Supplemental Notice for California Residents

LAST UPDATED: April 15, 2024

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of Personal Information (as defined in the Privacy Policy) that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

Notice at Collection. At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of Personal Information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how to opt-out of such uses, and how long such information is retained. You can find those details in this statement by clicking on the above links.

The CCPA provides California residents with the right to know what categories of Personal Information brightwheel has collected about them, whether brightwheel disclosed that Personal Information for a business purpose (e.g., to a service provider), whether brightwheel “sold” that Personal Information, and whether brightwheel “shared” that Personal Information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

  1. We disclose the following categories of Personal Information to the following categories of third parties for a business purpose.
    1. Affiliates and Service Providers: Identifiers; Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e); Commercial information; Internet or other electronic network activity; Professional or employment-related information; Inferences drawn from other personal information to create a profile about a consumer; Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; and Personal Information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
    2. Business Partners: Identifiers; Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e); Commercial information; Internet or other electronic network activity; and Inferences drawn from other personal information to create a profile about a consumer
    3. Other Users or Third Parties You Share or Interact With: Identifiers; Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)
  2. We sell or share the following categories of Personal Information to Advertising Networks.
    1. Identifiers; Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e); Commercial information; Internet or other electronic network activity; and Inferences drawn from other personal information to create a profile about a consumer

The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “What Information does brightwheel collect?”, “How does brightwheel use Personal Information?”, and “brightwheel’s Disclosures of Personal Information” in our main Privacy Policy, respectively. We will retain Personal Information in accordance with the time periods set forth in “How long will you store my Personal Information?”

We “sell” and “share” your Personal Information to provide you with “cross-context behavioral advertising” about brightwheel’s products and services.

Additional Privacy Rights for California Residents

Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of Personal Information and the “sharing” of Personal Information for “cross-context behavioral advertising.” California residents may exercise these rights by clicking on the “Your Privacy Choices” toggle at the bottom of our website and following the instructions that appear.

Disclosure Regarding Individuals Under the Age of 16. brightwheel does not have actual knowledge of any “sale” of Personal Information of minors under 16 years of age. brightwheel does not have actual knowledge of any “sharing” of Personal Information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Sensitive Personal Information. brightwheel only uses and discloses sensitive personal information for the following purposes:

  • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
  • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted Personal Information.
  • To resist malicious, deceptive, fraudulent, or illegal actions directed at brightwheel and to prosecute those responsible for those actions.
  • To ensure the physical safety of natural persons.
  • To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by brightwheel, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by brightwheel.
  • For purposes that do not infer characteristics about individuals.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.  

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Examples of our verification process may include asking you to provide the email address or phone number we have associated with your account.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To authorize an agent, provide written authorization signed by you and your designated agent to info@mybrightwheel.com and ask us for additional instructions.