Growing Brilliant
Growing Brilliant
Growing Brilliant

Privacy Policy

Updated 12/27/25

Introduction

We at Growing Brilliant believe that you should know what kind of data we collect from you, how we use it, and how you can have control over your data. We work to be transparent in our data collection efforts and to provide you with the information that you need to make informed decisions about our collection of data from you. The capitalized terms below are more fully defined in Growing Brilliant’s Terms of Use Agreement, which is hereinafter incorporated by reference.

When you use the Growing Brilliant Website, even if you are just browsing, we may collect some basic data from you such as the type of device that you are using, your geographical location, and your IP address. If you choose to create a User Account, you can choose to share additional data with us, which is outlined below. We also provide you with the ability to limit the data that we collect from you and how we use it.

Our Services are designed to help students and their families. All information we collect is used to advance our mission to assist students academically and to promote these important Services.

If you have any questions about our privacy policy, how we collect data from you, how we use your data, or how you can control your privacy settings, you can contact us at any time at online@growingbrilliant.com

Information We Collect

Data You Provide to Us

We may collect data from you when you voluntarily share it with us. This may include the following:

Account Data. You don’t have to create an account to use all of the Website features. If you do choose to create an account, however, you must provide us with some personal data so that we can provide you with the services that you have requested. This may include your username, password, email address, and phone number.

Educational Data. When you create an account and request services, you provide us with information regarding the educational and academic status and history of the student. This data is used to help us create a customized educational plan for the student and to deliver appropriate age-level content.

Public Data. Some of the activity on the Website may be public. We may use this public data to provide you with the services requested, to provide you with more relevant content, to tailor content to your preferences, to keep records of communications between us and you, and to defend against legal claims.

Private Communication Data. We may use your contact data, such as any data that you voluntarily provide to us like your phone number, address, and email address, to authenticate your account, to communicate with you, to respond to communications sent by you, to keep records of our communication, to fulfill your orders, or to pursue or defend against legal claims. We may store and process your private communications with us and data related to them to scan for malicious content, to review content for violations of our terms of use agreement, to ensure child safety, or to respond to legal processes or law enforcement inquiries.

Customer Data. Data related to purchases and contracts created with Growing Brilliant including name, billing address, email address, phone number, other contact information, purchase details, and payment information necessary to process transactions.

Data We Collect Automatically

We may also collect data from you automatically when you use the Website. This may include:

Location Data. We may collect data about your general location by collecting and processing your IP address and device settings. We may use this data to tailor our offerings to your geographic region, respond to law enforcement requests, or to provide you with content that is relevant to your location. We do not collect precise geolocation data without your explicit consent.

Technical Data. We may collect technical data about your use of the Website, such as your IP address, device identifiers, pages visited, referring web page, mobile device model, mobile carrier, search terms, cookie data, operating system, browser type, time zone, and session duration. We use this data to analyze your use of the Website, to administer and secure our services, to determine how we should allocate resources to our Website, and to understand the technical load on our servers.

Marketing and Analytics Data. We may collect your IP address, device identifiers, geographical location, pages visited, referring web page, mobile device model, search terms, advertising identifiers (such as Google Advertising IDs and Apple Advertising IDs), and cookie data to provide advertisements to you through third-party ad networks and to analyze the effectiveness of our marketing efforts. We may use your data to provide advertisements to you, to provide remarketing advertisements after you previously visited the Website, to determine the relevance of advertisements, to measure the effectiveness of advertisements, and to help make those advertisements more relevant to your preferences.

Video and Audio Data. All of our live class sessions are conducted via secure video connection. The sessions are recorded and we may use these video recordings to review student progress and instruction quality, for teacher training and development purposes, and to ensure child safety and compliance with our policies. Video recordings are stored securely and access is limited to authorized personnel.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to understand how you use the Website and to improve our services.

Session Cookies. Session cookies are only stored on your device during your use of the Website and are automatically deleted when you close your web browser.

Persistent Cookies. Persistent cookies remain on your device even after you close your web browser and can be read by the website when you revisit. We may use persistent cookies when we utilize analytics providers such as Google Analytics, which are intended to track the origin and behavior of traffic to the Website.

Third-Party Analytics. We may receive data from third parties including analytics providers or advertising networks such as Google, Facebook, Meta, Apple, and other platforms to help us understand user behavior and improve our services.

Your Cookie Choices. You can configure your browser settings to reject all cookies or prompt you before a cookie is set. However, if you choose to disable cookies, some features of our Website may not function properly.

How We Use Your Information

We use the information we collect for the following purposes:

  • To provide, maintain, and improve our educational services
  • To process transactions and manage your account
  • To communicate with you about your account, services, and updates
  • To personalize your experience and deliver relevant content
  • To analyze usage patterns and improve our Website and services
  • To ensure child safety and monitor for inappropriate content or behavior
  • To comply with legal obligations and respond to law enforcement requests
  • To detect, prevent, and address fraud, security issues, and technical problems
  • To send marketing communications (with your consent where required)

Marketing Communications

We may send you marketing communications if you have requested information concerning our services or if you have agreed to receive marketing communications from us. You may opt out of receiving marketing messages at any time by logging into your account to adjust your marketing preferences, by following the opt-out link in any marketing message sent to you, or by contacting us at online@growingbrilliant.com

How We Share Your Information

We only share your personal data in limited circumstances and do not sell your personal information to third parties.

