Bonfire Digital Wellness Privacy Policy

Last updated: April 2, 2021

This Privacy Policy describes how Bonfire Digital Wellness Inc. (“BDW,” “we,” “us” or “our”) collects, uses, and shares information about you and the choices you have regarding this information.

BDW is committed to protecting your privacy: it’s the foundation for a safe and trusted community. Our privacy policy outlines what information we collect from you, how we use that information, and what choices you have regarding how and whether we can use your information. Because BDW is a learning environment for children, we take additional measures to safeguard children’s privacy, including for children under the age of 13. 

This Privacy Policy applies to the information we collect when you access or use our products, services, and technology platforms (including the websites and mobile applications that help us provide the coaching services) (collectively, the “Services”). Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

CHILDREN

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.

Collection: BDW collects information about students directly from Parents, who provide us with the Child’s first name, age, type of schooling, local time zone, and additional notes for the Teacher. In addition, Children may share information about themselves during Sessions. The BDW class sessions may take place over online videos in which video images and audio of the Children are recorded. No information is collected directly from Children until they are in the session. Children cannot post personal data publicly on the BDW Services.

Information You Provide to Us

We collect information you provide directly to us when interacting with us or using the Services. The specific information we collect depends on the context of your interactions with BDW, as detailed below. 

If you are a registrant on our website and use our coaching services via our website or one of our mobile applications (“Member”), you will need to provide certain personal information in order to register your account, such as: name, email address, phone number, and time zone. This information is required at registration so that we can: 1) create your account; 2) ensure you are matched with a coach in an appropriate time zone;. We will also collect information as it relates to your use of the platform. 

Through your use of the Services, you will also provide us information to facilitate your coaching experience. We may collect information such as your coaching platform usage, group classes attended, engagement status, session ratings and evaluations, and any other information you choose to provide in conjunction with the Services. You may also be asked, at various places within the platform, to provide your opinions on BDW’s services and quality of coaching. These opinions or reviews will be used to improve our services, and in some cases, may be shared with the coach, on a de-identified basis, for quality or educational purposes.

Parental Consent: BDW obtains verifiable parental consent before collecting Personal Data from your Child. BDW requires that you provide your credit card information in order to register your Child for and pay for an BDW Membership. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use the Services in any way. If you are not using our services for any other purposes and do not provide consent within a reasonable time from the date the direct notice was sent, we will also delete your online contact information from our records.

Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Data from your Children in association with your account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may update your Child’s information by logging onto your account. You can contact BDW to request access to, change, or delete your Child’s personal information by sending an email to us at support@bonfiredw.org. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

Sensitive Personal Information

The use of the Services does not require you to provide any sensitive personal information such as financial or demographic information. However, there may be times, such as testing a new tool or feature, where we will ask for your consent to collect demographic information such as gender, race or ethnicity, or pronouns. In all such instances your involvement and providing such information is voluntary, will have no impact on your use of the Services if you decline, and in the case you provide consent, such consent may be withdrawn at any time. At the time of requesting your consent, we will provide you details of how the data will be used or processed and how to withdraw your consent.

Use and Disclosure: BDW shares the name, age, local time zone, and any notes Parents have provided about their Child to their 1-on-1 and group coaches, in order to allow the coach to provide Services. This information shall also be treated as part of the Parent’s “Personal Data” and may be shared as described in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements. Children may also share information about themselves with the Coach and the rest of their class during the Class session voluntarily. While BDW expects Coaches and all other Users to abide by our standards of conduct, please note that we cannot control or monitor what personal information your Child shares with Coaches or other classmates, nor what those third parties ultimately do with that information, and we disclaim all responsibility in that regard.

