Children's Privacy Notice
Our COPPA notice for parents
Bramble is made for families, and we treat it as directed to children under the U.S. Children’s Online Privacy Protection Act (“COPPA,” 15 U.S.C. §§ 6501–6506, and the FTC’s COPPA Rule, 16 C.F.R. Part 312). This notice explains, in COPPA’s terms, what that means for your family. It is a companion to our general Privacy Policy.
The one thing to know
Bramble collects nothing about your child: no child profile, no name, no age, no age band, and no record of what a child watched. Bramble has no way to know who is watching, and never tries to find out. The device does send two kinds of technical information that COPPA treats as identifiers: our own anonymous device identifier, and the device’s IP address and technical details, which Google’s billing software sends to Google. Both are used only to run the service and its billing, as explained below.
How Bramble works, and why that matters for privacy
A parent sets Bramble up on our website and builds a list of approved shows. Bramble is designed to be used with a parent present and involved, not handed to a child to use on their own. Bramble runs on a streaming device connected to your television — a Chromecast with Google TV, or another Google TV / Android TV device (in this notice, “the device” means that streaming device, and “your television” means the screen it is connected to). It shows that list as a grid on screen; opening a show launches the relevant streaming app directly. Bramble does not host, stream, or record any video, and it deep-links out to other apps to play content. We keep no record of what was launched: the app remembers recently-opened shows on that device alone, to order the grid, and that never leaves the television or reaches us.
The device identifies itself to our servers using a random, anonymous identifier that the device creates for itself. We use this identifier only to recognize the same device over time and to deliver the right household’s list. It is not derived from any hardware identifier (we never read an advertising ID, device serial number, MAC address, or phone identifier), it identifies a household’s list rather than a person, and the device is never even told which account it belongs to. One other piece of software on the device, Google’s billing software, sends Google technical diagnostics; see “A note about subscription purchases.”
What we collect from the device, and the legal basis
We collect one piece of information on the device: that anonymous device identifier (a “persistent identifier” in COPPA’s language). Google’s billing software also sends the device’s IP address and technical details to Google, as described below. Neither Bramble nor Google receives any other personal information about a child from the device.
COPPA lets an operator of a child-directed service collect a persistent identifier — and nothing else — without verifiable parental consent, as long as the identifier is used solely to support the internal operations of the service (16 C.F.R. § 312.5(c)(7)). We rely on that exception. For Bramble, “support for internal operations” means only these things:
recognizing the same device so it does not have to be set up again each day (authentication);
delivering your household’s approved-shows list and remembering a per-device display theme (serving and personalizing the content you asked for);
keeping the service secure and working and detecting problems (security and integrity, maintaining and analyzing functioning);
processing and troubleshooting subscription purchases made through Google Play, which requires Google’s billing software to send Google the billing diagnostics described below (maintaining and analyzing the functioning of the service); and
meeting our legal obligations.
We do not use this identifier — or anything else — to contact a specific person, to build a profile, to advertise, to track anyone across other apps or websites, or for any other purpose. We have added no advertising, analytics or tracking software to Bramble, and an automated test on every release enforces this.
How we keep these identifiers to these purposes. Our own identifier is sent only to Bramble’s servers, and our code and automated tests limit it to the uses listed above. For Google’s billing diagnostics, we rely on Google’s stated purpose for them and on Google’s terms for developers who use its billing software; we have asked Google to confirm in writing how it uses and keeps this information.
| What | Where it comes from | Why we have it | How long we keep it |
|---|---|---|---|
| Your email address | You, on the website | To create and secure your account (you sign in with a one-time code emailed to you, or with Google sign-in — either way there is no password and we store none), to bill you, and to send you service and legal messages (receipts, renewal and price-change notices) | While your account is open. If you subscribe and later cancel: 185 days after your access ends. If you create an account but never subscribe: 24 months after your last sign-in or account activity, and we email you 30 days before deleting it |
| Your approved-shows list | You, on the website | It is the service — the list the device displays | With your account (see above) |
| Anonymous device identifier and device record | The device generates it | To recognize the same device over time, deliver your list, remember a per-device display theme, and know when a device has gone unused long enough to forget. The record holds the anonymous identifier, the platform (e.g., “androidtv”), the chosen theme, a single “last seen” timestamp, and which household account the device belongs to — which is how we know whose list to send it. The identifier is not derived from anything about a person or the hardware, it is never used to identify an individual, and the device is never told which account it belongs to | 540 days after the device was last seen |
| Subscription and billing records | Google Play (device) or Stripe (website) after you subscribe | To grant what you paid for and keep the billing record the law requires | With your account; raw payment-provider messages are kept 90 days |
| Auto-renewal consent records | Recorded when you agree to the subscription terms at checkout | To prove what you agreed to, as automatic-renewal law requires. Includes the exact disclosure shown, its version, a timestamp, your IP address and browser type, and the email as it stood at consent | 4 years after the last event that could give rise to a claim (your last charge or cancellation) — see the Auto-Renewal Terms |
| Records of subscription notices we sent — that a legally required subscription notice (a renewal or price-change email) was sent, and the address it went to | Recorded when we send you a notice automatic-renewal law requires | To prove we gave the notices the law requires | 4 years after the notice was sent |
| Records of other account or billing emails we sent — that an email was sent, and to which address | Recorded when we send you an account or billing email | To confirm delivery and help resolve account and billing questions | 90 days after the email was sent |
| Your show ratings (optional) | You, on the website | If you choose to rate a show, we store two numbers (1–5) against your account and that show. Nothing about your child is stored — only your own rating of the show | With your account |
| Billing diagnostics sent to Google (not to Bramble) | Google’s billing software on the device | Google Play requires this software for subscriptions sold on the device. It reports the outcome of billing requests, with device details and the device’s IP address, to Google, which says it uses them to improve its billing software and support errors. We never receive it | Held by Google under Google’s policies, not by us. Google has not published a retention period |
| Payment method and card details | You, at checkout | We never receive or store your full card number. Payment is handled by Google Play or Stripe | Held by Google Play / Stripe under their policies, not by us |
A note about subscription purchases
If a parent buys a subscription on the device through Google Play, Google Play creates a purchase token and returns it to the app so we can grant access. That token is a billing credential generated by a parent’s purchase through Google Play — it is not information collected from a child, and it is not used to recognize a child. We keep it as the record of the purchase, as billing and consumer-protection law require.
