Privacy Policy

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.

This privacy policy covers all sites and apps where this policy is posted - that might be on our own sites or on apps we make available on third-party sites or platforms (e.g. the App store or Google Play store).


When you provide information to us on a third-party site or platform (for example, via our apps), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our apps. Our sites and apps may contain links to other sites not owned or controlled by us. We are not responsible for the privacy practices of those sites.

This privacy policy tells you how we look after your personal information when you visit our sites or apps (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.


If you have any questions, or good privacy related jokes, please contact us on hi@brightlittlelabs.com.


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.


We review our privacy policy regularly. This version was last updated on 28 May 2020.


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.


Aggregate Data is data that could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.


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.

  • Submissions Information includes

      1. Draft manuscripts, scripts, concept art, and other creative material submitted via the Website (or other means) for us to review.

      2. Profession, manuscript synopsis, whether or not previously published.

      3. Employment Information

      4. Job title, prior experience, references, CV and or other information relating to your personal professional employment history.


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.

  • Automated technologies or interactions. As you interact with our sites or apps, we will automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this information by using cookies and other similar technologies (see Online Tracking Technology section below). We may also receive Technical Information about you if you visit other websites employing our cookies, including for interest-based advertising. Please see our cookie policy for further details.

  • 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:

  • Where you submit Submissions Information in order for us to review a draft manuscript or other materials at our invitation;

  • 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;

  • Provide you with targeted advertising based on your activity on our sites and apps and on third-party sites and applications. To learn more about how we use your information for personalisation and tracking, please visit our Cookie Policy;

  • 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


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.


If a change happens to our business, for example our business (or part of it) is acquired, or we acquire another business, then the new owners may use your personal information in the same way as set out in this privacy policy.

Our third party providers:

  • G Suite Services

  • Firebase

  • Webflow

  • Mailchimp

  • Facebook

  • Breezy HR

  • Xero

  • Unity

  • AWS

  • Apple

  • Google Android


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:


Cookies. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your user experience more efficient, and some of our services will not function properly.


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.

Web beacons. Web beacons are small pieces of data that are embedded in images on the pages of sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use web beacons to bring together information we collect about you.

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:


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:

  1. 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.

  2. 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.

  3. 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 hi@brightlittlelabs.com. Please allow up to thirty (30) days for a response.