Data Policy


This policy describes the information that Bright Pilots (“We”) process to support the Bright Pilots Icebreakers service (“the Service”).

What kinds of information do we collect?

To provide the full, comprehensive customized version of the Service, we must process information about you.

Things you and others do and provide.

  • Information you provide. We collect information you provide when you use the Service, including when you sign up for an account, Like or Share content, indicate content as ‘Done’ and Bookmark content.
  • Your usage. We collect information about how you use the Service, such as the Icebreakers you view or engage with; the features you use; the actions you take; and the time, frequency and duration of your activities. For example, we log when you're signed in, and when you’re using and have last used the Service.

Device Information

As described below, we collect information about the computers, phones, connected TVs and other web-connected devices you use when using the Service. For example, we use information collected about your use of the Service on your phone to improve the experience of the content and how it’s presented on such devices.

How do we use this information?

We use the information we have (subject to choices you make) as described below and to provide and support the Service, according to the Terms of Use.

Provide, personalize and improve the Service.

We use the information we have to deliver the Service, including to ‘remember’ and track the Likes, Dones, Shares, as well as your customized lists of bookmarked Icebreakers. personalize features and content. We use the information we have to develop, test and improve the Service.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent bad experiences, and maintain the integrity of the Service. For example, we use data we have to investigate suspicious activity or violations of our Terms of Use.

Communicate with you.

We use the information we have to send you notifications for when this Data Policy or Terms of Use are updated. We also use your information to respond to you if you contact us.

How is this information shared?

Your information is shared with others in the following ways. Accrued totals of Likes, Dones and Shares are displayed publicly, however these totals are always anonymized, with no record viewable of which user account interacted with which Icebreaker.

New owner.

If the ownership or control of all or part of the Service or its assets changes, we may transfer your information to the new owner.

Sharing with Third-Party Partners

We do not sell any of your information to anyone, and we never will. We also impose strict confidentiality restrictions on how any third-party partners can view or use the personal data contained within the Service.

Researchers and academics.

We may provide information and content to research partners to conduct research that advances scholarship and innovation in the domain of facilitation and group dynamics. Any information that is shared will be completely anonymized, with no personal data disclosed.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

How can I manage or delete information about me?

We provide you with the ability to access, update, and erase your data, through your User Profile. If you delete your User Account, it is completely removed from our system (rather than archived or inactivated), with no means of retrieval. When you delete your account, We also delete any references to Icebreakers you have bookmarked.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

  • In response to a legal request (like a search warrant, court order or subpoena) if we believe that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Australia when we believe that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • When we believe it is necessary to: detect, prevent and address fraud, unauthorized use of the Service, violations of our Terms of Use, or other harmful or illegal activity; to protect ourselves (including our rights, property or Service), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on the Service.

How will we notify you of changes to this policy?

We will notify you using the email address you provide as part of your User Account before we make changes to this Data Policy and give you the opportunity to review the revised policy before you choose to continue using our Products.

How to contact Bright Pilots with questions

If you have questions about this Data Policy or our Terms of Use, you can contact us at Bright Pilots HQ.

Date of Last Revision: 20 April, 2020



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