PRIVACY POLICY
At Bright Bird, we place a high emphasis on transparency and openness, especially in the handling of your personal information. Protecting your privacy is a top priority for us. You can trust that your data is not only secure with Bright Bird but is also handled with the utmost responsibility and care. Your interaction with us, whether it's through browsing our website, utilizing our digital mental well-being content, participating in our 'groups & challenges' feature, using tools to track progress and moods, or engaging in any other feature or activity that involves sharing personal data with us, entails entrusting us with your personal information. We use this data to enhance your experience with our services. It's crucial for you to be aware of how we process and safeguard your data, and we assure you it is treated with the highest regard for your privacy. This privacy policy is designed to provide a clear understanding of how we use and protect your personal information. If you have any questions or concerns after reviewing our policy, please do not hesitate to reach out to us at [email protected]. We are always ready to address any queries you might have. Please note that this page will always contain the latest version of our privacy policy. We may update it periodically in response to developments at Bright Bird, changes in privacy legislation, or other relevant circumstances. To ensure that you are accessing the most current policy, we recommend checking this page regularly. The most recent update to our policy was made on 9 January 2024.
Data Processing Responsibility
Let's Talk App B.V., operating as ‘Bright Bird’ and located in Amsterdam, with a Chamber of Commerce registration number of 87170779, is responsible for the processing of your personal data associated with the services we offer.
Privacy Policy Coverage
This privacy policy pertains to the complete range of products and services provided by Bright Bird. It covers the handling of personal data for everyone who interacts with us, regardless of their role or capacity. This includes, but is not limited to, individuals who might use our services, those who visit our website, individuals applying for jobs, and any other persons who either reach out to us or have their personal data managed by us. This policy does not apply to the employees of Let's Talk App B.V., which operates under the name Bright Bird.
Types of Personal Data Processed by Bright Bird
Bright Bird processes a variety of personal data for specific purposes related to our digital mental well-being services. The types of personal data we may process include: · Your first name and last name · Gender you identify with · Email address · Telephone number · Country of origin · Information related to the content you engage with in our 'journeys' or sessions, including any data you provide during these interactions · Results from check-ins on various topics such as stress, mood, or other areas of focus, to monitor your progress or current state · Data related to our reward system, including points earned through interactions and how these points are utilized for prizes · Information regarding your participation in our 'groups & challenges' feature, including interactions with like-minded individuals, interests, and backgrounds · Any other personal data that you voluntarily share with us in the course of using our services This comprehensive approach ensures we cover all aspects of personal data you might provide while engaging with Bright Bird's offerings.
Bright Bird Privacy Policy - Data Processing Overview
1.Personal Identification Information · Data Types: First name, surname, email address, telephone number, country of origin, gender identity. · Source: Directly provided by users through the Bright Bird service interface and contact forms on the website. · Purpose: To deliver personalized services, maintain effective communication, and ensure compliance with regional regulations. · Legal Basis: Necessary for the performance of the service agreement (GDPR Article 6(1)(b)); Gender identity data is based on user consent (GDPR Article 6(1)(a)). 2.Service Usage Data · Data Types: Interactions with 'journeys' or sessions, participation in 'groups & challenges', check-in results (e.g., stress, mood assessments). · Source: Generated during the use of Bright Bird services. · Purpose: To tailor content, track user progress, facilitate group interactions, and manage challenges. · Legal Basis: Necessary for the performance of the service agreement (GDPR Article 6(1)(b)). 3.Reward System Data · Data Types: Points earned and redeemed in Bright Bird’s reward program. · Source: Generated through participation in the reward program. · Purpose: To effectively manage and operate the reward system. · Legal Basis: Necessary for the performance of the service agreement (GDPR Article 6(1)(b)). 4.Additional Voluntary Data · Data Types: Any other personal data shared voluntarily by users. · Source: Directly provided by users during their interaction with our services. · Purpose: To enhance service offerings based on user needs and feedback. · Legal Basis: Necessary for the performance of the service agreement (GDPR Article 6(1)(b)). 4.Website Analytics Data · Data Types: User statistics like number of visitors, visit duration, page views, navigation paths, and click patterns. · Source: Collected automatically during website visits. · Purpose: To improve website functionality and user experience. · Legal Basis: Legitimate interest in improving the website (GDPR Article 6(1)(f)). This structured overview of the Bright Bird Privacy Policy ensures clarity in understanding what data we collect, why we collect it, and the legal basis for doing so, in accordance with GDPR compliance.
