BrainyBee Privacy Policy

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").

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

2. Children's Privacy (COPPA)

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:

• Age Gate: Users must confirm their age category when first using the App
• Parental Verification: Parents or legal guardians must actively check a consent box confirming they are the parent/guardian
• Terms Acceptance: Parents must review and accept our Terms of Service and Privacy Policy before a child can use the App
• Re-consent: If we make material changes to this policy, we will require new parental consent

2.2 Information Collected from Children

We collect minimal information from children:

• Generated Player Username: A non-identifying username generated by Brainy Bee for an approved player account
• Game Data: Scores, math problem responses, time spent on activities, and achievement progress. This stays on the device before approval and synchronizes to Firebase after parent approval and player sign-in.
• Device Information: Device type, operating system version (for compatibility purposes only)
• Cloud Sync and Account Sessions: For an approved player username, Google Sign-In, Sign in with Apple, or a linked family account, we store game progress and preferences in Firebase.

2.3 Parental Rights

Parents and legal guardians have the following rights under COPPA:

• Review: Request to review personal information collected from your child
• Delete: Request deletion of your child's personal information
• Refuse: Refuse to allow further collection or use of your child's information
• Revoke: Revoke consent at any time

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

2.4 Rooms and Shared Activities

BrainyBee includes optional Rooms that let signed-in users participate in shared math activities. When a family manager adds an approved player to a family, the option to enable Rooms is selected by default. Before the player is linked with Rooms enabled, BrainyBee asks the family manager to separately confirm that choice or add the player without Rooms. The family manager may also turn Rooms off before adding the player or at any time afterward in My Family. Confirming Rooms records the family manager's choice, but Room access is available only while the family has verified Premium.

Rooms may include participants from different families. The Room owner and participants may see a player's generated username, Room participation, activity results, rankings, and achievement information needed to operate the shared activity. BrainyBee does not require a child's real name for Rooms. Rooms do not include chat, direct messaging, photo sharing, microphone access, or location sharing.

3. Information We Collect

3.1 Personal Data

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

• Name: Display name only (not full legal name)
• Email Address: Parent email for consent and an optional account email for cloud sync
• Account Identifiers: Firebase user ID, linked family-account membership, and Room membership when needed for cloud sync or Rooms
• Profile Picture: Optional, from Google account if cloud sync is enabled. If Sign in with Apple is used, Apple may provide account information according to the user's Apple settings.
• Avatar and Preferences: Optional avatar choices, Skill Builder progress, notification preferences, and other app settings needed to provide the service

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 build, this is product functionality data; the iOS build does not include Firebase Analytics, Google Analytics, AdMob, or any third-party advertising SDK.

• App usage statistics and feature usage
• Performance data and error logs
• Game completion rates and learning progress
• Room participation, shared activity results, and question-level reports where Rooms are used

3.3 Local Storage

By default, game data is stored locally unless cloud sync is enabled. Firebase-backed features, such as signed-in cloud sync, linked family accounts, and Rooms, require online storage in Firebase to work.

3.4 Offline Functionality

4. Information We Do NOT Collect

• 🎤 Microphone: BrainyBee does NOT access or use the device's microphone
• 📷 Camera: BrainyBee does NOT access or use the device's camera
• 📍 Location: BrainyBee does NOT collect GPS or precise location data
• 📇 Contacts: BrainyBee does NOT access the device's contact list
• 📸 Screenshots: BrainyBee does NOT take screenshots or record screen activity
• 💬 Chat/Messaging: There are NO chat rooms, direct messaging features, or ways for children to communicate with strangers. Rooms are limited to shared math activities, results, membership, and optional leaderboards; they are not messaging spaces.
• 🌐 Social Features: Children cannot post public content, share personal information with other users, or create public profiles
• 🔔 Unsolicited Notifications: We do NOT send marketing push notifications to children. Practice reminders are local device notifications and require parent or device permission where applicable.