With Your Consent. We may share or disclose your personal data with your consent or at your direction.

Service Providers. We may share your data with third-party service providers who help us operate the Website and deliver our services. This includes analytics providers, payment processors, cloud storage providers, email service providers, and customer support platforms. These service providers are contractually obligated to protect your data and use it only for the purposes we specify. The data shared with these providers typically includes technical data and does not include your email address, name, phone number, or username, but may include your geographical location and device identifiers.

Advertising Partners. We may share device identifiers and advertising IDs with third-party advertising networks to help determine whether to serve advertisements to you. We do not share personally identifiable information such as your name, email, or phone number with advertising partners.

Professional Advisors. We may share your personal data with our accountants, auditors, insurers, or attorneys where necessary to protect the interests of Growing Brilliant or to comply with any law or regulation.

Legal Requirements. We may share your personal data with government or law enforcement agencies when required by law, upon receipt of a valid subpoena or court order, in response to lawful requests by public authorities, or where necessary to protect our users, employees, contractors, third parties, or property. We may also disclose information when we believe in good faith that disclosure is necessary to protect our rights, enforce our policies, respond to claims, or protect the safety of any person.

Business Transfers. We may share your personal data if we sell, transfer, or merge any part of our business or assets. In such events, this Privacy Policy will continue to apply to your personal data when transferred to the new entity, and you will be notified of any changes to how your data is handled.

Data Security and Retention

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Regular security assessments and updates
  • Access controls limiting data access to authorized personnel only
  • Employee training on data protection practices
  • Secure video conferencing and storage systems for class recordings

Despite our security measures, no system is completely secure. We will notify you and any applicable regulatory body of any data breach that poses a risk to your rights and freedoms, in accordance with applicable law.

Data Retention. We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. When data is no longer needed, we securely delete or anonymize it. Account data is retained for the duration of your active account plus a reasonable period thereafter. Video recordings are retained for quality assurance and training purposes and are deleted in accordance with our data retention schedule unless longer retention is required by law.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information.

General Rights

If you have registered an account with us, you can access, modify, correct, or delete the personal data associated with your account through your account settings. To stop our collection and use of your personal data, you may delete your account and cease using the services.

If you have not registered an account, we only collect technical data from you. To stop our collection and use of your technical data, you may cease using the Website or configure your browser to block cookies and tracking technologies.

European Union (GDPR) Rights

If you are a resident of the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (GDPR):

  • Right of Access: Request access to your personal data
  • Right to Rectification: Request correction of inaccurate personal data
  • Right to Erasure: Request deletion of your personal data
  • Right to Restriction: Request restriction of processing your personal data
  • Right to Data Portability: Request transfer of your data to another service
  • Right to Object: Object to processing of your personal data
  • Right to Withdraw Consent: Withdraw consent where processing is based on consent

We may store or transfer your personal data to countries outside the European Union. When we do so, we ensure appropriate safeguards are in place, such as transferring data to countries approved by the European Commission or implementing Standard Contractual Clauses.

U.S. State Privacy Rights

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other U.S. states with comprehensive privacy laws, you may have additional rights:

  • Right to know what personal information we collect, use, and disclose
  • Right to request deletion of your personal information
  • Right to correct inaccurate personal information
  • Right to opt out of the sale or sharing of personal information for targeted advertising
  • Right to opt out of automated decision-making and profiling
  • Right to non-discrimination for exercising your privacy rights

Important Note: Growing Brilliant does not sell your personal information. We may share information with third-party analytics and advertising partners as described in this policy, which under some state laws may be considered “sharing” for targeted advertising purposes. You can opt out of this sharing by adjusting your cookie preferences or contacting us.

How to Exercise Your Rights

To exercise any of these rights, please contact us at online@growingbrilliant.com or send a written request to:

Growing Brilliant, LLC

Attn: Data Privacy Officer

3101 Sunset Blvd, Ste 2C Unit #28

Rocklin, CA 95677

You do not need to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

To verify your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to unauthorized individuals. We will respond to all legitimate requests within the timeframes required by applicable law (typically 30-45 days).

Authorized Agents: You may designate an authorized agent to make requests on your behalf. To do so, you must provide proof of authorization, such as a signed power of attorney, and verify your identity.

Children’s Privacy (COPPA Compliance)

This section explains our information collection, disclosure, and parental consent practices regarding information provided by children under the age of 13 (“Child” or “Children”). This policy complies with the U.S. Children’s Online Privacy Protection Act (“COPPA”).

