Privacy Policy

IMPORTANT — CHILDREN’S PLATFORM: BriBooks is a creative writing platform designed for children and young people aged 8–18. This Privacy Policy explains how we collect, use, and protect personal data — including the personal data of children. Please read this policy carefully. If you are a parent, guardian, or school registering a child on BriBooks, this policy applies to you and to the child you are registering.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Interpretation and Definitions

1.1 Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

1.2 Definitions

For the purposes of this Privacy Policy:

• Account: A unique account created for you to access our Service or parts of our Service.
• Company: Referred to as either “the Company,” “We,” “Us” or “Our” in this Agreement. Refers to Youbooks Edtech Pte Ltd, 200 Cantonment Road, #06-01A, Southpoint, Singapore (089763).
• Cookies: Small files placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
• Country: Singapore.
• Device: Any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Minor / Child: Any individual under the age of 18, or under the age defined as a minor in their applicable jurisdiction, whichever is higher. For COPPA purposes, “child” specifically means any person under 13 years of age.
• Parent/Guardian: The parent, legal guardian, or other person with parental responsibility for a Minor using the Platform.
• Registered School: An educational institution that has registered with BriBooks and enrolled students on the Platform.
• Education Records: As defined under FERPA (20 U.S.C. § 1232g): records, files, documents, and other materials that contain information directly related to a student and are maintained by BriBooks on behalf of a Registered School. This includes student names, usernames, written works, and usage data linked to a student account.
• Personal Data: Any information that relates to an identified or identifiable individual.
• Service: Refers to the Website.
• Service Provider: Any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
• Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website: BriBooks, accessible from www.bribooks.com.
• You: The individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

Data Collected from Student / Minor Users

COPPA NOTICE: BriBooks knowingly provides services to children under 13 in the United States through school and parental consent mechanisms. We collect the minimum data necessary from child users. The following is a complete list of personal data we collect from children under 13:

• First name and last name
• Username (chosen at registration)
• School name and grade/year group
• Creative content produced on the Platform (book drafts, published works, images uploaded by the student)
• Usage Data (device type, IP address, browser type, pages visited, time spent — used solely for service operation and security)

We do NOT collect from children under 13: phone numbers, precise geolocation data, government-issued identifiers, payment information, or any data beyond what is listed above.

We do not condition a child's participation in the Service on the disclosure of more personal information than is reasonably necessary.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

2.2 Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. The technologies we use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service.
• Flash Cookies: Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to count users who have visited those pages or opened an email and for other related website statistics.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies — Session Cookies: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.
• Cookies Policy / Notice Acceptance Cookies — Persistent Cookies: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies — Persistent Cookies: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference, to provide you with a more personal experience.

NOTE ON COOKIES AND MINOR USERS: BriBooks does not use tracking or advertising cookies on accounts identified as Minor users. Cookies set for Minor user sessions are limited to essential/session cookies necessary for the operation of the Service only.

2.3 Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your Account and your registration as a user of the Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
• To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information.
• To manage your requests to us.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets.
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing and your experience.

RESTRICTION ON USE OF CHILDREN’S DATA: Personal data collected from Minor users — including Education Records — will ONLY be used to provide and support the BriBooks educational service. We will not use children's personal data for marketing, advertising, profiling, or any commercial purpose. We will not sell, rent, or share children's personal data with third parties for any purpose other than delivering the Service.

2.4 Sharing Your Personal Data

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyse the use of our Service, or to contact you.
• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy.
• With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
• With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With your consent: We may disclose your personal information for any other purpose with your consent.

RESTRICTION ON SHARING CHILDREN’S DATA: Notwithstanding the general sharing provisions above, BriBooks will NOT share the personal data of Minor users or Education Records with Service Providers, affiliates, or business partners for advertising, marketing, or commercial profiling purposes. Any Service Provider that processes children's data on our behalf is contractually bound to use that data solely to deliver the BriBooks service and to comply with applicable children's data protection laws including COPPA and FERPA.

3. Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

CHILDREN’S DATA RETENTION: Personal data collected from Minor users and Education Records will be retained only for as long as the student's account is active or as is necessary to provide the Service. Upon account deletion or a school's request to remove a student, the student's personal data will be deleted from our active systems within 30 days. Backup copies will be purged within 90 days. We will not retain children's personal data beyond what is necessary for the educational purpose for which it was collected.

4. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

5. Disclosure of Your Personal Data

5.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

5.2 Law Enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

FERPA — EDUCATION RECORDS DISCLOSURE: Where BriBooks holds Education Records on behalf of a Registered School, BriBooks will not disclose those records to law enforcement or any third party without the prior written consent of the school or, where applicable, the eligible student or Parent/Guardian — except as required by a lawful court order or subpoena. In such cases, BriBooks will promptly notify the relevant school to the extent permitted by law before making any disclosure.