How We Protect Your Personal Data
At Bright Bird, we place a high priority on safeguarding your personal data through robust technical and organizational measures. Our commitment to data protection is unwavering, and we take numerous steps to ensure that your data is handled with utmost care and security. Strong Data Protection Measures: We implement stringent data protection protocols to ensure the safety of your personal data against potential risks. Our security measures are comprehensive and designed to protect your data effectively. Employee Confidentiality: We ensure that only authorized Bright Bird staff have access to your personal data, and they are all under strict obligations of confidentiality. This includes not only our team but also any contractors or partners who might have access to your data. All are bound by contractual confidentiality agreements. Secure Access Controls: We employ secure usernames and passwords across all our systems. These systems are routinely evaluated for robustness and security, ensuring they remain impervious to unauthorized access. Anonymizing and Pseudonymizing Data: Wherever possible, we anonymize or pseudonymize personal data. This is especially pertinent for the data in the employer dashboard, which is always anonymized and aggregated. This ensures that no data in the dashboard can ever be traced back to you or any other individual user, safeguarding your privacy even in the unlikely event of a data breach. Our approach to data protection is both proactive and responsive, ensuring that your personal data is handled in a secure environment at all times.
Who Your Data is Shared With
Bright Bird may share your personal data with specific parties under controlled circumstances: With You as a User: As part of our transparent practices, we may share your data with you to keep you informed about your interactions and progress with our services. Bright Bird Employees and Contractors: We share necessary data with employees or contractors who are directly involved in creating relevant and scientifically-backed content for our users. However, this sharing is limited strictly to the extent necessary for them to perform their duties effectively. Administrative and Research Staff: Employees engaged in administrative tasks or conducting research to improve our services may have access to personal data. This data is either anonymized or pseudonymized to ensure privacy. Service Providers (“Processors”): We engage other service providers to process your personal data, but they operate strictly according to Bright Bird's instructions and guidelines. We have established processing agreements with these processors that comply with GDPR requirements. An overview of these processors includes: Amazon Web Services (AWS): Hosting the Bright Bird mobile application and dashboard, ensuring optimal user experience. Google: Used for email contact and analyzing website usage. Sendgrid: Facilitating email communications from our platform. Your personal data is shared only when necessary, and we assure you that it will never be shared with your employer. Additionally, we do not share your data with third parties for commercial purposes without your explicit permission. In such cases, only the necessary contact information is shared. We recommend reviewing the privacy policies of the aforementioned companies to understand how they handle your data. Please note, at Bright Bird, the safeguarding of your personal data is paramount, and any sharing is conducted with the highest standards of privacy and security.
Where We Store Your Data
At Bright Bird, we prioritize the security of your data. Accordingly, we store all well-being data on secure servers located within the European Union, ensuring compliance with EU data protection regulations.
How Long We Store Your Data
Understanding you better is part of our service, but we are also committed to not retaining your personal data for longer than necessary. To this end, we adhere to the following data retention periods: Data Related to Personal Interactions and Well-being Assessments: This data is retained for three years after your last interaction with Bright Bird's services. If you grant us permission, we may retain this data for a longer period. Financial and Administrative Data: We maintain this data for a period of seven years from the date of collection for compliance with financial and legal obligations. Employee and Contractor Data (excluding financial and administrative data): We store this data for seven years after the termination of employment or the conclusion of the contractual relationship. Website Visitor Data: Visitor data is stored for a maximum of two years following your last visit to our website. If you object to this data storage, we will proceed to delete the data promptly. At Bright Bird, these retention periods are carefully considered to balance our need to provide you with high-quality services and our commitment to protecting your privacy by not holding data for longer than necessary.
