Introduction

Growing Brilliant, LLC (“Growing Brilliant,” “we,” “us,” or “our”) provides online educational classes and related services to families in the United States.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information through growingbrilliant.com, our parent portal, live classes, and related communications and services.

Parents and legal guardians manage enrollment and account matters. Our children’s privacy practices are explained separately below.

1. Information We Collect

Information provided by parents and guardians

We collect information you provide when you inquire about classes, enroll a child, manage an account, purchase services, or contact us. This may include:

• Your name, email address, telephone number, and billing address.
• Account credentials and account preferences.
• Your child’s name, birthday, age, class enrollment, and educational information.
• Assessments and information about your child’s learning needs or progress.
• Messages, questions, feedback, and other information you provide.
• Subscription, payment, transaction, and billing information.

Please provide only information relevant to the services you request. Avoid submitting sensitive information that we do not need.

Information collected during classes

During live classes, we collect children’s images, voices, participation, and information they share through class activities. We may also maintain assessments and instructional observations.

We record live classes. Section 6 explains recording purposes, access, and children’s privacy rights.

Information collected automatically

Our websites and service providers may collect:

• IP addresses and approximate location derived from them.
• Browser, device, and operating-system information.
• Cookie identifiers and similar online identifiers.
• Pages visited, referring websites, links clicked, and interaction timestamps.
• Website activity, enrollment events, purchase events, and technical error information.

Cookies, pixels, and similar technologies may collect information directly from your browser or device.

Information from service providers

We receive information from providers supporting payments, communications, website analytics, advertising, hosting, and class delivery. This may include payment status, message delivery information, advertising attribution, and technical activity associated with our services.

2. How We Use Information

We use personal information to:

• Create and administer accounts and enrollments.
• Deliver classes and provide age-appropriate instruction.
• Understand student participation and educational progress.
• Process payments and manage subscriptions.
• Answer questions and provide customer support.
• Send service notices, scheduling information, and account communications.
• Communicate with parents about our services and offers.
• Evaluate and improve instruction and service quality.
• Understand website performance and advertising effectiveness.
• Protect children, investigate incidents, and address complaints.
• Detect misuse, maintain security, and resolve technical problems.
• Establish, exercise, or defend legal claims and comply with applicable obligations.

Advertising activities relate to marketing our services to adults. Children’s recordings and educational records are not intended for advertising use.

3. How We Disclose Information

Service providers

We disclose information to providers that support our operations, including:

• Zoom: Live video classes and related video functionality. Zoom Privacy Statement
• Amazon Web Services (AWS): Hosting, infrastructure, and storage. AWS Privacy Notice
• Stripe: Payment processing and related transaction services. Stripe Privacy Policy
• Klaviyo: Customer communications and marketing services. Klaviyo Privacy Notice
• CookieYes: Cookie preferences and consent management. CookieYes Privacy Policy

Information provided to these services depends on their function. For example, payment and communication providers may receive adult contact details, while class and storage providers may process class content and children’s information.

Provider privacy notices explain their own practices. Linking to those notices does not replace our responsibilities for information handled on our behalf.

Google, Meta and others

We use Google and Meta tools for analytics, advertising, audience matching, and conversion measurement. We also use a wide range of other advertising and analytics tools that change often.

Depending on the tools and settings used, information disclosed may include browser and device identifiers, IP addresses, page visits, advertising interactions, enrollment or purchase events, and adult contact information transformed into hashed identifiers for matching.

Hashing does not necessarily make information anonymous. These tools may allow providers to associate website activity with information they already hold and measure or personalize advertising across services.

Read more: Google Privacy Policy | How Google uses information from sites or apps that use its services | Meta Privacy Policy

Disclosures for advertising may qualify as a “sale,” “sharing,” or processing for targeted advertising under applicable privacy laws, even without a monetary payment. See Sections 4 and 8 for choices and requests.

 California and other state laws require opt-in (not merely opt-out) consent before selling or sharing the personal information of a consumer known to be under 16, with additional protection for children under 13. If accurate, add: “We do not use advertising or analytics tools on the parent portal or during live classes, where children’s information is processed. The advertising and analytics tools described in this section operate only on our public marketing website, using information provided by adults inquiring about our programs.” If this is not yet true technically, this is worth fixing on the product side before adding the sentence, since it should describe an actual, verified separation rather than an aspiration.

