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Last Updated: March 5, 2026

Sparkade Privacy Policy

This Privacy Policy explains how Sparkade, an educational game-based learning platform owned and operated by Spark Launch Inc., collects, uses, and protects information relating to children, parents or legal guardians, educators, and schools. The Policy is designed to be clear, family-centered, and aligned with widely recognized data protection and children’s privacy standards.

Sparkade is built on the principles of data minimization and privacy-by-design. We collect only the information reasonably necessary to provide a safe, supportive, and effective learning experience. Sparkade does not display advertisements, does not engage in behavioral or targeted advertising, and does not sell personal information. Children’s data is handled with heightened care and default privacy protections.

 

About This Policy and Who We Are

This Privacy Policy applies to Sparkade’s websites, applications, and related services (collectively, the “Service”). It does not apply to third-party websites, tools, or services that are not owned or controlled by Spark Launch Inc., even if they are accessed through links within Sparkade.

Sparkade is an educational platform intended to support learning, engagement, and skill development. It is not designed or intended to diagnose, treat, or provide medical, psychological, or clinical assessments, and it should not be used as a substitute for professional advice or services.

Sparkade is designed to align with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA) and other applicable children’s privacy frameworks. We implement privacy-by-design principles and age-appropriate safeguards consistent with those standards.

Depending on the context in which Sparkade is used, Spark Launch Inc. may determine the purposes and means of processing personal data for account management and platform operations, or may process data on behalf of schools under written agreements and documented instructions. These roles are reflected in our contractual arrangements, internal controls, and data protection practices.

Where required by applicable data protection frameworks, Spark Launch Inc. will designate appropriate representatives or officers responsible for data protection oversight and will make relevant contact information available through this Policy or within the Service.

For questions or requests relating to privacy or children’s data, you may contact:

Email: privacy@sparklaunch.ai  

Sparkade is owned and operated by Spark Launch Inc., a Delaware corporation, with its principal place of business at:

8, The Green STE A, Dover, DE 19901  

COPPA Operator Disclosure

For purposes of the Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506), the operator of the Service is:

Spark Launch Inc.

8, The Green STE A, Dover, DE 19901  

Email: privacy@sparklaunch.ai

 

Who Uses Sparkade and How Consent Works

Sparkade may be used by children, parents or legal guardians, educators, and schools. We recognize the additional responsibility involved in providing digital services for children and educational environments, and Sparkade is designed with the expectation that adults may supervise, manage, or administer children’s access and data.

Children’s participation in Sparkade is not conditioned on providing more personal information than is reasonably necessary for the learning experience. Where consent is required, Sparkade implements age-appropriate and context-appropriate mechanisms to obtain Verifiable Parental Consent (VPC) from a parent or legal guardian, or authorization from an educational institution where permitted by law, before personal information from a child is collected, used, or disclosed, in accordance with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA).

Sparkade is structured so that personal data collected from children is limited to what is necessary to deliver the Service, maintain safety and security, and provide meaningful learning insights to parents and educators. Different processing activities rely on appropriate and lawful bases, such as delivering the Service, ensuring platform integrity, meeting legal obligations, or relying on valid consent where required.

 

School and Classroom Use 

When Sparkade is used in school-managed or classroom settings, student information is processed solely for educational purposes and in accordance with the instructions and authority of the school. Educators are provided access to learning progress and performance insights, not sensitive or unnecessary personal information.

Spark Launch Inc. supports recognized educational data protection principles through contractual commitments, operational safeguards, and restricted data use. Student data is not sold, rented, or used for advertising or commercial profiling, and is handled in a manner consistent with the expectations placed on education service providers.

When Sparkade is provided to a school under a written agreement, Spark Launch Inc. acts as a “school official” with a legitimate educational interest, as that term is commonly understood under the U.S. Family Educational Rights and Privacy Act (FERPA), and processes student information solely for the purposes authorized by the educational institution.

 

Information we collect and what we do not collect​

Sparkade collects information in a limited, education-focused way. Under the COPPA Rule, “personal information” includes items such as online contact information, persistent identifiers (including cookies and IP addresses), photos/audio containing a child’s image or voice, precise geolocation sufficient to identify street and city, and biometric identifiers.  This section describes what Sparkade may collect and what Sparkade intentionally does not collect.

Information provided by parents/guardians (family-managed accounts): When a parent or legal guardian creates or manages an account, we may collect the parent/guardian’s email address, first name, last name, and account login credentials, along with account preferences and settings needed to operate the Service. We may also collect a child’s age or age range (we aim to avoid collecting full dates of birth) so we can apply appropriate child safeguards and age appropriate experiences.

Information provided by schools/educators (school-managed accounts): Where Sparkade is deployed in a classroom or school-managed environment, we may collect educator contact details and school/classroom association details necessary to administer accounts, assign learning content, and provide progress reporting to authorized educators. Where a school provides student roster or identifiers, we encourage the use of minimal consistent with school policy and applicable law.