5.3 Other Legal Requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

6. Your Privacy Rights

As a user of BriBooks, you have the following rights regarding your personal data:

1. Right to Request Deletion: You may request that we delete the personal data we have collected about you, subject to legal or contractual obligations.
2. Right to Request Access: You may request a copy of the personal data we collect and process about you.
3. Right to Request Correction: You may request corrections to any inaccurate or incomplete personal data we hold.
4. Right to Know Whether Data is Sold: You have the right to know whether we sell your personal data. BriBooks does not sell personal data.
5. Right to Know Whether Data is Shared: You have the right to know whether we share your personal data with third parties, and for what purposes. BriBooks does not share personal data for commercial purposes.
6. Right to Opt-Out of Sale: While BriBooks does not engage in any form of data sale, if BriBooks ever engages in selling personal data, you will have the right to opt-out.
7. Right to Opt-Out of Sharing: You may opt-out of your personal data being shared with third parties for purposes beyond providing our services.

7. COPPA — Children’s Privacy Rights (United States)

WHO THIS SECTION APPLIES TO: This section applies to parents and guardians of children under 13 in the United States, and to Registered Schools acting on behalf of such children under COPPA (15 U.S.C. §§ 6501–6506).

BriBooks knowingly collects personal data from children under 13 through the verifiable consent mechanisms described below. We are committed to full compliance with COPPA.

7.1 Consent Mechanism

Children under 13 may only access BriBooks after verifiable parental consent has been obtained through one of the following methods:

• Direct Parent/Guardian Registration: a parent or guardian registers the child directly on the BriBooks portal and provides consent at the time of registration.
• School Registration (School as Agent): a Registered School registers the child on behalf of the parent/guardian. By doing so, the school warrants that it has obtained all necessary parental consents and acts as the parent's authorised agent for COPPA consent purposes. This consent is limited to educational use within the school programme.

7.2 What We Collect from Children Under 13

We collect only the minimum data necessary to provide the Service:

• First name and last name
• Username
• School name and grade/year group
• Creative content produced on the Platform
• Usage Data (device and session data for service operation and security only)

We do NOT collect: phone numbers, precise location data, government identifiers, biometric data, payment information, or any data not listed above.

7.3 How We Use Children's Data

Personal data collected from children under 13 is used solely to:

• Create and manage the child's account on BriBooks
• Provide the creative writing and publishing features of the Platform
• Communicate with the Registered School or Parent/Guardian about the child's activity
• Ensure the safety and integrity of the Platform

We do NOT use children's data for: targeted advertising, behavioural profiling, marketing, or any commercial purpose. We do NOT sell children's data.

7.4 Parental Rights Under COPPA

Parents and guardians have the following rights at any time:

• Review the personal data we have collected from their child
• Direct us to delete their child's personal data
• Refuse to permit further collection or use of their child's data
• Withdraw consent and request closure of their child's account
• Request a description of the types of third parties (if any) with whom we share children's data

To exercise any of these rights, contact: support@bribooks.com (subject: "COPPA Parental Rights Request"). We will respond within 10 business days.

7.5 Data Retention for Children

Children's personal data is retained only for as long as the account is active or as necessary to provide the Service. Data is deleted from active systems within 30 days of account closure. We do not retain children's data for longer than necessary for the educational purpose for which it was collected.

8. FERPA — Education Records (United States)

WHO THIS SECTION APPLIES TO: This section applies to Registered Schools in the United States and to parents/guardians and eligible students (aged 18+) whose Education Records are held by BriBooks on behalf of a US school under FERPA (20 U.S.C. § 1232g).

8.1 BriBooks as a School Official

Where BriBooks is used by US educational institutions, BriBooks acts as a school official with a legitimate educational interest as defined under FERPA. BriBooks processes Education Records solely to provide the BriBooks service to the school and its students, and for no other purpose.

8.2 Our FERPA Commitments

• BriBooks will not disclose Education Records to any third party without the prior written consent of the school, eligible student, or Parent/Guardian — except as expressly permitted by FERPA.
• BriBooks will not use Education Records for any commercial purpose, including advertising, marketing to students or families, or building profiles for third parties.
• Registered Schools retain full ownership and control of their students’ Education Records held by BriBooks.
• BriBooks will maintain appropriate administrative, technical, and physical safeguards to protect Education Records against unauthorised access, disclosure, alteration, or destruction.
• In the event BriBooks receives a subpoena or court order for Education Records, BriBooks will promptly notify the relevant school to the extent permitted by law before making any disclosure.

