Privacy Policy

Effective Date: October 1, 2026

Platform Provider: Brighter Minds Lab LLC ("Brighter Minds," "Company," "we," "us," or "our")

Brighter Minds Lab LLC respects your privacy and is committed to protecting personal information. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard information when you use Learn Depot, Clarifly-powered learning experiences made available through Learn Depot, our websites, creator tools, course marketplace and related services (collectively, the "Platform"). It applies to course creators, learners, prospective users, visitors, and other individuals who interact with the Platform (collectively, "you" or "Users").

Please read this Privacy Policy carefully. By using the Platform, you acknowledge the data practices described here. Where applicable law requires consent for a particular processing activity, we will request that consent separately.

1. Information We Collect

1.1 Information You Provide Directly

Account and Profile Information: Name, email address, password or authentication credentials, phone number if provided, business or organization name, profile information, account preferences, and related registration information.

Creator and Course Content: Course titles and descriptions, scripts and transcripts, text, outlines, documents, images, audio, video, assessments, Mem Cards, Brain Bites, Smart Visuals, learner activities, and other materials you upload, create, edit, publish, or otherwise provide through the Platform.

Commerce and Subscription Information: Subscription plan, billing status, purchases, course pricing, transaction history, refunds, disputes, payout status, promotional or referral codes, and related commerce records. Payment-card details and certain payout or identity-verification information may be collected directly by our payment providers rather than stored by Brighter Minds.

Payout and Verification Information: If you use Learn Depot Pay or receive marketplace payouts, our payment provider may collect identity, business, tax, bank-account, or other verification information. Where supported, sensitive verification materials such as full Social Security numbers, employer identification numbers, identity documents, and bank credentials are collected and retained by the payment provider rather than Brighter Minds. We may receive verification status, payout eligibility, account identifiers, and other non-sensitive account state needed to operate the service.

Communications: Information you provide when contacting support, submitting feedback, responding to surveys, participating in account or compliance reviews, or otherwise communicating with us.

1.2 Information Collected Automatically

Usage and Activity Data: Access times, pages and screens viewed, features used, course activity, learning progress, interactions with creator tools and AI-assisted features, navigation events, error events, and similar usage information.

Technical and Device Data: IP address, browser type, operating system, device type, language and locale settings, referring URLs, network information, and identifiers used for security, authentication, diagnostics, or service operation.

Cookies and Similar Technologies: Cookies and similar technologies may be used to keep you signed in, remember preferences, maintain security, understand Platform performance, and support analytics. Where required, we will provide applicable cookie choices or consent controls.

1.3 Information From Other Sources

Service Providers and Business Partners: We may receive information from payment processors, identity or payout-verification providers, hosting and infrastructure providers, analytics or security vendors, referral or affiliate systems, and other providers used to operate the Platform.

Creator-Provided Learner Information: When a learner accesses a creator’s course or learning experience, we may process information associated with that learner’s enrollment, access, progress, responses, completion, and interactions in order to provide the learning experience and related creator-facing functionality.

2. How We Use Information

Provide and Operate the Platform: Create and maintain accounts; authenticate users; host and deliver courses; provide learning activities; save progress and preferences; support creator workspaces; and provide customer support.

Payments, Subscriptions, and Payouts: Process creator subscriptions and course purchases; administer Build Credits where applicable; facilitate payouts; apply promotions or referral attribution; manage refunds, disputes, chargebacks, taxes, and transaction records; and prevent payment abuse.

AI-Assisted Features: Process creator-provided grounding materials, prompts, instructions, and relevant course context to generate or assist with learning activities and other requested outputs.

Personalization and Learning Functionality: Provide locale-aware content, recommendations, progress views, course navigation, learning activities, and other features based on a User’s settings and Platform activity.

Security, Integrity, and Fraud Prevention: Protect accounts and infrastructure; detect abuse, unauthorized access, fraud, malicious activity, or violations of our Terms; investigate incidents; and maintain audit and security records.

Improve and Develop the Platform: Analyze performance and usage, troubleshoot problems, evaluate feature effectiveness, improve usability and reliability, and develop new functionality.

Communications: Send transactional messages, account notices, security alerts, billing or payout communications, support responses, service announcements, and, where permitted, marketing communications.

Legal and Compliance: Comply with law, respond to lawful requests, enforce agreements, establish or defend legal claims, and protect the rights, safety, and property of Brighter Minds, Users, and others.

3. AI Processing and Creator Content

Processing of AI Inputs: When you intentionally use an AI-assisted feature, relevant prompts, scripts, transcripts, course materials, instructions, and contextual data may be sent to AI service providers or other subprocessors as needed to produce the requested result.

Purpose Limitation: We use AI inputs and outputs to provide, secure, evaluate, and improve the requested Platform functionality. We do not sell proprietary creator course content or AI prompts.

Generalized Model Training: Brighter Minds does not use proprietary creator course content to train a generalized Brighter Minds model without separate authorization. Third-party AI providers process information under their applicable agreements, privacy commitments, configurations, and our service arrangements. Because provider practices can change, Users should not submit information to AI-assisted features that they are not authorized to process or that is unnecessary for the requested task.

Human Review and Safety: Authorized personnel may access limited content when reasonably necessary for support, security, abuse prevention, legal compliance, quality review, or troubleshooting, subject to access controls and confidentiality obligations.

4. How We Disclose Information

Service Providers and Subprocessors: We may disclose information to vendors that provide cloud hosting, storage, content delivery, video infrastructure, communications, analytics, customer support, security, payment processing, payout verification, AI processing, and other services on our behalf. They receive information as necessary to perform their services and are subject to contractual or legal obligations as applicable.

Creators and Learners: Information necessary to operate a course may be shared between the creator and enrolled learners. For example, creators may receive learner enrollment, progress, completion, and engagement information, while learners may see creator identity, course materials, and information the creator chooses to publish.

Payment and Commerce Partners: Transaction, subscription, identity-verification, payout, refund, dispute, and fraud-related information may be shared with payment processors and financial-service providers as necessary to process commerce and comply with their requirements.

Affiliates and Referral Programs: If a purchase or signup is associated with a referral or affiliate code or link, we may process and disclose attribution and transaction information needed to administer the program, calculate commissions, apply discounts, and handle reversals.

Optional Distribution: If a creator affirmatively participates in an additional distribution channel, such as Clarifly Distribution, we may use and disclose course, creator, transaction, and engagement information as needed to review, operate, measure, and support that distribution.

Business Transfers: Information may be disclosed in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to applicable law.

Legal, Safety, and Rights: We may disclose information when we reasonably believe disclosure is required by law or legal process, or is necessary to protect rights, safety, security, users, the public, or the integrity of the Platform.

5. Sale, Sharing, and Advertising

No Sale of Personal Information: We do not sell personal information for money. We also do not sell proprietary creator course content or AI inputs.

Targeted or Cross-Context Advertising: Our current Platform is not designed around selling User information to advertisers. If our practices change in a way that creates a legal right to opt out of sale, sharing, or targeted advertising, we will provide the notices and controls required by applicable law.

Service Analytics: We may use service providers to understand Platform usage, reliability, and performance. Their handling of information is governed by applicable agreements and law.

6. Payments, Identity Verification, and Financial Information

Payment Processing: Payments may be processed by third-party payment providers. Brighter Minds generally receives transaction details and payment status rather than full payment-card credentials.

Creator Payouts: Creators who receive marketplace payouts may be required to complete identity, business, tax, bank-account, or risk verification with our payment provider before payouts are enabled.

Sensitive Verification Data: Where supported by our payment provider, Brighter Minds does not store raw Social Security numbers, employer identification numbers, identity-document images, or complete bank credentials. We may retain the provider account identifier, verification state, payout eligibility, risk or restriction state, and records necessary for legal, financial, fraud-prevention, and audit purposes.

7. Data Retention

General Retention: We retain personal information for as long as reasonably necessary to provide the Platform, maintain accounts and courses, fulfill transactions, comply with law, resolve disputes, enforce agreements, prevent fraud, maintain security, and satisfy legitimate business and audit needs.

Account and Course Deletion: When an account, course, or workspace is deleted, associated information may be deleted or de-identified according to our retention processes, except where we must retain information for legal, financial, security, fraud-prevention, backup, dispute, or audit purposes.

Inactive Pre-Subscription Creator Workspaces: Unpaid pre-subscription creator workspaces may become eligible for deletion after 90 days without meaningful Creator Studio activity. We may provide advance notice before deletion where practicable. Activity may reset the abandonment period. Certain legal, security, and audit records may be retained after workspace deletion as permitted or required by law.

Backups: Residual copies may remain in backups for a limited period until overwritten or deleted in the ordinary course of our backup and disaster-recovery processes.

8. Data Security

Safeguards: We use administrative, technical, and organizational safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction. Measures may include encryption in transit, access controls, authentication controls, logging, monitoring, and secure infrastructure practices.

No Absolute Security: No method of transmission or storage is completely secure. We cannot guarantee absolute security, and Users are responsible for protecting account credentials and promptly notifying us of suspected unauthorized access.

9. Your Privacy Rights and Choices

Access, Correction, and Deletion: Depending on where you live and subject to legal exceptions, you may have rights to request access to personal information, correct inaccurate information, obtain information about our processing, or request deletion.

Portability: Where required by law, you may have the right to obtain certain personal information in a portable format.

Opt-Out Rights: Where applicable, you may have rights to opt out of certain sales, sharing, targeted advertising, or profiling. As described above, we do not currently sell personal information for money.

Sensitive Personal Information: Where applicable law grants rights concerning sensitive personal information, you may exercise those rights as provided by law.

Marketing: You may unsubscribe from promotional email communications using the unsubscribe mechanism in those messages. We may still send non-promotional messages necessary to operate your account or transactions.

Cookie Choices: You can control many cookies through browser settings and any consent or preference controls we make available. Disabling certain cookies may affect Platform functionality.

Non-Discrimination: Where required by law, we will not unlawfully discriminate against you for exercising applicable privacy rights.

Submitting a Request: To submit a privacy request, contact support@brighterminds.io. We may need to verify your identity or authority before completing a request. Authorized agents may submit requests where permitted by applicable law.

Appeals: If applicable law gives you a right to appeal our response to a privacy request, you may submit an appeal using the same contact information and identify the request you are appealing.

10. California Privacy Rights

Applicability: If the California Consumer Privacy Act, as amended, applies to Brighter Minds and to your information, California residents may have rights to know, access, delete, correct, opt out of sale or sharing, limit certain uses or disclosures of sensitive personal information, and receive equal service and pricing when exercising privacy rights, subject to statutory exceptions.

Categories of Information: The categories described in Section 1 may include identifiers; customer records; commercial information; internet or electronic network activity; professional or employment-related information; education-related information; audio, electronic, visual, or similar information; inferences; and, when applicable, sensitive personal information.

Sources, Purposes, and Recipients: We collect information from Users, devices and browsers, creators, service providers, payment and verification providers, and other sources described in this Policy. We use it for the purposes in Section 2 and disclose it to the categories of recipients described in Section 4.

Requests: California residents may contact support@brighterminds.io to exercise applicable rights. We will verify and respond to requests as required by law.

11. Children’s Privacy

General Audience Service: Learn Depot and its creator tools are not directed to children under 13. We do not knowingly collect personal information online from children under 13 without the authorization required by applicable law.

If We Learn of Underage Collection: If we learn that we collected personal information from a child under 13 in circumstances requiring parental consent and did not obtain the required consent, we will take appropriate steps to delete or otherwise address the information as required by law.

Creator Responsibilities: Creators must not use the Platform to collect personal information from children in violation of applicable law. If a creator intends to offer learning experiences to minors, the creator is responsible for complying with applicable age, consent, education, and privacy requirements, and Brighter Minds may impose additional safeguards or restrictions.

12. International Users and Data Transfers

United States Operations: Brighter Minds is based in the United States. If you access the Platform from another country, your information may be processed in the United States or other locations where our service providers operate.

Transfer Safeguards: Where applicable law requires specific safeguards for cross-border transfers, we will use appropriate contractual or other lawful transfer mechanisms.

13. Third-Party Links, Embeds, and Services

Third-Party Services: The Platform may contain links to or integrations with third-party websites, video hosts, payment services, authentication providers, plugins, or other services. Their privacy practices are governed by their own policies, not this Privacy Policy.

Embedded Content: Creators may include supported third-party video links or other embedded content. When a User interacts with that content, the third-party provider may receive information such as IP address, device information, or interaction data according to its own privacy practices.

14. Changes to This Privacy Policy

Updates: We may update this Privacy Policy from time to time. We will post the updated policy and revise the Effective Date. If changes are material, we may provide additional notice, such as through the Platform or by email, as required by applicable law.

Consent Where Required: If applicable law requires renewed consent for a material change, we will request that consent rather than relying solely on continued use.

15. Contact Us

Privacy Questions and Requests: Brighter Minds Lab LLC 11175 Cicero Drive, Suite 100 Alpharetta, GA 30022, USA Email: support@brighterminds.io