5. How We Use Information

We use collected information to:

• Provide and maintain the App's functionality
• Track learning progress and provide educational feedback
• Enable cloud backup, linked family accounts, and synchronization where enabled
• Provide optional Rooms and shared math activities
• Improve educational content and user experience
• Respond to parent/guardian requests and inquiries
• Comply with legal obligations

6. Information Sharing and Disclosure

We may share information only in the following limited circumstances:

• With Parents: Upon request, we provide parents access to their child's information
• Service Providers: Firebase (Google) for authentication, account/session management, cloud database, cloud storage, and analytics where enabled, subject to its privacy policy and COPPA-focused configuration
• Apple: If Sign in with Apple is used, Apple provides authentication according to Apple's terms and privacy policy
• Legal Requirements: When required by law or to protect safety
• Room Owners and Participants: Within a Room, generated usernames, participation, activity results, rankings, and achievements are shared only as needed to provide the shared activity. Participants may belong to different families.

We do NOT share information with:

• Advertisers or marketing companies for profiling
• Data brokers
• Social media platforms (except for optional authentication)
• Any third party for behavioral advertising purposes

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:

• No Ad SDK: BrainyBee does not use an advertising SDK to serve ads
• No iOS Ad Network: BrainyBee iOS builds do not include AdMob, Google Mobile Ads, or another ad network SDK
• No Behavioral Advertising: We do NOT use interest-based or personalized advertising for children
• No Data Collection for Ads: We do not collect or share personal information for advertising purposes

8. In-App Purchases

• Authentication Required: In-app purchases require device password/biometric authentication controlled by the device's app store (Google Play or Apple App Store, depending on device)
• No Direct Child Purchases: Children cannot make purchases without parental approval
• Clear Pricing: All prices are clearly displayed before purchase
• No Manipulative Tactics: We do not use manipulative tactics, pressure, or dark patterns to encourage purchases
• Refund Policy: Accidental purchases can be refunded through the applicable app store within its refund window

9. Third-Party Services

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

Firebase (Google)

• Cloud database, cloud storage, authentication, and account/session management
• BrainyBee iOS builds use Firebase Auth, Firestore, Storage, and Core. Firebase Analytics, Google Analytics, and Firebase/Google advertising products are not enabled in those iOS builds.
• Firebase Analytics may be used in Android consumer builds, configured without advertising use for children
• Privacy Policy: firebase.google.com/support/privacy

Google Sign-In

• Optional authentication for cloud sync and account linking
• Used when explicitly enabled by a parent or account holder
• Privacy Policy: policies.google.com/privacy

Sign in with Apple

• Optional authentication for Apple users where available
• Used only when selected by the parent or account holder
• Privacy Policy: apple.com/privacy

10. Data Security

We employ reasonable technical and organizational measures to protect data:

• Encryption in Transit: All data transmitted uses HTTPS/TLS encryption
• Encryption at Rest: Cloud data is encrypted using Firebase's default encryption
• Access Controls: Restricted access with authentication safeguards
• Local-First: By default, data stays on your device
• Minimal Data Collection: We only collect data necessary for app functionality
• Regular Review: We regularly review our data practices for security

11. Data Retention

• Local Data: Retained on device until manually deleted by user or app is uninstalled
• Cloud Data: Retained while the account is active, plus up to 90 days after a verified deletion request unless a longer period is required by law
• Consent Records: Retained for 3 years to comply with COPPA verification requirements
• Backup Data: Purged within 30 days of deletion request
• Analytics Data: Where analytics is enabled in a platform build, aggregated and anonymized data may be retained for product improvement. BrainyBee iOS builds do not use third-party analytics SDKs.

Contact us to request data deletion at any time.

12. International Data Transfers

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:

• Access: Request a copy of data we store about you or your child
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of personal data
• Opt-Out: Opt-out of certain collection or processing activities
• Portability: Request data in a portable format

Canadian Users (PIPEDA)

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

• Access your personal information held by us
• Challenge the accuracy and completeness of your information
• File a complaint with the Privacy Commissioner of Canada

European Users (GDPR)

EU users have rights under GDPR including:

• Right to access, rectification, and erasure
• Right to restrict processing
• Right to data portability
• Right to lodge a complaint with a supervisory authority

California Users (CCPA)

California residents have rights under CCPA including:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale of personal information (note: we do NOT sell personal information)
• Right to non-discrimination for exercising your rights

14. Do Not Track Signals

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

• We do not track users across third-party websites or services
• We do not use behavioral advertising
• We limit data collection to essential app functionality only

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:

• In-app notification requiring acknowledgment
• Updated "Last Updated" date on this page
• Email notification for significant changes (if email is provided)
• Requiring re-consent for material changes affecting children's data

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: