1. Scope of this policy
We are Bright Little Labs Limited - [we make big stories for small people]. We are responsible for your personal information, which gives us the exciting title (according to the General Data Protection Regulation (GDPR) (EU) 2016/679) of “data controller”.
Bright Little Labs R.E.S.P.E.C.Ts your privacy and is committed to protecting your personal information.
If you have any questions, or good privacy related jokes, please contact us on firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). But we’re a friendly bunch, so please talk to us first before you approach the ICO and hopefully we can help.
2. The types of information we collect about you
We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of data, aggregate data.
Personal information means any information about an individual from which that person can be identified.
Anonymous information means information that does not directly, or indirectly identify and cannot be reasonably used to identify an individual.
We may collect, use, store and transfer the following types of information:
- Identity information includes first name, last name, country of residence, date of birth, username, and password.
- Contact information includes email address and telephone numbers.
- Technical information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or apps.
- Messaging information sent either one-to-one or within a limited group using our message, chat, post, or posted as a comment in our sites or apps, or similar functionality, where we are permitted by applicable law to collect this information;
- Usage information includes information about how you use our websites or apps on third-party sites or platforms, our products, services, or open emails we send.
3. How we collect your information
We use different methods to collect this information:
- Direct interactions. You may give us your Identity and Contact information by corresponding with us by post, phone, email or register with us via one of our products or sign up for marketing materials.
- Third parties or publicly available sources. We collect information using analytics tools, including when you visit our sites and apps or use our apps on third-party sites or platforms. We get information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorise the third party to share your information with us before we can acquire it.
4. How we use your personal information
Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:
- Provide you with the experiences, products, and services you request, view, engage with, or purchase;
- Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and apps or changes to our policies;
- Send you offers and promotions for our products and services or third-party products and services;
- Personalise content and experiences;
- Operate, understand, optimise, develop, or improve our sites, apps, products, services and operations, including by using analytics tools; and
- Detect, investigate and prevent activities that may violate our policies or be illegal.
5. Third Parties
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
For more insight, you may want to read Shopify’s Terms of Service or Privacy Statement.
Other third parties
We may share your personal information with the parties set out in the table below, so that we can properly carry out the activities listed in Section 4.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Our third party providers:
G Suite Services
HubSpot Ireland Limited
6. Online Tracking Technologies
We and certain service providers operating on our behalf, collect information about your activity, or activity on devices associated with you, on our sites and apps using tracking technologies such as cookies, pixels, tags, software development kits (SDKs), application program interfaces (APIs), and web beacons. Definitions for some of the tracking technologies listed, as well as information about your choices with respect to them, are available below. This tracking data may be used for many purposes including to:
- Provide useful features to simplify your experience when you return to our sites and apps (for example, remembering your username);
- Deliver relevant content and marketing based on your preferences, usage patterns and location;
- Monitor, evaluate, and optimise the use and operation of our sites and apps; and
- Analyse traffic on our sites.
We may collect information whether or not you are logged in or registered, and may associate this tracking data with your registration account (if you have one), in which case we will treat it as personal information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.
You may choose not to receive targeted advertising from many ad networks and partners, data exchanges, and marketing analytics and other digital advertising and marketing service providers. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within apps by using the settings and controls on your devices (for example, by re-setting your mobile device’s advertising identifier and/or opting out of interest based ads).
Examples of online tracking technologies include:
Pixels. Pixels are pieces of code that work by placing and triggering cookies to track and optimise marketing services as you interact with our website and advertisements.
We use analytics for the purpose of analysing performance and usage of our products so that we can constantly learn and improve the experience that a user has. We use Google Analytics and Firebase Analytics. You can opt out of Google Analytics by visiting: https://tools.google.com/dlpage/gaoptout
Web browsers can transmit Do Not Track signals that indicate that a user does not wish to have activity tracked. Currently, no universally accepted standard exists for how to interpret such signals, clever people at other companies are working on this at the moment, but until then, we’re afraid our system does not support and does not act on DNT signal headers that we may receive.
7. International transfers
Many of our external third parties are based outside the EEA so their processing of your personal information will involve a transfer of information outside the EEA.
Whenever we transfer your personal information out of the EEA, we ensure at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
8. Keep your personal information safe
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Retaining your personal information
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your personal information: see Section 9: Your legal rights, below for further information.
In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. You can ask us to suspend the processing of your personal information in the following scenarios:
- If you want us to figure out if the personal information we hold is accurate
- Where our use of the personal information is unlawful but you do not want us to delete it.
- When you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
A few things to bear in mind:
- You won’t have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we might have to refuse to carry out your request.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Notice to California Residents / Your California Privacy Rights
Under California Civil Code § 1798.83, California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the prior calendar year. We do not share personal information with any unaffiliated third parties for their own marketing purposes. Nonetheless, you may make one request per year if you are a California resident. If making such a In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request this information in writing by contacting us at email@example.com. Please allow up to thirty (30) days for a response.
The information we collect from children
Our sites and apps offer activities that may collect information from children. Below we summarise potential instances of collection and outline how and when we will provide parental/guardian notice and/or seek parent/guardian consent.
