You can trust Brainlox to safeguard your privacy: it's the foundation of a safe and secure community. The Brainlox Privacy Statement explains how we protect your privacy when you use Brainlox services or visit our public website. Some Brainlox services are provided by other organizations, such as schools and businesses. This Privacy Statement does not apply when you use Brainlox with an account tied to your organization, and when we work solely on their behalf. You are instead subject to their privacy policies when you use those services. As part of our services to schools that are subject to the Federal Educational Rights Privacy Act (FERPA), we provide protections as required by that act. This Privacy Statement applies if your organization gives you a voucher or offer code that allows you to create a Brainlox account directly.
For children under the age of 13, we take additional measures to protect their privacy due to Brainlox being a learning environment. Here are the details of Brainlox's children's privacy statement
The Brainlox "Services" include allowing registered parents or guardians ("Parents") to enroll learners ("Learners") in online small-group classes, and allowing registered teachers ("Teachers") to create, publicize, and offer those classes (the “Services”). In this Privacy Statement, Brainlox describes what personal information it collects from Brainlox registered Parents, Teachers, and Learners as well as how it collects and uses information from visitors to our public website and mobile app (collectively, "Sites"). In our Children's Privacy Statement, we describe a learner mode called Learner Space that provides additional protections to children under the age of 13 who use the Brainlox Services.
It is possible for us to collect information about you when you visit our Site, whether alone or in combination, that could identify you, your device, or your household ("Personal Data"), as described below.
In order to use the Services, we collect Personal Data from you when you directly provide it to us, such as when you register for a Brainlox account. Your Personal Data may include, for example, the following:
Credit card or other payment information
When you fill out the "about me" section of your profile or communicate with us, we collect your age, month and year of birth, gender, pronouns, marital status, and other demographic information.
Information about health or disabilities may be included voluntarily by parents in forms or messages sent to teachers to aid with learning. It is also possible for parents to enroll their children in special classes designed for children with disabilities. Discussions between teachers and learners are otherwise prohibited that may elicit or result in sensitive information being shared.
We may request a Parent to show us proof of the Learner's age, such as a birth certificate, passport, or driver's license. Documents such as these may reveal sensitive data such as full dates of birth, places of birth, and government identification numbers. Except for the month and year of birth, we do not record this information. In the course of receiving background reports, we may also receive sensitive information about teachers' criminal histories.
Content Files may include
✓ Enrolled in classes
✓ An automatic recording of your image and voice during classes
✓ The content and communications you share with the class or groups, such as your profile photo, and photos, documents, and messages you upload
✓ Linked to your Facebook account or your profile picture that you voluntarily provided
✓ Profile information you voluntarily provide in the "about me" section
✓ Review information provided voluntarily
✓ Teachers provide us with information to run background checks as well as third-party background check reports
✓ You provide notes to Teachers when enrolling your Learner.
Brainlox and our third-party partners may collect, receive, and store certain data when you use or interact with our Site. For example- The times you logged in, the search terms you entered, and the pages you visited, as well as other information about your browser and device.
Additionally, we may collect your IP address, device identifiers like cookie identifiers and mobile device identifiers, as well as your device's operating system and browser type.
Such information and other information may be used to track usage and device and system data, such as the total number of visitors to our Sites, the number of visitors to each page of our website, and the domain names of the Internet service providers you use. This data may also be used for interest-based advertising by us and our partners.
In order to purchase classes and other merchandise verify parental consent, some Personal Data is required, such as credit card payments. Teachers are also required to give us access to Personal Data pertaining to background checks. Live classes also require teachers to have their cameras on. The video feature of learners' devices must be enabled at least at the start of class to verify their identity, subject to authorized exceptions. There are certain Personal Data that you may decline to provide.
We primarily collect Personal Data about you from you. Third parties may also provide us with any of the above categories of information. These third-party sources include, for example:
✓ The applications and services of third parties, including social networks that you choose to connect with or interact with.
✓ Those who collect or provide data on our behalf, such as those who determine your device's location based on its IP address.
✓ Co-branding partners and joint marketing partners.