Google’s billing software also runs on the device. Google’s billing software. Google Play requires apps that sell subscriptions on a device to use Google’s own billing software (the Google Play Billing Library), and Bramble does. Whenever the Bramble app starts or returns to the screen, that software connects to Google Play and sends Google technical diagnostics: the app and billing-software versions, the result of each billing request, and details about the device (make, model, operating-system version and build, memory, language and region setting, time zone, and network type), along with the device’s IP address, as with any internet connection. It includes no name, email address, Google account, advertising ID, or persistent device ID (only a random number that changes each time the app starts), and nothing about what is watched. Bramble never receives this information. Google says it uses it “to improve the performance of the Play Billing Library and provide better support for errors,” handles it under the Google Privacy Policy (policies.google.com/privacy), and has not published how long it keeps it.
What we never collect from children
A child’s name, age, age band, or any profile; viewing history or what was launched; precise location; contacts, photos, microphone, or camera; any advertising identifier, device serial number, MAC address, or phone identifier; or anything typed on the device. There are two places to type on the device, and nothing typed in either one is sent to us or leaves the device. The Search page filters the show list you already approved — you spell out a title with the remote on an on-screen keyboard (the device’s system keyboard is not used); what you type only narrows what is shown, is discarded the moment you leave the page, and is never stored or transmitted. The number pad that guards Settings lets you set a PIN; that PIN is kept only on that device and is never sent to us. Several of the protections in this list are enforced by automated tests that fail the build if they are ever violated.
- Any child's name, age, or age range
- Anything about which child is watching
- What was watched, or for how long
- Any analytics, crash-reporting, advertising or attribution software of our own. A test in each project fails the build if one is ever added. (Google’s required billing software is the one outside code that reports back; see “A note about subscription purchases.”)
- Location, contacts, photos, microphone or camera
- Anything typed on the device — the search keyboard narrows the list you already approved, and what you type is never written down or sent to us
How long we keep it, and deletion
The anonymous device record (the identifier, the platform, the chosen theme, and a single “last seen” timestamp) is deleted 540 days after the device was last seen. We do not keep it indefinitely. Our full retention periods are in the Privacy Policy (Section 3) and in the written data-retention policy we maintain under 16 C.F.R. § 312.10.
The billing diagnostics Google’s software sends are held by Google, not by us. Google has not published how long it keeps them, and we cannot delete them.
Your rights as a parent
Because we collect no personal information about your child, there is no child profile to review or correct. You remain fully in control:
Review and change your approved-shows list, your email, and your ratings any time by signing in at watchbramble.com.
Delete your account at any time from your account page. This removes your account and the data tied to it, including the household’s device records. The only things we keep afterward are the minimal subscription records automatic-renewal law requires us to keep as proof — that you agreed to the subscription terms, and that we sent you the notices the law requires. These concern the account holder and the payment; they contain nothing about a child, because we never collect anything about a child.
Refuse or stop collection of the anonymous device identifier by not using, or by removing, the Bramble app on the device; without it, the device cannot recognize itself and the service cannot run. Removing the app also stops Google’s billing software on that device from sending diagnostics.
You do not need to take any action to protect your child’s information. We collect nothing about your child in the first place.
No third-party collection for advertising
We do not allow any third party to collect personal information from children through Bramble for advertising or tracking. All show artwork is served only from Bramble’s own servers, so the device contacts no third-party image host — no outside company receives the device’s IP address or any other information when artwork appears.
One outside company does receive information from the device: Google, through the billing software Google Play requires. It is never used for advertising, and what it sends is described in “A note about subscription purchases.”
Questions or concerns
If you have questions about this notice, or you believe we have somehow collected personal information from a child, contact us and we will address it and delete any such information:
privacy@watchbramble.com · Scovel Investments 719, LLC (d/b/a Tenere Technology) · 1040 Pendragon Castle Drive, Pflugerville, TX 78660
The FTC provides information for parents about children’s online privacy at ftc.gov and consumer.ftc.gov.