8.3 School and Parental Rights Under FERPA

Registered Schools, eligible students (18+), and parents/guardians have the following rights:

• Inspect and review Education Records held by BriBooks on behalf of the school
• Request amendment of Education Records that are inaccurate or misleading
• Request deletion of Education Records upon withdrawal from the school programme
• Receive a copy of BriBooks’ data processing practices relating to Education Records

To exercise any of these rights, contact: support@bribooks.com (subject: "FERPA Records Request").

8.4 Data Processing Agreement

Registered Schools that require a formal Data Processing Agreement (DPA) or FERPA-specific contractual addendum may request one by emailing support@bribooks.com (subject: "FERPA DPA Request"). BriBooks will enter into such an agreement upon reasonable request at no additional charge.

9. California Consumer Privacy Act (CCPA) Rights

If you are a California resident, you are entitled to specific rights under the California Consumer Privacy Act (CCPA), including:

• The right to request disclosure of the categories and specific pieces of personal data we have collected.
• The right to request deletion of your personal data.
• The right to opt-out of the sale of your personal data.
• The right to know whether your personal data has been shared.
• The right to non-discrimination for exercising your CCPA rights.

10. Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We maintain appropriate administrative, technical, and physical safeguards to protect personal data — including Education Records and children's data — against unauthorised access, disclosure, alteration, or destruction.

11. Children’s Privacy

CORRECTED POLICY STATEMENT: Earlier versions of this policy stated that 'Our Service does not address anyone under the age of 13'. That statement was inaccurate. BriBooks is designed for children aged 8–18 and knowingly provides services to children under 13 through verifiable parental and school consent mechanisms as described in Sections 7 and 8 of this Privacy Policy. The detailed children's privacy protections applicable to BriBooks are set out in those sections.

If you are a parent or guardian and you are aware that your child has provided us with personal data without your knowledge, please contact us at support@bribooks.com. We will promptly investigate and, where required, delete such information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we will require your parent's consent before we collect and use that information.

12. Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective, and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Terms & Conditions for BriBooks.com Image Upload

• Copyright and Intellectual Property Rights: You represent and warrant that you own or have obtained all necessary licences, permissions, and consents required to use and upload the images to BriBooks.com. You agree not to upload any images that infringe or violate any intellectual property rights, including but not limited to copyright, trademark, or trade secret rights. You also agree to indemnify and hold BriBooks.com harmless from any claims or damages arising out of any alleged or actual infringement or violation of intellectual property rights.
• Religious and Cultural Sentiments: You acknowledge and agree that BriBooks.com is a platform for people of all cultures and religions. Therefore, you must not upload any images that are discriminatory, defamatory, or offensive to any particular community or religion.
• Image Usage Rights: By uploading your images to BriBooks.com, you grant BriBooks.com a worldwide, royalty-free, non-exclusive, perpetual, irrevocable, and sublicensable licence to use, reproduce, modify, adapt, publish, translate, distribute, and display the images in connection with our services. Where the uploader is a Parent/Guardian or school accepting on behalf of a Minor, any use of the Minor's name, image, or likeness in marketing requires the additional separate written consent of the Parent/Guardian.
• Image Removal Rights: BriBooks.com reserves the right to remove any images that violate these terms and conditions or are deemed inappropriate or offensive. BriBooks.com will not be responsible for any damages or losses arising out of the removal of any images.
• User Conduct: You agree not to use BriBooks.com for any unlawful, harmful, or inappropriate purposes, including but not limited to uploading images that are illegal, fraudulent, obscene, or harassing.
• Limitation of Liability: BriBooks.com will not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising out of your use of our services or these terms and conditions.
• Governing Law: These terms and conditions will be governed by and construed in accordance with the laws of Singapore, subject to any mandatory children's privacy or consumer protection laws that apply in your jurisdiction.
• Modification: BriBooks.com reserves the right to modify these terms and conditions at any time. Your continued use of our services after any modification constitutes your acceptance of the modified terms and conditions.

15. Data Controller and Data Protection Officer (DPO)

Data Controller
Youbooks Edtech Pte. Ltd.
200 Cantonment Road, #06-01A, Southpoint, Singapore (089763)
Email: support@bribooks.com

Data Protection Officer (DPO)
Rupesh Kanth
Email: dpo@bribooks.com
Address: Same as Data Controller above.

16. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

Enquiries: support@bribooks.com
Data Protection Officer: dpo@bribooks.com
Website: https://www.bribooks.com