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BrainyBee Privacy Policy

Last Updated: June 4, 2026

COPPA-Focused Privacy PIPEDA-Aware Privacy Ages 5-15

1. Introduction

This Privacy Policy explains how PauloFrancis ("we," "us," or "our") collects, uses, and discloses information related to the BrainyBee mobile application (the "App" or "Service").

๐ŸŽฏ Target Audience: BrainyBee is designed specifically for children ages 5 to 15 years old. We take children's privacy extremely seriously and have designed our App with privacy-by-default principles.

By using BrainyBee, you acknowledge this Privacy Policy and consent to the practices described below.

App Name: BrainyBee

Developer: PauloFrancis

Contact: paulofrancis.software@gmail.com

Address: 1940 Rue Cloutier, Brossard, QC J4Z 0S4, Canada

2. Children's Privacy (COPPA)

โš ๏ธ IMPORTANT: BrainyBee is designed for and directed at children ages 5-15 years old. We are committed to complying with the Children's Online Privacy Protection Act (COPPA) and applicable Canadian privacy laws including PIPEDA.

2.1 Parental Consent & Age Verification

Before collecting any personal information from a child, we require verifiable parental consent through our in-app consent flow:

2.2 Information Collected from Children

We collect minimal information from children:

2.3 Parental Rights

Parents and legal guardians have the following rights under COPPA:

To exercise these rights: Contact us at paulofrancis.software@gmail.com with the subject line "COPPA Request - [Your Request Type]". We will respond within 10 business days.

2.4 Teacher/Classroom Features

When using consumer classroom features, student progress may be shared with assigned teachers within the App only. No student information is shared outside the App or with third parties for advertising or marketing. Consumer classroom features require appropriate parental consent and teacher verification.

2.5 Brainy Bee Schools Addendum

Brainy Bee Schools is a school-managed version of the App for school-authorized educational use. For school accounts, access is managed by the school or district, and the consumer in-app parental consent prompt may not be shown.

Where permitted by COPPA, a school or district may authorize collection, use, and disclosure of student personal information on behalf of parents only for the use and benefit of the school and only in the educational context. We remain responsible for our own COPPA obligations and provide notice of our collection, use, and disclosure practices to schools.

School-version data may include school roster information, Firebase user IDs or school account identifiers, school email addresses, display names, school role, class membership, assigned classes or rooms, room membership, class controls, math practice results, question-level reports, student progress, achievements, Skill Builder progress, avatar choices, notification preferences, and device-level preferences needed to provide the service. We use this information only to provide, secure, support, and improve the school-requested educational service.

For school administrators and teachers, the App may store school information, teacher/student records entered by authorized staff, class policies, room settings, school branding choices, and uploaded or selected logo/branding assets. Material and resource uploads that are labeled as local drafts are not published to teachers or students until a publishing feature is implemented.

Students may be able to control local device-level practice reminder notifications where allowed by parent or school settings. These reminders are scheduled on the device for educational practice only and are not advertising, profiling, or marketing push messages.

We do not use school-version student information for targeted advertising, behavioral advertising, sale, marketing profiles, or unrelated commercial purposes. We do not re-disclose education records or student personal information except to service providers that help provide the App, as required by law, or as directed by the school or district.

Parents, guardians, and eligible students should contact their school or district to exercise rights related to education records. Schools and districts may contact us at paulofrancis.software@gmail.com for access, correction, export, deletion, or to prevent further collection or use of student information where applicable.

Schools and districts may also have obligations under FERPA, PPRA, state student privacy laws, and local policy. Brainy Bee Schools is designed to support role-based access controls so students cannot view school directory information and teachers/admins see only tools available to their role.

2.6 FERPA Notice (Schools & Districts)

Our Role Under FERPA

When Brainy Bee Schools is used by a school or district subject to the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. ยง 1232g, we act as a school official with a legitimate educational interest in student education records, as permitted under 34 C.F.R. ยง 99.31(a)(1). The school or district retains control of the education records; we process them only at the direction of the school and only to provide the App service.

Data Processing Agreement

Schools and districts that require a written Data Processing Agreement (DPA) before deployment may request one by contacting us at paulofrancis.software@gmail.com. The DPA will document our FERPA obligations, data handling practices, security measures, and deletion commitments.

What Education Records We Process

We do not collect Social Security numbers, government-issued IDs, financial account information, health or biometric data, geolocation, or any data unrelated to the educational service.

Permitted Uses Only

Education records processed through Brainy Bee Schools are used exclusively to:

We do not use education records for advertising, marketing, profiling, sale, or any purpose unrelated to the school-requested educational service.

Re-Disclosure Restrictions

We do not re-disclose education records to third parties except: (a) to subprocessors that help provide the App under confidentiality obligations consistent with FERPA; (b) as required by law or court order; or (c) as expressly directed in writing by the school or district. All subprocessors are listed in our DPA upon request.

Parent and Eligible Student Rights

Under FERPA, parents of students under 18 (and eligible students 18 and older) have the right to:

Because the school or district controls these records under FERPA, rights requests should first be directed to the school or district. Schools may then contact us at paulofrancis.software@gmail.com to process access, correction, export, or deletion requests on your behalf. We will respond to school-authorized requests within 10 business days.

Data Retention

Student education records in the App are retained only as long as the school's license is active or as directed by the school. Upon termination of a school's use of the App, or upon a verified deletion request from the school, we will delete or anonymize student education records within 30 days, except where retention is required by law.

Security

We implement role-based access controls enforced in Firebase Security Rules so that students can only access their own records, teachers can only access records for their assigned classes, and cross-class access is blocked. All data is transmitted over TLS/HTTPS. School admins control who can view the school directory, class membership, and admin tools.

3. Information We Collect

3.1 Personal Data

Personal data may include information that can be used to identify or contact you:

3.2 Usage and Learning Data

We collect learning activity and limited app-use data needed to provide the App and improve the educational experience. In the BrainyBee iOS builds, including BrainyBee and Brainy Bee Schools, this is product functionality data; the iOS builds do not include Firebase Analytics, Google Analytics, AdMob, or any third-party advertising SDK.

3.3 Local Storage

By default in the consumer app, game data is stored locally unless cloud sync is enabled. Some Firebase-backed features, such as signed-in cloud sync, school accounts, assigned rooms, school rosters, class controls, and school administration tools, require online storage in Firebase to work. School-version use may be authorized and managed by the school or district.

3.4 Offline Functionality

๐Ÿ“ฑ Offline Mode: Many practice features work offline. Data created offline stays on the device until connectivity resumes. If the user is signed in, using school features, or playing an assigned room, relevant progress, preferences, and room/class results may synchronize to Firebase when the connection returns.

4. Information We Do NOT Collect

๐Ÿ›ก๏ธ Privacy by Design: BrainyBee is designed with children's safety as a priority. The following features are intentionally NOT included:

5. How We Use Information

We use collected information to:

6. Information Sharing and Disclosure

๐Ÿšซ WE DO NOT SELL, RENT, OR TRADE CHILDREN'S PERSONAL INFORMATION. EVER.

We may share information only in the following limited circumstances:

We do NOT share information with:

7. Advertising

No Third-Party Advertising

BrainyBee does not display third-party advertisements in the app. For children's privacy protection, we use the following safeguards:

8. In-App Purchases

๐Ÿ‘จโ€๐Ÿ‘ฉโ€๐Ÿ‘ง Parental Control Required: All in-app purchases in BrainyBee require parental authentication.

9. Third-Party Services

We integrate the following third-party services, all configured for COPPA compliance:

Firebase (Google)

Google Sign-In

Clever

Sign in with Apple

10. Data Security

We employ reasonable technical and organizational measures to protect data:

Limitation: No method of transmission or storage is 100% secure. While we strive to use industry-standard practices, we cannot guarantee absolute security.

11. Data Retention

Contact us to request data deletion at any time.

12. International Data Transfers

๐ŸŒ Cross-Border Data: BrainyBee is operated from Canada. If you use our App from outside Canada, your information may be transferred to, stored, and processed in Canada and the United States (where our service providers, including Google/Firebase, maintain servers).

By using BrainyBee, you consent to the transfer of your information to these countries, which may have different data protection laws than your country of residence.

We ensure that any international transfers comply with applicable laws and that appropriate safeguards are in place to protect your data.

13. Your Rights

Depending on your jurisdiction, you may have the following rights:

Canadian Users (PIPEDA)

Canadian users have additional rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including the right to:

European Users (GDPR)

EU users have rights under GDPR including:

California Users (CCPA)

California residents have rights under CCPA including:

14. Do Not Track Signals

Our App respects "Do Not Track" (DNT) signals. When we detect a DNT signal:

Note: As a children's app, we already limit tracking by default regardless of DNT signals.

15. Changes to This Policy

We may update this Privacy Policy periodically. Material changes affecting children's data will require new parental consent.

We will notify users through:

We encourage you to review this Privacy Policy periodically for any changes.

16. Contact Us

For privacy questions, to exercise your rights, or to report concerns:

๐Ÿ“ง Email: paulofrancis.software@gmail.com

๐Ÿ“ฌ Address: 1940 Rue Cloutier, Brossard, QC J4Z 0S4, Canada

โฑ๏ธ Response Time: Within 48 hours (10 business days for formal COPPA requests)

๐Ÿ“ Subject Line: "Privacy Request - [Your Request Type]"

๐Ÿ’š Your Privacy Matters: We are committed to protecting children's privacy and complying with all applicable laws. If you have any concerns about your child's privacy or our data practices, please contact us immediately. We take all concerns seriously and will respond promptly.