✓ Public sources of information such as open government databases and background check services we used for Teachers.
Brainlox may use any of the above categories of your Personal Data to:
✓ Process payments for our Brainlox Services, bill you, handle accounting, improve internal operations, secure our systems, detect fraudulent and illegal activity, and comply with our legal obligations;
✓ Troubleshoot, maintain, improve, and personalize the Brainlox Sites;
✓ Messages about new and recommended classes, groups, events, and other marketing content we may send to parents and teachers that you signed up for;
✓ Analyze website usage and usage of the Site's features, content, and pages
✓ Provide customer support and security alerts, as well as other administrative messages; confirm registration and send updates;
✓ Check your background if you are a teacher.
Our goal is to provide you with a seamless, consistent, and personalized experience by combining data from different sources. Recordings of Brainlox classes can be accessed by teachers, used to improve curriculum and classes, and shared with parents and learners. Besides providing feedback to teachers, Brainlox may also use class recordings for customer support and compliance purposes.
You may receive information from Brainlox about services and opportunities that we think you will find interesting if you are a Parent or Teacher. Each promotional email we send you will contain instructions allowing you to "opt-out" of receiving future promotional emails. In addition, if you wish not to receive any future communications or to have your contact information included in our opt-out lists, please contact email@example.com. We will continue to contact you via email to respond to your requests.
There is a possibility that your information, including Personal Data, will be transferred to and stored on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ. Providing information to us from outside the United States means the data, including Personal Data, will be transferred to and processed in the United States and India.
With your consent or authorization and with whom you have intentionally interacted, we may share your Personal Data with third parties. In order to complete your transaction and provide the services you've requested or authorized, we may need to share your Personal Data. For example, we use third parties to process credit card payments.
In addition, we may share data as follows:
(i) to comply with a legal obligation
(ii) to safeguard Brainlox, Teachers, Learners, and Parents' rights or property
(iii) to operate and maintain the security of our Sites, including the prevention or stopping of an attack on our computer systems and networks
(iv) to protect the personal safety of Site users or the public
(v) to avoid legal liability.In the course of working with Learners, teachers are required to report any suspicions of child abuse or neglect to Brainlox. Brainlox expects all Teachers to comply with their reporting obligations, including reporting suspected abuse or neglect to local authorities. Occasionally, Brainlox may report suspected cases of abuse and neglect.
Using our Site may allow you to share Personal Data, including communications, with third parties, including the general public. It is important that you avoid sharing sensitive Personal Data when you do so. Respecting other people's privacy and following our community standards, as well as other guidelines and restrictions on postings and sharing activities, such as sharing private information, communications, or documents, or sharing other Personal Data about others that may cause harm, embarrassment, or conflict, are expected of everyone. Personal Data about Learners or their families should not be revealed by your Learners or other Learners.
Your user profile will be publicly available to all users of our Services (the "User Profile"). There is no requirement for you to include any Personal Data in your User Profile. However, you will be given the option to include different types of Personal Data in your User Profile, which may include your first name, last name, biographical information, geographical location, and avatar. User Profiles are public, so any information you publish there becomes available to everyone. As soon as such information is published, we have no control over how it is used or distributed. If you include Personal Data in your User Profile, please consider it carefully.
As a teacher leading our online classes, you can share your video and photographic images, name, and username, as well as other information, such as your profile, demographic data, content and files, and general location information (such as your city or state)
We provide Teachers and Parents with the opportunity to share information on a variety of topics with other Brainlox Users through public forums (the "Public Forums"). It is entirely voluntary to use the Public Forums. It is important to realize, however, that any information you share in the Public Forums will be available to all Brainlox Users without restriction.
It is not our policy to systematically monitor the content of posts in the Public Forums. The public has access to any information published in Public Forums.
The Service allows learners to message teachers, parents to message each other, and parents and teachers to message each other. Teachers and learners can communicate with each other via messages. The use or dissemination of the information published, posted, or messaged is beyond our control. If you choose to share Personal Data with others on our Service, please think carefully before doing so.