Information collected during use (learning and gameplay): Sparkade collects learning-related data produced by gameplay and engagement, such as progress, performance, in-game responses, session duration, and interaction patterns. This data exists to personalize learning content, evaluate learning effectiveness, and provide insights to parents/educators. These data are treated as personal data where they relate to an identified or identifiable user under GDPR, and they may be treated as children’s personal information under COPPA when associated with a child account. 

Device, log, and technical data: Like most online services, Sparkade may collect device and technical information necessary to operate the Service reliably and securely, such as IP address and device or browser identifiers. Under COPPA, persistent identifiers can include an IP address, a cookie-based customer number, or a unique device identifier.  Under GDPR, device identifiers and online identifiers can be personal data when they can be linked to a user. Sparkade does not store IP addresses in persistent user profiles and does not use IP addresses for tracking or profiling purposes.

Voice and audio input: Sparkade may offer voice-based interactions with an AI companion. Voice/audio files that contain a child’s voice are explicitly included in COPPA’s definition of personal information.  Sparkade’s intended design is to process voice input only to enable the requested interaction and to avoid storing voice recordings by default; additional safeguards and options are described in the “How we use information and lawful bases” section.

Information we do not collect: Sparkade is designed to avoid collecting sensitive data categories. In particular, Sparkade does not intend to collect precise geolocation information sufficient to identify street name and city/town; we do not require children to provide photos or videos; we do not require social media account information; and we do not ask for medical, psychological, or diagnostic records. 

COPPA’s definition of personal information includes precise geolocation sufficient to identify street and city and biometric identifiers such as voiceprints; Sparkade’s design intent is to avoid collecting these categories as part of normal operation.  GDPR also restricts the processing of special categories of personal data (such as health data and biometric data used for unique identification) unless a specific exception applies; Sparkade’s design intent is to avoid such processing. 

 

How We Use Information

Sparkade uses information solely to operate, maintain, and improve the educational experience, to ensure the safety and integrity of the platform, and to support parents, guardians, educators, and schools. All processing is limited to what is reasonably necessary for these purposes and is carried out in accordance with principles of data minimization, proportionality, and purpose limitation.

Information collected through Sparkade is never used for advertising, commercial profiling, or non-educational monetization.

 

Educational Service Delivery and Personalisation

Sparkade uses learning activity and gameplay data to deliver core educational functionality. This includes adapting learning paths, adjusting difficulty levels, recommending appropriate content, and presenting progress insights to authorized adults and educators. These uses are intrinsic to providing the Service and supporting meaningful learning outcomes. Personalization is designed to enhance engagement and understanding without labelling, categorizing, or making determinations about a child beyond the immediate educational context.

Safety, Security, and Platform Integrity

Information such as technical data, usage logs, and system signals may be used to secure accounts, prevent misuse, detect and investigate harmful activity, respond to incidents, and maintain the reliability and integrity of the Service. Sparkade applies technical and organizational safeguards appropriate to the sensitivity of the information and the nature of the platform, particularly where children are involved.

Spark Launch Inc. maintains administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, role-based access controls, system monitoring, and documented incident response procedures. These safeguards are periodically reviewed and updated as appropriate.

Communications and Support

Sparkade may use contact information provided by parents, guardians, educators, or schools to send service-related communications. These communications may include account verification messages, security alerts, updates about features or functionality, responses to support requests, and notices required for the operation of the Service. Sparkade does not send promotional or advertising communications to children.

No Advertising or Behavioral Profiling

Sparkade does not display advertisements and does not use personal information for behavioral advertising, marketing, or commercial profiling. Information collected through the Service is not used to track users across unrelated services or to build profiles for marketing purposes.

Cookies, Local Storage, and Limited Analytics

Sparkade does not use third-party analytics tools such as Google Analytics. Analytics and system performance monitoring are conducted internally using AWS infrastructure. We may collect device information such as device make, model, operating system, and operating system version to ensure compatibility, security, and performance. Users are authenticated and tracked within the platform using a unique internal user identifier for security, analytics, and personalization purposes.

AI-Supported Features and Safeguards

Sparkade includes guided AI-supported features designed to enhance engagement and learning. These features are constrained to educational support and are subject to safety filtering, age-appropriate controls, and oversight. AI systems within Sparkade are not designed to provide medical, clinical, or diagnostic advice, and they are not used to make decisions that have legal or similarly significant effects on a child. Sparkade does not use AI to identify, label, or profile children beyond immediate learning interactions.

Sparkade may integrate with external artificial intelligence or machine learning service providers through secure third-party APIs to support guided educational interactions. Data shared with such providers is limited to what is necessary to provide the requested functionality and is subject to contractual and technical safeguards.

Sparkade does not use children’s personal information to train general-purpose AI models. AI-supported features operate in-session and do not retain conversational content beyond what is operationally necessary.

Voice Processing (If enabled)

If voice interaction features are enabled, Sparkade may process audio input solely to provide the requested functionality, such as converting speech to text and generating in-platform responses. Voice input is processed only as necessary and is not retained by default. Where limited retention is required for safety, security, or user-requested functionality, such data is protected with appropriate safeguards and retained only for as long as reasonably necessary.