Other disclosures

We may disclose relevant information:

• To professional advisers supporting legal, accounting, insurance, or business matters.
• When legally required or necessary to address safety concerns, fraud, security incidents, or legal claims.
• In connection with a merger, acquisition, financing, reorganization, or transfer of business assets, subject to applicable protections.
• At your direction or with consent where required.

4. Cookies, Pixels, and Privacy Choices

We use cookies and similar technologies for essential website functions, preferences, analytics, and advertising.

• Necessary technologies support functions such as security, account sessions, and remembering privacy choices.
• Preference technologies remember optional settings.
• Analytics technologies help evaluate website use and performance.
• Advertising technologies help measure campaigns, attribute conversions, and deliver relevant advertisements.

Use the CookieYes banner and cookie-preference controls on our website to make available choices. You may also request assistance or opt out of advertising-related sharing by emailing online@growingbrilliant.com.

Cookie choices may be specific to your browser or device. Clearing cookies, changing browsers, or using another device may require you to make those choices again.

Browser settings may allow you to block or remove cookies. Blocking necessary cookies may affect account access or other essential functions. Browser controls alone may not prevent every type of data transmission, including server-side transmissions.

Browser privacy signals

Global Privacy Control (“GPC”) is a browser signal communicating an opt-out preference. Where applicable law requires us to recognize such signals, we process them as requests to opt out of covered sale, sharing, or targeted advertising. Learn more at Global Privacy Control.

Traditional “Do Not Track” signals are different from GPC. Our website does not respond to traditional Do Not Track signals.

You can also manage advertising preferences through Google My Ad Center and Meta Ad Preferences. Those settings govern the respective providers and do not replace requests submitted to Growing Brilliant.

5. Marketing Communications

You may unsubscribe from promotional emails using the unsubscribe link included in the message or by contacting online@growingbrilliant.com.

If you receive promotional text messages, you may follow the opt-out instructions in those messages.

Opting out of promotional communications does not prevent necessary communications about an active account, enrollment, payment, scheduling change, or safety matter.

6. Children’s Privacy and Class Recordings

Children’s information

Our classes serve children, including children under 13. Parents and guardians provide enrollment information, and children provide information through participation in live classes.

Information collected directly from children may include their image, voice, statements, responses, participation, and assessment activity. Class technology may also process identifiers needed to deliver and secure the session.

We use this information for instruction, educational assessment, quality review, safety, incident investigation, and related legal protection.

Recording and access

We record live classes to review instruction, evaluate safety concerns, investigate unusual events or complaints, and preserve relevant evidence for potential claims.

 Access to stored recordings within Growing Brilliant is limited to authorized administrators. We do not make full class recordings generally available to enrolled families or other students, because each recording also contains other children’s images, voices, and information alongside your own child’s. As described under “Parental rights” below, a parent or legal guardian may request to review the portion of a recording containing their own child, subject to identity/parental-authority verification and reasonable measures to protect other participating children’s privacy.

Teachers and classmates can see and hear participating children during the live class. Providers supporting video delivery and storage, including Zoom and AWS, process class information to perform those services.

Relevant recordings may be disclosed when necessary to respond to legal process, investigate an incident, or work with legal advisers, insurers, or appropriate authorities.

Class recordings are not authorized for public promotional use merely because a family enrolls. Any proposed promotional use requires separate parental permission.

Parental notice and consent

For information collected from children under 13, applicable law requires direct parental notice and verifiable parental consent before collection, except where a specific legal exception applies.

This Privacy Policy, a cookie selection, or agreement to payment terms does not by itself constitute verifiable parental consent.

We obtain verifiable parental consent when a parent or guardian enrolls a child. Enrollment requires the enrolling parent or guardian to separately acknowledge — distinct from, and in addition to, general agreement to our Terms of Service — that they consent to Growing Brilliant’s collection and use of their child’s information, including the child’s image, voice, and class participation, as described in this Privacy Policy, before their paid enrollment is completed.