It is possible for parents and teachers to log in using a Facebook account. We receive your name, profile picture, and email address from Facebook when you log in, and Facebook records when we access this information. Rather than providing your Facebook login information to Brainlox, you will provide it directly to Facebook. Facebook's privacy practices and other actions are governed by its policies; Brainlox is not responsible for how Facebook uses, stores, or discloses your information.
The Site takes reasonable measures to protect the Personal Data provided via the Site from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Internet security cannot be guaranteed, and we cannot guarantee or warrant the security of the information or content you provide. In addition, it is your responsibility to protect the credentials associated with your account. To protect your Personal Data, you should never disclose your password, and protect your username, password, and credentials used to access the Services. Make sure you don't share your username and password with anyone else.
By default, most web browsers accept cookies. It is possible to delete or reject cookies via your browser settings. We may be unable to provide certain features or services to you if you delete or reject cookies. You may need to recreate advertising preferences if you delete cookies controlled by those cookies.
Permission controls and mobile identifiers are available in iOS and Android operating systems. It is possible to limit tracking and/or reset advertising identifiers, as well as change permissions regarding push notifications and access to your camera and photos.
You can disable the automatic download of images, including web beacons, in most email clients, which prevents the automatic connection to the web servers hosting those images.
By setting Do Not Track in your web browser, you can tell websites that you do not want to be tracked. Your web browser's Preferences or Settings page allows you to enable or disable Do Not Track. Our site does not currently support Do Not Track signals, but we adhere to this Privacy Statement regardless of whether a user sets Do Not Track.
It is our responsibility to keep your Personal Data accurate and up-to-date, and we will provide you with mechanisms for correcting, amending, deleting, or limiting its use. Those parties to whom your information may be disclosed will be informed of this amended Personal Data as appropriate. To provide you with the best service possible, we need accurate Personal Data about you.
California consumers are the only ones covered by this portion of our Privacy Statement.
Our disclosure of "Personal Information," as defined in California Civil Code 1798.140(o), to California residents within the last twelve months includes the Personal Data described above in the
Each category of Personal Information we collect is used for the purposes described in the “What we do with your personal information?
In California, you have certain legal rights regarding your Personal Information. The following rights may be exercised, except as otherwise provided or excepted by applicable law:
✓ The types of Personal Information we have collected about you;
✓ Sources from which Personal Information is collected;
✓ The purpose for which we collect Personal Information;
✓ Third parties with whom we share Personal Information; and
✓ Your specific information that we have collected.
Section 22581 of the California Business and Professions Code gives California residents under 18 who are registered users of online services, applications, or websites the right to remove, or request, and obtain the removal of, content or information publicly posted by them. If you wish to remove content or information you have publicly posted, please send a detailed description to privacy@Brainlox.com. The law may not permit or require removal in certain circumstances, so your request does not guarantee complete or comprehensive removal of content or information posted online.
The following rights apply to Personal Data that we process under EU data protection law:
✓ Accessing, rectifying, or erasing your personal information is possible;
✓ A copy of your Personal Data in a usable and portable format is available to you if any automated processing is conducted based on your consent;
✓ You can withdraw your consent for future processing at any time if the processing is based on your consent;
✓ Under certain circumstances, you may object to or restrict the processing of your Personal Data;
✓ If you reside in France, you can provide us with specific instructions regarding the use of your data after your death.
Please use the contact information at the bottom of this statement to make such requests or to get in touch with our Data Protection Officer. In certain cases, such as relationships we have with schools, we process Personal Data on behalf of another party that is the "data controller." You should direct your request to that party. If you have any questions or concerns, we encourage you to contact us before lodging a complaint with a supervisory authority. When collecting and processing Personal Data about you, we rely on a variety of lawful bases, including with your consent and/or as necessary to provide you with the services you use, operate our Site and business, meet our contractual and legal obligations, protect our customers and systems, or fulfill other legitimate interests.
The Personal Data we collect is retained as long as necessary in order to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes. Depending on factors such as the expectations of users or consent, the degree of sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations, actual retention periods can differ significantly for different types of data and for different services. Our Class Recordings, for instance, are kept for 90 days following the date of the class.