1-on-1 Coaching Recordings:  Coaching sessions take place through BDW video chat platform are automatically recorded by BDW (“Coaching Session Recordings”). We value our Users' and Coaches' privacy, and our use of Coaching Session Recordings is extremely limited. Specifically, Coaching Session Recordings are made available only to the student, and BDW staff, in order to allow them to (1) review the Coaching Session Recording, for their personal educational purposes; and (2) review the Class Recording personally in order to improve their Sessions. In addition, BDW may use Coaching Session Recordings to provide feedback to Coaches, to improve our Services, for customer support, and for compliance purposes. BDW retains Coaching Session Recordings for six months after the date of the applicable Session, subject to this Privacy Policy, after which they are deleted. Notwithstanding the foregoing, BDW will also delete Coaching Session Recordings earlier than six months under the following circumstances: (a) upon the request of a Parent for the deletion of their child’s personally identifiable information, or (b) upon the reasonable determination of BDW that a Coaching Session Recording should be removed to protect the privacy of certain Users or because of violations of these Terms of Service. We will not use Coaching Recordings containing images of you (or your children) for promotional or any other purposes without your express written consent. By using the services, you consent to you and/or your child appearing in Coaching Session Recordings for the limited purposes set forth above.

Group Class Recordings: Classes that take place through BDW’s video chat platform are automatically recorded by BDW (“Class Recordings”). We value our Users' and Coaches' privacy, and our use of Class Recordings is limited. Specifically, Class Recordings are made available only to BDW members, and the Coach providing the Class in question, in order to allow them to (1) provide a viewable copy to BDW members who missed the Class, or who wish to review the Class, for their personal educational purposes; and (2) review the Class Recording personally in order to improve their Classes. In addition, BDW may use Class Recordings to provide feedback to Coaches, to improve our Services, for customer support, and for compliance purposes. BDW retains Class Recordings for six months after the date of the applicable Class, subject to our Privacy Policy, after which they are deleted. Notwithstanding the foregoing, BDW will also delete Class Recordings earlier than six months under the following circumstances: (a) upon the request of a Parent for the deletion of their child’s personally identifiable information, or (b) upon the reasonable determination of BDW that a Class Recording should be removed to protect the privacy of certain Users or because of violations of these Terms of Service. We will not use Class Recordings containing images of you (or your children) for promotional or any other purposes without your express written consent. By using the services, you consent to you and/or your child appearing in Class Recordings for the limited purposes set forth above.

Information We Collect Automatically When You Use the Services

When you access or use the Services, we automatically collect information about you, including the following:

• Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.
• Information Collected by Tracking Technologies: We use different technologies to collect information, including web beacons. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and to understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Information Collected By Cookies” below.
• Browser local storage. We also store data locally on your device to enhance the user experience for our Services. For example, browser local storage allows us to save the state of your current page so that when you return at a later time or refresh the browser, the page will remain the same. We may also use browser local storage to: (i) save a list of items the user last used on the website or Services (such as events and properties the user selected) so we can display “recently viewed items”; or (ii) marking once a user has seen a tutorial, video, tooltip or onboarding flow so that the user only sees the content one time.
• Mobile Services. We may also collect information from your mobile device, such as but not exclusively, the first time the mobile application is opened, mobile carrier, and the type of device that is being used, if you have downloaded our applications. This information is generally used to help us deliver the most relevant information to you and improve our Services and coaching platform. Examples of information that may be collected and used include how you use the Services and information about the type of device you use. In addition, in the event our mobile applications crash on your mobile device, we will receive information about your mobile device model and OS version, which allows us to identify and fix bugs and otherwise improve the performance of our Services. We send you push notifications from time-to-time such as reminders for coaching sessions. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.

Information You Or Your Child Share In Group Classes

While we encourage our members to build relationships with other members in Group Classes, we encourage you and your child to keep your personal information private and share at your own risk.  Please don't ask others to share personal information (e.g., email address, social media handles, mailing address, phone number, gamer tags, etc.) unless they proactively are sharing.  

COOKIES

Information Collected by Cookies

We use different technologies to collect information, including cookies. Cookies are small text files placed on an individual’s computer by websites that the individual has visited. They are used to make websites work more effectively, such as enabling you to sign in more efficiently and providing analytics on our site’s usage and performance. No Personal Information is stored within them; however, details below describe some of the cookies BDW uses, and to explain why they are used. 

