the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Family Educational Rights and Privacy Act ("FERPA"), 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.

b. Verifiable Parental Consent

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.

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, the Parent or Guardian represents and warrants that:

  • they are legally authorised to provide consent on behalf of the Student;
  • they have reviewed and agreed to these Terms and the Privacy Policy;
  • 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.

Where permitted under Applicable Laws, BrightChamps may rely on consent obtained through the Parent or Guardian's acceptance of the Services, account registration process, payment process, school authorisation, classroom enrollment workflow, or other legally recognised consent mechanisms.

c. Information Collected from Children

BrightChamps seeks to limit the collection of children's personal information to information reasonably necessary to provide, operate, secure, improve, support, and maintain the Services and educational activities.

Depending on the Services used, BrightChamps may collect limited categories of information relating to Students, including:

  • student name or username;
  • age or date of birth;
  • parent or guardian contact information;
  • class participation information;
  • assignments, projects, submissions, and educational progress;
  • audio, video, chat, or class recordings;
  • device and technical information;
  • usage and activity information;
  • communications and support interactions.

BrightChamps does not knowingly require children to disclose more information than is reasonably necessary to participate in the Services.

d. Use of Children's Information

Children's personal information may be used for purposes including:

  • providing educational classes, tutoring, and learning activities;
  • account management and authentication;
  • student safety, safeguarding, moderation, and misconduct prevention;
  • communication with Parents, Guardians, schools, and Students;
  • customer support and troubleshooting;
  • platform operations, analytics, and service improvement;
  • legal, regulatory, compliance, and security purposes;
  • protecting the rights, safety, integrity, and security of Users and the Services.

BrightChamps does not knowingly use children's personal information for behavioral advertising, profiling, or interest-based advertising where prohibited under Applicable Laws.

Where legally required, BrightChamps will obtain separate parental consent before using children's personal information for marketing or advertising-related purposes.

e. Parents' and Guardians' Rights

Subject to Applicable Laws, Parents and Guardians may have the right to:

  • review their child's personal information;
  • request correction or updating of information;
  • request deletion of their child's personal information;
  • withdraw consent for further collection or processing;
  • object to or restrict certain processing activities;
  • request access to information regarding how children's data is processed;
  • manage certain privacy and communication settings associated with the Student Account.

Requests may be submitted through BrightChamps' designated privacy or support channels. BrightChamps may take reasonable steps to verify the identity and authority of the requesting Parent or Guardian before processing such requests.

f. Educational Institutions and School-Based Consent

Where the Services are provided through or in connection with a school, educational institution, teacher, district, or educational partner, BrightChamps may rely on the authorisation, consent, or instructions provided by such institution to the extent permitted under Applicable Laws.

Schools and educational institutions are responsible for ensuring that they have obtained any necessary consents, notices, authorisations, or permissions required under Applicable Laws before sharing Student information with BrightChamps or enabling Student access to the Services.

g. Retention and Deletion of Children's Information

BrightChamps retains children's personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, comply with Applicable Laws, resolve disputes, enforce agreements, protect Users, maintain educational records, prevent fraud or abuse, and satisfy legitimate operational or legal requirements.

BrightChamps may retain certain information where required or permitted by Applicable Laws, safeguarding obligations, legal process, regulatory requirements, dispute resolution needs, security purposes, or legitimate business interests.

When children's personal information is no longer reasonably required, BrightChamps will take commercially reasonable steps to delete, anonymise, or securely dispose of such information in accordance with Applicable Laws and internal retention practices.

h. Safeguarding and Monitoring

To promote student safety, service integrity, compliance, and safeguarding obligations, BrightChamps may monitor, review, moderate, record, or retain classes, communications, submissions, chats, recordings, and interactions occurring through the Services, subject to Applicable Laws and the Privacy Policy.