Use of Cookies and Similar Technologies on Our Website
At Bright Bird, our primary goal is to support and improve mental well-being through our digital platform. Our website serves as a key channel for disseminating information and engaging with current and potential users, as well as partners. In enhancing your experience on our website and to support our marketing efforts, we use cookies and similar technologies. These serve several purposes: Personalization of Services: Cookies help us remember your settings and preferences, making your interactions more seamless across visits. Customized Content and Marketing: By leveraging cookies, we can tailor the content and marketing materials presented to you, ensuring relevance and personalization. Service Effectiveness Monitoring: We analyze the use of our services through cookies to continually enhance their effectiveness. Usage Statistics: Gathering data such as visitor numbers and page views helps us understand and improve overall usage patterns on our site. When you first visit our website, we will request your consent for the use of various cookies, including those for marketing. You can adjust your cookie preferences or withdraw consent at any time through the “cookie preferences” link in our website’s footer. For an in-depth understanding of cookies, including their roles in websites and marketing, visit Kaspersky's comprehensive guide at Kaspersky's Cookie Information. This resource offers valuable insights into the different types of cookies and their functions, enhancing your knowledge about web technologies.
Accessing, Modifying, or Deleting Your Personal Data at Bright Bird
If you have questions about your personal data or wish to review what information Bright Bird holds about you, our team is ready to assist. You can reach out to us via [email protected] for any inquiries or requests regarding your personal data. Here's what you can do: Inquire About Your Data: Discover exactly what personal data we have of yours and understand how it is being utilized. Data Portability: You have the right to obtain your data from us for the purpose of transferring it to another service. Correction of Errors: If any of your personal data is incorrect, you can request to have these inaccuracies rectified. Deletion of Outdated Data: Request the removal of personal data that is no longer relevant or necessary. Withdraw Consent: If you've previously consented to the processing of your personal data, you have the right to withdraw this consent. Object to Specific Uses: You can object to certain ways in which your personal data is being used. For more specific requests, such as obtaining a copy of your data, please send an email to [email protected]. We are committed to responding promptly and addressing your requests, including the correction of any factual inaccuracies in your data. Should you wish to have your personal data deleted before the end of our specified retention period, you can also make this request via email. We generally accommodate such requests swiftly, ensuring your personal data is removed in accordance with your wishes. At Bright Bird, we prioritize your right to control your personal data and are committed to ensuring that your privacy is respected at every step.
Your Right to Lodge a Complaint
At Bright Bird, we take your concerns about personal data processing very seriously. If you have any complaints about how we handle your personal data, we encourage you to get in touch with us directly at [email protected]. Our dedicated team is committed to addressing your concerns and resolving any issues to your satisfaction. Additionally, you have the right to lodge a complaint with an appropriate supervisory authority, such as the data protection authority in your country (for example, the Information Commissioner's Office in the UK), if you believe your data is being mishandled.
For Any Further Questions
We understand that you might have questions or concerns about your personal data or how we handle it. Please feel free to reach out to us with any queries at [email protected]. Our team is here to assist you and provide answers to any questions you may have. We are dedicated to ensuring that you have a clear understanding of our practices and your rights when it comes to your personal data.
Final Provisions
The Privacy Policy has been written in English. The translation of this Privacy Policy is intended for informational purposes only. Should there be any difference in content, meaning or interpretation, the English version takes precedence. In this document, the name Bright Bird is sometimes used instead of the legal entity Let's Talk App B.V. It should be understood that when Bright Bird is mentioned, it is to be considered as referring to Bright Bird as a service provided by Let's Talk App B.V., and that all terms and conditions herein apply accordingly. This includes a clear acknowledgement that all rights, obligations, and responsibilities as set out in this policy are fully applicable when the name Bright Bird is used in place of Let's Talk App B.V., and that this is legally binding.
Imprint for Bright Bird
Operator & Responsible Entity
Let's Talk App B.V. (operating as Bright Bird) Address: De Boelelaan 1095a, 1081 HV Amsterdam, The Netherlands Legal representative: Camiel Kuik Chamber of Commerce ID: 87170779 VAT ID: NL864224448B01
Contact Information:
Website: www.brightbird.app Email: [email protected]
EU Dispute Resolution and Consumer Arbitration Board
The European Commission offers a platform for online dispute resolution (ODR). For more information on this platform, please visit: https://ec.europa.eu/consumers/odr/. Bright Bird is not obligated to participate in dispute resolution proceedings before a consumer arbitration board. However, for any potential disputes, please feel free to contact our team at [email protected].
