Privacy Policy and Personal Data Protection Notice

Effective date: 10 July 2026
Last updated: 10 July 2026

1. Introduction

Dew Bright Solution respects your privacy and is committed to handling personal data responsibly, transparently and securely.

This Privacy Policy and Personal Data Protection Notice explains how we collect, use, store, disclose and protect personal data when you:

  • Visit www.dbsolution.pro;

  • Request or participate in a Dew Bright pilot;

  • Subscribe to communications;

  • Contact us;

  • Review, purchase or use our educational resources; or

  • Communicate with us in a professional or institutional capacity.

It also explains the choices and rights available to you.

For the purposes of applicable data protection laws, the party responsible for the personal data described in this policy is:

Dew Bright Solution
Operated by: Oleh Borysiuk
Location: Hai Phong, Vietnam
Email: schools@dbsolution.pro
Phone: +84 58 638 0109
Website: https://www.dbsolution.pro

In this policy, “Dew Bright,” “we,” “us” and “our” refer to Dew Bright Solution.

2. Who Our Services Are For

Dew Bright provides educational systems, pilot programmes and professional resources to schools, educational institutions, school leaders, teachers and other education professionals.

Our website and services are intended for adults acting in a professional or institutional capacity. They are not directed to children or individual students.

Schools participating in a pilot are not required to provide student names, student email addresses, photographs, identification details, academic records or other student personal data.

3. Personal Data We May Collect

The personal data we collect depends on how you interact with us.

3.1 Pilot and institutional enquiries

When you request a pilot pack, discuss implementation or enquire about institutional access, we may collect:

  • School or institution name;

  • School email address;

  • Country;

  • Your name, if provided;

  • Your professional role or position, if provided;

  • Telephone number, if provided;

  • Information contained in your enquiry or correspondence;

  • Pilot participation and implementation information; and

  • Professional feedback voluntarily provided by participating educators.

School name, school email address and country are necessary for us to verify institutional eligibility and provide the requested pilot. If this information is not provided, we may be unable to process the request.

Other information is voluntary unless clearly identified otherwise.

3.2 Newsletter and communications

If you subscribe to updates or request information, we may collect:

  • First name;

  • Email address;

  • Communication preferences;

  • Subscription and unsubscribe history; and

  • Records of emails sent, delivered or interacted with, where supported by our communication platform.

Newsletter subscription is voluntary and is not required to receive or participate in the pilot.

3.3 Institutional licensing and transactions

If an institution purchases or licenses Dew Bright resources, we may collect:

  • Institutional and authorised-contact details;

  • Billing and invoicing information;

  • Transaction records;

  • Licence and access information;

  • Contractual correspondence; and

  • Support and implementation records.

We do not directly store complete payment-card information. Payments may be processed by independent payment providers operating under their own privacy policies.

3.4 Information collected automatically

When you visit our website, certain technical information may be collected automatically, including:

  • Internet Protocol address;

  • Approximate location derived from the IP address;

  • Browser and device type;

  • Operating system;

  • Referring website;

  • Pages viewed;

  • Date and time of access;

  • Time spent on pages;

  • Links and buttons used;

  • Website performance and diagnostic data; and

  • Cookie or similar technology identifiers.

3.5 Information obtained from professional and public sources

When conducting school outreach, we may obtain professional contact information from:

  • Official school and institutional websites;

  • Public education directories;

  • Publicly available professional profiles;

  • Institutional publications;

  • Professional referrals; and

  • Other lawful, publicly accessible sources.

This may include a person’s name, professional title, school, institutional email address and other publicly available business-contact information.

We use such information only for relevant professional communication and where the communication is permitted by applicable law.

4. How We Use Personal Data

We may use personal data to:

  • Verify whether an applicant represents an eligible school or institution;

  • Respond to enquiries;

  • Deliver requested pilot materials;

  • Administer and support pilot participation;

  • Provide implementation guidance;

  • Communicate about requested resources or services;

  • Manage institutional licences and contractual relationships;

  • Process payments, invoices and administrative records;

  • Collect and evaluate professional pilot feedback;

  • Improve our educational resources, website and user experience;

  • Measure website performance and engagement;

  • Maintain website security and prevent misuse;

  • Keep appropriate business and compliance records;

  • Send newsletters or promotional communications where you have consented or where otherwise permitted by law;

  • Honour unsubscribe, objection and communication-preference requests;

  • Establish, exercise or defend legal rights; and

  • Comply with legal and regulatory obligations.

We do not use personal data collected for a pilot application to enrol a person in unrelated marketing without an appropriate legal basis.

5. Legal Grounds for Processing

Depending on the circumstances and applicable law, we process personal data on one or more of the following grounds:

  • Consent: You have freely agreed to a particular use of your personal data.

  • Steps taken at your request: Processing is necessary to respond to your enquiry, provide a requested pilot or discuss institutional access.

  • Contractual necessity: Processing is necessary to enter into or perform an institutional agreement.

  • Legal obligations: Processing is necessary to meet accounting, regulatory, security or other legal requirements.

  • Legitimate professional interests: Where permitted by law, processing may be necessary for reasonable institutional communication, service improvement, security or administration, provided those interests do not override your rights.

  • Other lawful grounds: We may process information where another applicable legal exception or authorisation permits it.

Where consent is required, you may withdraw it at any time. Withdrawal does not affect processing lawfully performed before consent was withdrawn.

6. Pilot Feedback and Educational Information

Teacher and school feedback helps us evaluate and improve Dew Bright resources.

We may use feedback to:

  • Identify implementation strengths and challenges;

  • Improve instructions, timing, classroom management and activity design;

  • Assess the practical usability of resources; and

  • Prepare aggregated or anonymised findings.

We will not publicly identify a school, educator or institution in a testimonial, case study or promotional publication without appropriate permission.

Schools should not include student names, identifiable student images, student contact information, medical information, assessment records or other student personal data in feedback forms or correspondence.

If identifiable student data is submitted unintentionally, we may delete, anonymise or restrict it and contact the submitting institution where appropriate.

7. Marketing and Professional Communications

If you request a pilot, we may send communications necessary to:

  • Verify your school;

  • Deliver the pilot;

  • Explain implementation;

  • Request agreed professional feedback; and

  • Respond to questions about participation.

These operational messages are part of the service you requested.

Separate promotional newsletters or general product announcements are sent only where permitted by applicable law. You may unsubscribe at any time by:

We may retain a minimal suppression record, normally the email address and opt-out date, to ensure that your preference continues to be respected.

8. Cookies and Similar Technologies

Our website may use cookies, tags and related technologies to operate correctly, understand website usage, improve performance and measure communication effectiveness.

These technologies may include:

Essential technologies

These support basic website operation, security, forms, page delivery and user preferences.

Analytics technologies

These help us understand how visitors use the website, which pages are viewed and how the site performs.

Our analytics tools may include:

  • Google Analytics;

  • Google Tag Manager; and

  • Ahrefs Web Analytics.

Marketing and measurement technologies

The website may use the Pinterest tag or similar technologies to measure referrals, campaign performance or website interactions.

These providers may receive technical information such as IP address, device information, page activity and cookie identifiers. Their handling of information is also governed by their respective privacy policies.

Where applicable law requires consent, non-essential analytics or marketing technologies should be activated only after the visitor has been given an appropriate choice.

You may manage cookies through the website’s consent controls, where available, or through your browser settings. Blocking certain cookies may affect some website functions.

9. When We Share Personal Data

We do not sell or rent personal data.

We may disclose limited personal data to trusted service providers that help us operate Dew Bright, including providers of:

  • Website building, hosting and content delivery;

  • Online forms and contact management;

  • Email delivery and communication automation;

  • Analytics and website measurement;

  • Cloud storage and information technology;

  • Payment processing and invoicing;

  • Security, backup and technical support;

  • Professional legal, accounting or compliance advice; and

  • Pilot feedback and survey tools.

Services used in connection with the website may include Systeme.io, Google services, Ahrefs, Pinterest and cloud infrastructure or content-delivery providers used by those services.

We may also disclose information:

  • When required by law, regulation, court order or a competent authority;

  • To investigate fraud, security threats or misuse;

  • To protect our legal rights or the rights and safety of others;

  • In connection with a business reorganisation, transfer or succession, subject to appropriate safeguards; or

  • With your explicit permission.

Service providers are authorised to process personal data only for relevant operational purposes and are expected to protect it appropriately.

10. International Data Transfers

Dew Bright Solution operates from Vietnam and serves institutions in multiple countries.

Our technology and service providers may process or store personal data in Vietnam, the United States, the European Economic Area or other countries in which they or their subcontractors operate.

Data protection standards may differ between countries. Where required, we take reasonable steps to protect international transfers through appropriate contractual arrangements, provider assessments, consent or other recognised transfer mechanisms.

By requesting an internationally delivered service, you understand that limited personal data may need to be processed outside your country so that we can provide that service.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for legitimate legal, administrative and security requirements.

Our general retention approach is:

  • Pilot requests and participation records: During participation and normally for no longer than 24 months after the last meaningful interaction.

  • General enquiries: Normally for up to 24 months after the enquiry is resolved.

  • Newsletter information: Until you unsubscribe, withdraw consent or the subscription becomes inactive and is removed.

  • Institutional licence and transaction records: For the duration of the relationship and any additional period required for accounting, taxation, contractual or legal purposes.

  • Personal data contained in feedback: Normally for up to 24 months, after which it may be deleted or anonymised.

  • Anonymised or aggregated information: May be retained for research, development and statistical purposes because it no longer identifies an individual.

  • Analytics information: According to our configured retention settings and the applicable provider’s retention controls.

  • Suppression records: For as long as reasonably necessary to honour an unsubscribe or objection.

We may retain information for a longer period where required by law, necessary to resolve a dispute or needed to establish, exercise or defend legal claims.

12. Data Security

We use reasonable technical and organisational measures designed to protect personal data from unauthorised access, disclosure, alteration, misuse, loss or destruction.

These measures may include:

  • Secure HTTPS connections;

  • Restricted access to administrative accounts;

  • Password and account-security controls;

  • Data minimisation;

  • Reputable hosting and service providers;

  • Software and platform updates;

  • Backup and recovery procedures; and

  • Periodic review of the information we retain.

No website, email system or electronic-storage method can be guaranteed to be completely secure. We therefore cannot promise absolute security, but we will respond appropriately if a security incident occurs.

Where required by law, we will notify the relevant authority and affected individuals of a qualifying personal-data breach.

13. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:

  • Be informed about how your personal data is processed;

  • Request access to personal data we hold about you;

  • Request correction of inaccurate or incomplete information;

  • Request deletion of personal data;

  • Withdraw consent;

  • Object to or limit particular processing;

  • Opt out of direct marketing;

  • Request a portable copy of certain information;

  • Ask about parties to whom information has been disclosed; and

  • Submit a complaint to an appropriate data protection authority.

To exercise a right, contact schools@dbsolution.pro with the subject line:

Personal Data Request

Please explain your request clearly. We may ask for reasonable information to verify your identity and protect personal data from unauthorised disclosure.

We will respond within the period required by applicable law. Some rights may be limited where we have a legal obligation or legitimate reason to retain or continue processing particular information.

14. Whether Providing Information Is Mandatory

Providing personal data through the website is generally voluntary.

However, school name, school email address and country are required when requesting a pilot because we need them to verify institutional eligibility and provide the requested materials.

If required information is not supplied, we may be unable to:

  • Verify the institution;

  • Provide the pilot pack;

  • Respond to the request;

  • Establish an institutional licence; or

  • Deliver related support.

Newsletter information is optional and refusing it will not affect pilot eligibility.

15. Children’s and Student Privacy

Dew Bright works with educational institutions, but we do not offer accounts or services directly to children.

We do not knowingly request or collect personal data directly from students through the public website.

Teachers and institutions must not submit identifiable student information unless this has been expressly agreed, is necessary for a clearly defined purpose and is handled in accordance with applicable law and the institution’s own safeguarding and privacy requirements.

If you believe that a child’s personal data has been submitted to us improperly, contact schools@dbsolution.pro so that we can investigate and take appropriate action.

16. Automated Decision-Making

We do not use personal data to make solely automated decisions that produce legal or similarly significant effects on individuals.

Automated tools may be used for routine functions such as country suggestions, spam prevention, email delivery, analytics or form processing.

17. Third-Party Websites and Platforms

Our website may contain links to external services such as LinkedIn, Facebook, Google Forms or other third-party websites.

When you follow an external link, that organisation may collect and process information under its own privacy policy. Dew Bright Solution is not responsible for the privacy practices or content of independent third-party websites.

We encourage you to review their policies before providing personal data.

18. Changes to This Policy

We may update this Privacy Policy when our services, technology, providers or legal obligations change.

The revised version will be published on this page with an updated effective date. Where a change materially affects how we use personal data, we will provide additional notice where reasonably possible or legally required.

19. Contact and Complaints

For privacy questions, requests, concerns or complaints, contact:
Dew Bright Solution
Operated by: Oleh Borysiuk
Hai Phong, Vietnam
Email: schools@dbsolution.pro
Phone: +84 58 638 0109

Please use the email subject:

Privacy Enquiry

We will review your concern and respond as soon as reasonably practicable.

You may also have the right to complain to the data protection or privacy authority responsible for your location.

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