When we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law.
In the event we discover we have collected information from a child in a manner inconsistent with regulatory requirements, we will either delete the information or immediately seek the parent/guardian consent for that collection.
Why we collect information from children
Personalise the experience: We collect information on how a child uses our sites and apps and the content they interact with to tailor their view of a service or personalise the content and features made available.
Improve and develop new services: We collect non-personal information to understand how our users interact with our sites and apps so we can improve them and develop new services to meet our users’ needs. We may also use this information to conduct statistical analysis and for business planning. For example, we will use the information to identify which aspects of our sites or apps are the most popular, so we can ensure that our tech infrastructure is sufficient to meet demand. We will also use the information to identify less popular aspects of our sites or apps to ensure that we are making things that our users love. We may aggregate this information with other users’ information and use it for statistical analysis, research and reporting purposes. We may also share this information with our business partners. This aggregated information cannot be used to identify a user or otherwise be traced back.
In order to respond to a question or request from a child: a child may choose to use one of our public email addresses to contact us or send us post to our public postal address. We believe that kids should ask lots of questions, so we believe it’s an important part of our service to reply to these communications.
Defend our Legal Rights We may also use personal information to prevent potentially illegal activities, protect the safety of our users and others, enforce our terms of service and comply with our legal and regulatory obligations, requests from government bodies or courts, or respond to litigation. Typically, we will do this because it is necessary in order to comply with a legal or regulatory obligation to which we are subject (e.g. complying with court orders).
How we collect information from children
A child can create a profile on some of our sites or apps. It does not require, or permit, the use of any personal information. Any profile created is anonymous, the child chooses a username from a a selection of pre-defined words. We do not collect any information that could identify them or their location in the creation of their profile.
Their profile shows:
- Username, which makes the use of a selection of pre-defined words;
- Avatar, which does not contain any personal information;
- Missions, levels, tasks which a child has completed; and
- Badges, stickers, rewards a child has collected.
Sharing and Search
There are no private channels or personal chat areas on our sites or apps. Children can’t search for each other on the sites or apps.
Communicating with Us
On occasion, in order to respond to a question or request from a child, we may need to ask for the child’s online contact information, such as an email address. We will delete this information immediately after responding to the question or request.
A child may provide us with personal information by communicating directly with us. For example, if a child chooses, they may use one of our public email addresses to contact us or send us post to our public postal address. The communication may require that we communicate more than once with the child. In such instances we will retain the child’s online contact information to honour the request. One example would be a newsletter that provides occasional updates about our sites, games, activities or competitions, or continued replies to email exchanges when children submit their “mission reports” to us via email and request to be sent further missions. We rely on our legitimate interest to respond to their letter or communication as we are using a child’s data in ways they would reasonably expect and which have a minimal privacy impact.
Whenever we collect a child’s online contact information for ongoing communications, we will request a parent or guardian’s email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
User Generated Content
Certain activities on our sites and apps allow children to create or manipulate content and save it. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, we plan to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
For competitions, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent/guardian email address (to notify the parent/guardian where required by law). We only contact the parent/guardian for more personalised information for prize-fulfillment purposes when the child wins the competition.
Of course, some competitions may ask the child to submit their own created content along with the child’s entry. In those instances, we may require parent/guardian consent prior to submission. Please see User Generated Content above for more information on our collection, notice, and consent policies.
Our sites and apps directed at children do not collect geolocation information that is specific enough to equate to the collection of a street address.
- provide children with access to features and activities on our sites and applications
- customise content and improve our sites and apps
- conduct research and analysis to address the performance of our sites and apps
- generate anonymous reporting for use by us
In the event we collect (or allow others to collect) such information from children on our sites and apps for other purposes, we will notify parents and obtain consent prior to such collection.
How and when we communicate with parents
Consistent with the requirements of COPPA and the GDPR, on any child-targeted site or app, we will ask for a parent or guardian’s email address before we collect any personal information from a child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at firstname.lastname@example.org. We will not use parent/guardian email addresses provided for parental consent purposes to market to the parent/guardian, unless the parent/guardian has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
About Verifiable Parental Consent
In the event we wish to collect personal information from a child, we are required to first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent/guardian can provide consent, and how the parent/guardian can revoke consent. If we do not receive consent within a reasonable time, we will delete the parent/guardian contact information and any other information collected from the child in connection with that activity.
In the event we collect personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to:
- asking for a credit card or other payment method for verification (with a nominal charge involved),
- speaking to a trained customer service representative by telephone or video chat, or
- requiring a signed consent form by mail, email attachment.
Teacher consent in lieu of a parent.
With regard to school-based activities in the US, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record in the US under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
Sharing information we collect from children with others
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, apps, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
Parent/Guardian Choices and Control
At any time, parents/guardians can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Parents/guardians can contact us to request access to, change, or delete their child’s personal information by contacting us. Provided we are comfortable that the parent/guardian holds parental responsibility for the child, then we will allow the holder of parental responsibility to exercise the child’s rights on their behalf. The exception to this is if, in the specific circumstances, we have evidence that this is not in the best interests of the child.
In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number.