Internal Risk Assessment and Review

For features or processing activities that involve children’s data at scale, novel functionality, or expanded use of automated systems, Spark Launch Inc. conducts internal assessments to evaluate privacy and safety risks prior to deployment or material changes. These assessments inform design decisions, safeguards, and operational controls.

 

Sharing, Service Providers, and Transfers

Sparkade does not sell personal information or use it for behavioral or targeted advertising purposes. Information is shared only in limited circumstances and solely to support the operation of the Service, subject to appropriate protections.

Sharing with Parents, Guardians, and Educators: Sparkade is designed to share learning progress, performance insights, and relevant account information with authorized adults responsible for a child’s learning environment. In family-managed accounts, this typically includes the parent or legal guardian. In school-managed accounts, this includes authorized educators and administrators, consistent with institutional policies and contractual arrangements.

Service Providers: Sparkade may engage trusted service providers to support essential operations such as secure hosting, infrastructure, customer support, and limited analytics related to system performance. Sparkade uses Amazon Web Services (AWS) for cloud hosting and infrastructure. AWS processes data solely to provide hosting and infrastructure services in accordance with contractual data protection obligations. These providers are permitted to access information only as necessary to perform their services and are contractually required to protect confidentiality, security, and integrity, and to use the information solely for Sparkade related purposes.

Sub-Processors: Some service providers may rely on additional sub-processors to deliver infrastructure or support services. Spark Launch Inc. applies oversight and contractual controls to ensure that any such sub-processing is subject to equivalent data protection and security obligations. Information about sub-processors may be made available to schools or other authorized parties upon request.

Legal and Regulatory Disclosures: Sparkade may disclose information where required to comply with applicable law, legal process, or lawful requests from public authorities. Such disclosures are limited to what is reasonably necessary, and Spark Launch Inc. seeks to protect user privacy and challenge overbroad requests where permitted.

Business Transactions: If Spark Launch Inc. undergoes a merger, acquisition, restructuring, or sale of assets, information may be transferred as part of that transaction. Any such transfer will be subject to continued protection of personal information consistent with this Privacy Policy.

Cross-Border Processing: Spark Launch Inc. and its service providers may process information in locations necessary to operate and support the Service. Where information is transferred across borders, Spark Launch Inc. applies safeguards designed to ensure that personal data remains protected in accordance with this Policy and applicable data protection standards. For users located in the United Kingdom, data may be processed in the United States, including AWS data centers located in North Virginia (US East 1). Such transfers are protected through encryption in transit and at rest, along with contractual and technical safeguards.

Where personal data originating from the United Kingdom or European Economic Area is transferred outside those regions, Spark Launch Inc. implements appropriate safeguards, which may include standard contractual clauses, technical security measures, and access controls designed to maintain an equivalent level of protection.

 

Retention and Deletion of Information

Sparkade retains personal information only for as long as it is reasonably necessary to provide the Service, support learning outcomes, maintain safety and security, and meet legal or contractual obligations. Retention periods are determined based on the nature of the information, the purpose for which it was collected, and operational requirements.

Operational technical metadata may be retained for up to 90 days for security, integrity, and performance monitoring purposes, unless a longer period is required for legal or safety reasons.

When information is no longer needed, Sparkade takes reasonable steps to delete or de-identify it. Deletion means removing information from active systems so that it is no longer accessible in the normal course of operations.

Like many digital services, Sparkade may maintain encrypted backups for business continuity and disaster recovery.

Information that has been deleted from active systems may persist in backups until those backups are overwritten or rotated out. Access to backups is restricted, and deleted information is not restored except where necessary to recover systems.

 

Rights and Requests

Parents, guardians, educators, and schools may have rights to access, correct, or request deletion of personal information associated with their accounts or with a child’s use of Sparkade. Requests may also include questions about how information is handled or concerns about privacy practices.

To protect children and families, Spark Launch Inc. verifies that a requester is authorized before fulfilling access, correction, or deletion requests. Verification methods are designed to confirm authority while avoiding unnecessary or intrusive data collection.

Requests may be submitted by contacting Email: privacy@sparklaunch.ai

We respond to requests within a reasonable timeframe and may request additional information as needed to confirm identity or authority.

Where Sparkade is used through a school or educational institution, Spark Launch Inc. processes student information in accordance with the school’s instructions and applicable contractual terms. Schools may request access to, correcting, or deletion of student information consistent with their agreements and internal policies.

Spark Launch Inc. supports institutional requirements through written agreements that define permitted data use, security obligations, restrictions on onward disclosure, and deletion or return of information when services end.

 

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, features, or operational requirements. The “Last Updated” date at the top of the Policy indicates when it was most recently revised.

If changes materially affect how children’s information is collected, used, or protected, we will provide appropriate notice and, where required, seek renewed authorization before applying those changes.

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