Parents and Guardians acknowledge and agree that such monitoring and recording may be necessary to:

  • provide educational Services;
  • investigate complaints or misconduct;
  • protect Students and Users;
  • enforce policies and legal obligations;
  • improve platform safety and operational integrity.

i. International Applicability

Children's privacy rights and protections may vary depending on the User's jurisdiction. BrightChamps endeavours to implement reasonable safeguards and compliance measures consistent with applicable international children's privacy and data protection laws.

Nothing in this Section limits any non-waivable rights available to children, Parents, or Guardians under Applicable Laws.

15. Third-Party Services and Links

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").

Third-Party Services may include, without limitation:

  • video conferencing and communication platforms;
  • payment gateways and payment processors;
  • cloud hosting and infrastructure providers;
  • analytics and performance monitoring providers;
  • authentication and login providers;
  • customer support and communication tools;
  • social media integrations;
  • educational integrations and classroom tools.

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 may receive, share, transmit, or process certain information through Third-Party Services as reasonably necessary to provide, support, secure, maintain, improve, or operate the Services in accordance with these Terms, the Privacy Policy, user instructions, or Applicable Laws.

Links to external websites or services are provided solely for convenience and informational purposes. BrightChamps is not responsible for the content, policies, practices, or availability of any external websites or resources and shall not be liable for any loss or damage arising from the use of or reliance upon such Third-Party Services or external resources.

Users are encouraged to review the applicable privacy policies, security practices, and terms of use of any Third-Party Services before interacting with or using such services.

16. Regional Privacy Rights

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.

a. European Economic Area ("EEA"), United Kingdom, and Switzerland

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;
  • lodge complaints with applicable supervisory authorities.

Where required under Applicable Laws, BrightChamps implements reasonable safeguards for international data transfers, including contractual protections, transfer mechanisms, or other legally recognized safeguards.

b. United States Privacy Rights

Depending on the applicable U.S. state laws, including laws in California and other jurisdictions, 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;
  • limit use of certain sensitive personal information where required under Applicable Laws;
  • receive equal service and pricing regardless of exercising privacy rights.

BrightChamps does not knowingly sell children's personal information where prohibited under Applicable Laws.

California residents may also have additional rights under applicable California privacy laws, including the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").

c. India

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") and related rules or regulations.

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;
  • seek grievance redressal through designated mechanisms.

Parents or Guardians acting on behalf of children may exercise applicable rights relating to children's personal information in accordance with Applicable Laws.

e. Exercising Regional Privacy Rights

Users, Parents, Guardians, or authorised representatives seeking to exercise applicable privacy rights may contact BrightChamps through the contact details or designated privacy channels provided in this Privacy Policy.

BrightChamps may take reasonable steps to verify the identity, authority, and authenticity of requests before processing them and may deny or limit requests where permitted or required under Applicable Laws.

Certain rights may be limited, delayed, or subject to exceptions under Applicable Laws, including where retention or processing is necessary for legal compliance, security, fraud prevention, safeguarding, dispute resolution, educational purposes, contractual obligations, or protection of rights and interests.

17. Changes to This Privacy Policy

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.

Where legally required, BrightChamps will obtain additional consent before implementing changes that materially affect the processing of personal information or children's personal information.

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.

18. Contact Us / Grievance Redressal

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy, or the manner in which your personal information is collected, used, processed, or disclosed, you may contact BrightChamps using the details below.

a. Privacy Contact

Email: privacy@brightchamps.com

We will use reasonable efforts to respond to your request within the timelines prescribed under Applicable Laws.

b. Grievance Officer (India – DPDP Act Compliance)

Grievance Officer: Surbhi Sharma
Email: grievance@brightchamps.com
Address: 1st Floor, 36/6, Hustle Hub Tech Park, 27th Main Road, PWD Quarters, Sector 2, HSR Layout, Bengaluru, Karnataka 560102

c. Verification and Response

BrightChamps may require Users to provide sufficient information to verify identity and/or authority before responding to requests or grievances.

We will make reasonable efforts to address and resolve grievances in accordance with Applicable Laws and within applicable statutory timelines, where required.

Where a complaint cannot be resolved internally, Users may also have the right to approach the relevant data protection authority or regulatory body under Applicable Laws.