Information We Collect from Children

Growing Brilliant collects information about students directly from parents or legal guardians, who provide us with the Child’s name, age, grade level, educational needs, and any additional notes for the teacher. Children may also share information about themselves during live classes. Class sessions take place over online video in which video images and audio of the Children are recorded. No information is collected directly from Children until they participate in a class session. Children cannot post personal data publicly on the Growing Brilliant Services.

How We Use Children’s Information

We use children’s information solely to:

  • Provide educational services and live classes
  • Allow teachers to deliver age-appropriate and personalized instruction
  • Monitor and ensure child safety during classes
  • Provide teacher training and quality assurance
  • Comply with legal obligations and respond to safety concerns

How We Share Children’s Information

We share children’s information only in the following limited circumstances:

  • With the child’s assigned teacher to enable class instruction
  • With other students in the same class during live sessions (as children may interact during class)
  • With service providers who help us operate our platform, under strict confidentiality obligations
  • As required by law or to protect child safety
  • In connection with a business transfer, with continued protection under this policy

While we expect all teachers and users to abide by our standards of conduct, we cannot control what information children may voluntarily share with teachers or classmates, nor what those individuals ultimately do with that information. We disclaim responsibility for such third-party actions while maintaining our commitment to child safety.

Class Video Recordings

Growing Brilliant records video and audio of students and teachers during live classes (“Class Recordings”). Class Recordings are made available to:

  • The teacher of the class
  • Growing Brilliant management and authorized personnel
  • The enrolled students in the class and their parents (“Permitted Recipients”)
  • Teachers may share class recordings with the entire class and their parents for review purposes

We use Class Recordings to provide feedback to teachers, for customer support, for teacher training, and for compliance and safety purposes. We will obtain additional parental consent before using Class Recordings for promotional or marketing purposes.

We implement reasonable technical measures to limit the ability of teachers and Permitted Recipients to download, copy, or share Class Recordings beyond authorized purposes. However, we cannot fully control what individuals do with recordings they access, and we disclaim responsibility for unauthorized use by third parties.

Parental Consent

Growing Brilliant obtains verifiable parental consent before collecting personal information from children. We require that you provide payment information (credit card) to register your child for and pay for Growing Brilliant services, which serves as our method of verifying parental consent.

If you do not provide consent, we will not collect, use, or disclose any personal information about your child, and your child will not be permitted to use the services.

Parental Rights and Controls

At any time, parents and legal guardians may:

  • Review the personal information collected from their child
  • Request deletion of their child’s personal information
  • Refuse to permit further collection or use of their child’s information
  • Update or correct their child’s information through their account settings

Please note that a request to delete records or refuse further data collection may result in termination of the account and services.

To exercise these rights, contact us at online@growingbrilliant.com. We will respond to valid requests within a reasonable timeframe. We exercise commercially reasonable efforts to delete personal information belonging to children when it is no longer needed for the purpose for which it was collected.

Third-Party Links and Services

Our services may include links to third-party websites and applications. By clicking on third-party links, you may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

Do Not Track Signals

You can generally opt out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (networkadvertising.org/choices) and DAA website (optout.aboutads.info). Our Website currently does not respond to browser Do Not Track (DNT) signals, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

International Data Transfers

Growing Brilliant is based in the United States. If you access our services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where our service providers operate. These countries may have data protection laws that differ from those of your country. By using our services, you consent to the transfer of your information to the United States and other countries. We take appropriate measures to ensure your information receives an adequate level of protection wherever it is processed.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this policy and post the revised policy on our Website. For material changes, we will provide additional notice, such as by email or through a prominent notice on our Website. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Privacy Officer:

Email: online@growingbrilliant.com

Mail:

Growing Brilliant, LLC

Attn: Data Privacy Officer

3101 Sunset Blvd, Ste 2C Unit #28

Rocklin, CA 95677

Phone: 833-255-5788

We are committed to working with you to obtain a fair resolution of any privacy concerns.

Here are the authoritative research links validating all the compliance revisions made to the Privacy Policy, organized by topic:

CALIFORNIA PRIVACY LAW (CCPA/CPRA) – 2026 Updates

Official Government Sources:

Legal Analysis:

U.S. STATE PRIVACY LAWS (Virginia, Colorado, Connecticut, Utah, etc.)

Comprehensive State Law Guides:

Specific State Laws:

GDPR (European Union) – 2025/2026 Compliance

Official EU Sources:

Compliance Guides:

COPPA (Children’s Online Privacy) – 2025/2026 Updates

Official FTC Sources:

Legal Analysis:

Key Compliance Dates Summary:

  • CCPA/CPRA: January 1, 2026 (new regulations effective)
  • COPPA: June 23, 2025 (effective date), April 22, 2026 (compliance deadline)
  • State Laws: Various – Indiana/Kentucky/Rhode Island: January 1, 2026
  • GDPR: Ongoing with 2025 simplification proposals

All the updates made to our Privacy Policy are based on these authoritative sources from government agencies (FTC, CPPA, EDPB), major law firms, and compliance experts. The policy now reflects the most current requirements for 2026 compliance across all major privacy frameworks.