Privacy Policy

Brightfox provides customized test prep and tutoring programs, in person and online. This Privacy Policy ("Privacy Policy" or "Policy") explains our practices regarding the collection, use, and disclosure of information that we receive through our website located at www.gobrightfox.com (the "Site"), our staff and facilities, the software and technologies we provide, written materials you may provide, and our communications with you (collectively, the "Services"). It also serves as a way to help you understand and exercise your privacy rights. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we'll notify you of those changes by posting them within the Services or by sending you an email or other notification, and we'll update the "Last Updated" date above to indicate when those changes become effective.

Information That We Collect

This section describes the different types of Personal Data we may obtain about you.

Information that You Provide Directly

• Sign Up Information: When you sign up to create an account, we collect and retain certain information that can be used to identify you ("Personal Data"), including your name, email address, phone number, residential address; as well as name, contact information, educational experience and goals of the students who you will allow as Authorized Users.
• Through Communicating with Us: You may provide information to us when you use the Services, including when you contact, respond to surveys, or provide feedback about the Services. This information may include your name, email address, phone number, address, and other information that may relate to you or identify you.
• Purchase and Payment Information: When you pay for the Services, we will keep records of what you purchased or ordered, and will request financial information so we can charge you for the purchase. We use a third-party payment processor (Stripe) to process payments. We do not directly collect or store any payment card information entered through our Services.
• Through Interactive Features: If you use any of our interactive features, such as messaging between Users or comment features, we will collect information that you might submit or make available.
• Job Applications: We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

Information Collected Automatically

Information Sent by Your Device: We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to IP Address, user agent information, network and connectivity information, device identifiers, language preferences, software and operating system names and versions, and other information about your use of our Services.

• Location Information: When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by requesting precise location through your browser settings.
• Cookies and Web Technologies: We utilize automated data collection tools such as cookies, web beacons, and pixel tags to collect certain information from Users. These tools are used for User authentication, account security, delivery and measuring of advertising, analyzing site traffic and trends, and fraud prevention. We use Necessary, Performance, Preference, and Marketing cookies.
• Interaction Data: We also collect information relating to the actions that you perform while logged into your account.

Information From Third Parties

We may also obtain information about Users from third parties, including but not limited to affiliates, joint marketing partners, lead providers, fraud and risk mitigation vendors, and identity verification services.

How We Use the Information

Our primary goals in collecting information are to provide and improve our Services, to customize content and the Services for you, to administer your use of the Services, and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:

• Providing our Services, including the tutoring services and communications related to those, to communicate with you, and to provide customer support;
• Resolving disputes, responding to inquiries, collecting and processing payments and troubleshooting problems;
• Managing our everyday business needs, including auditing, administration of the Services, fulfillment, analytics, fraud prevention, and enforcement of our Terms of Service;
• Customizing your experience and otherwise measuring and improving our content and Services;
• Sending you relevant emails and communications (including keeping you informed about our products, offerings, and any promotional offers) that might be of interest to you;
• Enforcing our agreements, terms, conditions, and policies, and sending you notices and alerts;
• Better understanding our Users' interests, behaviors, and demographics;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.

Information that We Share with Third Parties

We may share information you provide us, including your Personal Data, with third parties in the following scenarios:

• Services Providers and Business Partners: We may engage third-party service providers to help us administer, provide, and improve the Services, including web hosting providers, cloud hosting providers, fraud detection services, and customer support partners.
• At Your Request: We may share information about you with third parties in the event that you request we do so.
• Our Subsidiaries and Affiliates: We share information with our corporate subsidiaries and affiliates for our administrative purposes.
• Information Shared with Web Analytics Services Providers: We use Google Analytics to gather information about how Users engage with our Site and Services.
• Information Disclosed in Connection with Business Transactions: If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer.
• Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law.

Your Privacy Rights

Based upon the laws that apply in your jurisdiction, you may have some or all of the following rights related to your privacy and Personal Data. To inquire about or to exercise any of these rights, you may contact us at hello@gobrightfox.com.

• Access: the right to access Personal Data about you, including confirming whether we are processing your Personal Data and obtaining access to or a copy of your Personal Data;
• Correction: the right to request correction of your Personal Data where it is inaccurate or incomplete;
• Deletion: the right to request deletion of your Personal Data;
• Objection: the right to request restriction of or object to our processing of your Personal Data; and
• Withdraw Consent: the right to withdraw your consent to our processing of your Personal Data.

Your Choices

We offer you choices regarding the collection, use and sharing of your Personal Data and we'll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

• Opt-Out of our Mailings: We may periodically send you free newsletters and emails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the email you receive.
• Cookie and Ad Tracking Choices: You can opt out of the collection and use of your information for ad targeting by configuring the settings on your browser, or by using cookie blocking extensions in your browser.
• Modifying Your Information: You can access and modify the Personal Data associated with your account by sending an email to hello@gobrightfox.com. If you want us to delete your Personal Data or your account, please contact us at the same email address with your request.

The Security of Your Information

We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Data Retention

We need to retain the information you provide us in order to provide our Services, and we retain such information for as long as you maintain your account, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a Third-party Service is provided directly to the owner or operator of that service and is subject to the owner's or operator's privacy policy. We're not responsible for the content, privacy, or security practices and policies of any Third-party Service.

Our Policy Toward Children

Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete such information from our files as soon as possible.

Use of Google User Data

Brightfox's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the limited use requirements.

Privacy Questions

We know issues of privacy and data protection are complex. But we're here to help in any way we can. Please contact us via email if you have any questions about your Personal Data, our data practices, or this Privacy Policy.

Brightfox Education, Inc. 2000 Crow Canyon Place, Suite 185 San Ramon, CA 94583 hello@gobrightfox.com