The term cookie refers to a small text file containing a string of characters that can be placed on your computer or mobile device in order to uniquely identify your browser or device. A cookie is used in conjunction with a web beacon and similar technologies. You can read cookies placed on your device by web beacons (also known as single-pixel or clear GIF images).
Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device. Cookies are used with web beacons and similar technologies. Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email and can read cookies they place on your device.
We use third-party analytics and advertising providers on our website and in our emails. Read more about our approach here and how to opt-out of their use of certain of the above cookies and other technologies on our Site and in our emails in our Choice and Control section.
In our cookie article, linked above, you will find choices specific to your browser and device. You will need to opt-out separately on each device or browser from which you access our Site.
It is possible for us to change this Privacy Statement at any time. Should we decide to change this Privacy Statement in the future, we will post or provide an appropriate notice. As required by law, we will notify you about any material changes to the statement or obtain your consent before making such changes. This document indicates the date of the latest update at the top.
If you have any questions regarding Brainlox's Privacy Statement or the information practices of our Sites, please do not hesitate to contact us.
You may contact us as follows: You may send an email to privacy@Brainlox.com or send mail to: Brainlox, LLC, ………………………………
We describe in this section how we collect, use, disclose, obtain parental consent, and provide parental choice for information provided by Learners, including children under the age of 13 (“Child“ or “Children”). Our practices regarding Children's Personal Data in the United States are outlined in this policy in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA"). Visit https://consumer.ftc.gov/articles/protecting-your-childs-privacy-online for more information about COPPA and general tips for protecting children's online privacy.
Through our website and mobile app, Brainlox collects Personal Data about Children directly from Parents and directly from Children when we have verified parental consent. After parents complete the initial set up, our mobile apps are set to only be available in children's mode ("Learner Space"). Parents are expected to select the children's mode (e.g., the "Learner Space") when their children use our website service. To participate in online classes ("Classes") and to join online forums with other children ("Learner Groups"), children must be in Learner Space. Learner Space does not allow children to enroll in Classes or Learner Groups.
Children may mark Classes or Learner Groups they are interested in attending. Classes and Learner Groups can be viewed by parents. Classes and Learner Groups are only open to children whose parents enroll them. Based on your child's marked and enrolled Classes, we may make recommendations and offer classes based on his or her interests in topics. We receive the name and age of the child from the parents. Additional information may be provided by parents regarding their child's schooling, local time zone, and additional notes for the teacher. During online classes, children may also share information about themselves. Our systems record video images and audio of the children during Brainlox Class sessions and Learner Groups. As described in our general Privacy Notice, we may also collect Personal Data about Children in Learner Space, including passively collected data. Except for payment information, we do not collect payment information from Children or allow third parties to use the Personal Data collected through analytics or advertising cookies for their own purposes. Additionally, we do not collect more Personal Data than is reasonably necessary to provide our Services to Children. In online classes and when reporting emergency safety and compliance issues, children may also share information about themselves.
Upon obtaining verified parental consent, we may collect and use Personal Data about Children for many of the same purposes described in the general Privacy Notice. Children's activities on our Site, such as marking classes or Learner Groups, or enrolling in classes or Learner Groups, and using our mobile app or website, enable us to recommend classes, Learner Groups, and new features to Parents and Children. Children and Parents may receive these messages through push notifications if Parents enable this feature in the mobile app. Additionally, we may send emails to Parents about the recommendations and surveys and informational emails to children. Through Learner Space, we do not send promotional emails to Children or allow third parties to collect Personal Data for their own use.
The name, age, postal address, local time zone, and any notes Parents have provided about their Child are shared by Brainlox with the Class Teacher in order to facilitate classes, facilitate learner groups, and deliver supplies to children.
Students can also privately message their teachers. Notices and copies of these messages will be sent to parents. When children participate in classes, their video images, voice audio, and potentially background images of their home and family are shared with the teacher and other students. If parents are concerned about posting images of their home and family, they might consider using virtual backgrounds. In addition to sharing content, images, and videos during class sessions, students may also divulge information about themselves to their Teacher and classmates voluntarily.