Parents have the right to consent to collection and use of their child’s information without consenting to disclosures that are not integral to the service. Separate consent is required for such disclosures where applicable.

Questions about parental notice, verification, or consent should be directed to online@growingbrilliant.com before the child participates.

Parental rights

A parent or legal guardian may contact us to:

• Review personal information collected from their child.
• Request correction or deletion.
• Withdraw consent and refuse further collection or use.
• Ask about recipients of their child’s information.

We may verify parental authority before providing access or acting on a request. Review of a recording may require measures to protect other children’s information.

If a request prevents collection or use necessary to deliver a class, we will explain the effect on participation. We do not require disclosure of more information than reasonably necessary to participate.

7. Retention and Deletion

Class recordings

Our scheduled retention period for class recordings is five years from the date of the class. The purpose is to support investigation of safety concerns, complaints, and potential legal claims.

Five years is an outer scheduled limit for routine recordings, not a requirement to retain every recording for that entire period. We review continued necessity and delete recordings sooner when they are no longer reasonably necessary for their collection purposes, subject to applicable legal requirements.

If a recording becomes relevant to a specific incident, investigation, legal obligation, or reasonably anticipated or pending claim, we may preserve the relevant recording under a legal hold. We review that hold and delete the recording when preservation is no longer necessary.

Other records

We currently do not maintain a routine automatic-deletion schedule for parent account records, enrollment information supplied by parents, billing records, or general correspondence. These records may remain after an account closes. Their retention remains subject to applicable law and valid deletion requests.

Information collected directly from children, other than recordings, is subject to a scheduled maximum of five years from collection, with earlier deletion when no longer reasonably necessary. Relevant legal preservation requirements may affect deletion of particular records.

Deletion obligations apply to information held on our behalf by service providers. Backup storage does not authorize indefinite retention of children’s information.

To request deletion, email online@growingbrilliant.com. We assess requests under applicable law, explain relevant exceptions, and address information retained through our providers as required.

8. Privacy Rights and Requests

Depending on your location and whether a particular law applies to our processing, you may have rights to:

• Know about and access personal information.
• Correct inaccurate information.
• Request deletion.
• Obtain a portable copy of certain information.
• Opt out of sale, sharing, or targeted advertising.
• Withdraw consent for processing based on consent.
• Appeal a decision concerning a privacy request.
• Exercise rights without unlawful discrimination.

To submit a request, email online@growingbrilliant.com or write to the address below. Privacy requests are handled through our contact channels rather than self-service account deletion.

Please describe your request and provide enough information to identify the relevant account. Do not send passwords, full payment-card numbers, or unnecessary identification documents.

We may verify identity or parental authority when appropriate. Opt-out requests do not require the same identity verification as requests to disclose account information.

Authorized agents may submit requests where permitted by law. We may request evidence of authorization and any verification permitted for the type of request.

We respond within applicable legal deadlines. If we cannot fulfill a request, we explain the reason and any available appeal process. To appeal, email us with “Privacy Appeal” in the subject line. You may also contact your state attorney general or other applicable regulator.

9. Security

We use administrative, technical, and organizational measures intended to protect personal information and restrict access according to operational responsibilities.

No internet transmission or storage system is completely secure. Please protect your account credentials and contact us if you suspect unauthorized access.

We provide notices of security incidents when required by applicable law.

10. United States Services and External Websites

Our services are offered to families in the United States. Information may be processed in locations where we or our providers operate, subject to applicable legal requirements.

Links to external websites do not make Growing Brilliant responsible for those websites’ independent practices. Review their privacy notices before providing information directly to them.

11. Changes to This Policy

We update this policy when our practices or applicable requirements change. The date above identifies the most recent revision.

For material changes, we provide additional notice where required. If a change requires new parental or other consent, publication of an updated policy or continued use of the service does not replace that consent.

12. Contact Us

Growing Brilliant, LLC

Attn: Privacy Requests 3101 Sunset Blvd, Ste 2C Unit #28 Rocklin, CA 95677

Email: online@growingbrilliant.com

Website: growingbrilliant.com