You have options in how to control the data collected by cookies or similar technology. If you are a Member, you may update your cookie preferences at any time via the settings tab in your profile. 

We use the following cookies in conjunction with providing the Services.

Name	Purpose	Privacy Policy Link
Google Analytics	Analytics	Google Privacy
Google Tag Manager	Management and deployment of marketing tags	Google Privacy
CoachAccountable	Coaching platform	CoachAccountable Privacy
LandBot	ChatBot platform	LandBot Privacy
Calendly	Appointment scheduling platform	Calendly Privacy

If you wish, you may also opt-out of all cookies on your browser, by visiting the following links (note, this will opt you out of all cookies, not just BDW)

Chrome Opt Out

Safari Opt Out

Explorer Opt Out

Information We Collect From Other Sources

We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. There may also be a limited instance where we receive information about you from the coaches with whom you interact through the Services, such is when there is an issue with a session, or if you have raised an issue or concern with the coach and that coach needs additional information from us.

USE OF INFORMATION

We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the coaching services.

The information we collect from Members may be used to:

• Provide and deliver the products and services you request, process transactions, and send you related information;
• Verify your identity and, if applicable, authorization for you to use the Services (such as from your employer);
• Respond to your comments, questions, and requests;
• Send you technical notices and other administrative messages;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Conduct research, analysis, and surveys;
• Personalize and improve the Services and provide content or features that match user profiles or interests; 
• SMS messages

SHARING OF INFORMATION

If you are a Member, when you use the Services, we will share information about you with our coaches so that they can provide services to you. 

If you are a User who is accessing the services through a paid subscription through your employer , we will share information with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended, when the session was attended, or completion of an assessment). We will not share your personal information you share with our coaches. Information we do share with your employer, or other entity who has sponsored your use, is provided in an aggregated and de-identified form. 

We may also share or transfer information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf and on a need-to-know basis;
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;
• In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.

MEMBER ACCOUNT, PASSWORD AND SECURITY

You are responsible for maintaining the confidentiality of your password and account, if any, and are fully responsible for any and all activities that occur under your password or account. You agree to (a) immediately notify BDW of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session when accessing the Service. BDW will not be liable for any loss or damage arising from your failure to comply with this Section.

ANALYTICS AND ADVERTISING SERVICES

In order to provide the Services we engage analytics service providers on our behalf. These providers help us track actions on the platform to help identify areas of engagement and to help us improve your site experience. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information.  This information may be used by BDW and its third party providers, to analyze and track data and better understand your online activity while using our Services.

DATA RETENTION

We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

YOUR CHOICES

Your Information

You may update, correct or delete information about you at any time by contacting us at compliance@BDW.co. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

Promotional Communications

CALIFORNIA 

If you are a California resident, you have certain rights and protections under the law regarding the processing and sale of your personal data. The California Consumer Privacy Act (CCPA) grants new privacy rights to Californians, including rights to: 

• The right to know about the personal information a business collects about you and how it is used and shared;
• The right to delete personal information collected from you (with some exceptions);
• The right to opt-out of the sale of your personal information; and
• The right to non-discrimination for exercising their CCPA rights. 

Businesses are required to give consumers certain notices explaining their privacy practices. This section and our Privacy Policy will explain to you what personal information we may collect and the purposes for which we use this information.

BDW does not sell your personal information. BDW may share your personal information with our Service Providers, who are defined within CCPA as entities who will process your personal information on behalf of BDW but are contractually limited to processing and retaining your information solely to provide the service to BDW. 

If you are a California resident and would like to exercise any of your rights as described here, e-mail us at:  support@bonfiredw.org

CONTACT INFORMATION

If you have questions or comments about our Privacy Policy, or you are a consumer with a request, please email us at support@bonfiredw.org