We take reasonable steps to monitor certain communications and posts on Brainlox, and we expect Teachers and all other Users to follow our standards of conduct. However, we cannot be liable for all Personal Data your Child may share with Teachers or other classmates, nor for what third parties ultimately do with that information.
Children can also be enrolled in Learner Group chat sessions by their parents. Before allowing the Child to participate, we ask for a short video of them. To verify that participants are children, we do this. In Learner Groups, teachers may or may not participate or lead, but no other adults are allowed to interact with the children.
In group chat sessions on various topics, children interact with each other. The Learners can exchange messages, posts, and other content with each other. For safety reasons, Brainlox moderates this content to ensure compliance with community standards. These chats can be viewed by parents as their children, but they cannot post in them.
Please remind your children to follow our community standards when posting content and messages in class or in learner groups. When choosing what to share with others, you should also encourage your children to consider their own privacy and safety. Children in Classes or in Learner Groups should be encouraged not to share Personal Data like their address or contact information. Children and Parents may occasionally submit content to us, such as photos and artwork, along with other information about the Child (such as age, first name, initials, city, state, and country) that you may allow us to display publicly. It is recommended that parents review their children's submissions and avoid uploading any private information about the children, family members, or others in the Content. In the event that you share publicly identifiable information with others, Brainlox is not responsible for what they do with it. Children and their parents may be asked by some teachers to use third-party websites and services. For more information about the privacy practices of those third-party sites and services, parents should review their privacy notices. Third-party services and sites are not our responsibility and may not have been reviewed by us.
Children and Teachers are recorded during Brainlox classes ("Class Recordings"), as described above. Teachers are provided with the Class Recordings by Brainlox. They may share them with the class (including their parents) to view (the "Permitted Recipients"). In some cases, instructors are not individuals but organizations, groups, or teams ("Teacher Organizations"). As a result, the entire Teacher Organization may access Class Recordings, and access is not necessarily limited to a single instructor. In addition to providing feedback to Teachers, Brainlox may use Class Recordings for customer support, compliance, and customer support.
Before Brainlox uses any Class Recordings for promotional or other unexpected purposes, we will obtain additional parental consent. Teachers are requested not to make copies of the Class Recordings or to share them outside of Permitted Recipients, and Permitted Recipients are asked not to download or re-share the Class Recordings. Teachers and Permitted Recipients are expected to adhere to our standards of conduct, but we cannot control or monitor what they do with Class Records.
Before collecting, using, or sharing Personal Data from your Child, Brainlox sends a direct notice and obtains verifiable parental consent. In order to register your Child for a Brainlox Class and pay for it, Brainlox requires your credit card information. In the event that you do not consent or withdraw consent, we will not collect, use, or disclose any Personal Data about your Child, except for legal compliance and enforcement purposes, and your Child will not be allowed to use the Services. You will also be deleted from our records if you do not provide consent within a reasonable time from the date the direct notice was sent and are not using our services for any other purposes, such as for teens.
You may at any time review and deny us permission to collect further Personal Data from your Children. If you would like us to delete your Personal Data associated with that account, you can also request that we do so from our records. If you request to delete records, your account, membership, or other service may be terminated. Logging into your account allows you to access and edit certain information about your Child. Your account allows you to review topics of interest that have been inferred based on your Child's interests. It is possible for you to opt out of recommendations based on your child's activities and instead choose the learning topics you would like to hear about. If you wish to access, change, or delete your Child's Personal Data, or revoke consent for our collection, use, and sharing of Personal Data, please contact us at privacy@Brainlox.com. Within a reasonable timeframe, we will accommodate a valid request to delete Personal Data. Further, we will use commercially reasonable efforts to delete Personal Data collected from Children when it is no longer needed for the purpose for which it was collected
In our mobile app, Parents can choose whether to allow Children to receive push notifications, as well as access to the camera and photos. It is recommended that parents enable parental controls to prevent their children from changing permissions. These controls can usually be set in the device settings of most devices.