Privacy Policy
Last updated: December 10, 2024
1. Introduction
Sparkaly, operated by Avanzado Technologies LLC ("we," "us," or "our"), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our adaptive learning platform.
2. Information We Collect
Personal Information
- Name and email address
- Account credentials (encrypted)
- Profile information (grade level, learning preferences)
- Parent/guardian contact information (for minors)
Learning Data
- Chat conversations with AI tutor
- Quiz responses and scores
- Learning progress and achievements
- Uploaded study materials
Technical Data
- IP address and device information
- Browser type and version
- Usage patterns and session data
- Cookies and similar technologies
3. How We Use Your Information
We use collected information to:
- Provide personalized learning experiences
- Improve our AI tutoring capabilities
- Track and report learning progress
- Ensure platform safety and security
- Communicate important updates
- Comply with legal obligations
- Analyze usage to improve the Service
4. Data Protection for Children (COPPA)
We comply with the Children's Online Privacy Protection Act (COPPA):
- We require verified parental consent for users under 13
- Parents can review, modify, or delete their child's data
- We collect only information necessary for educational purposes
- We do not display targeted advertising to children
- Child accounts have enhanced safety features
5. Educational Privacy (FERPA)
For educational institution users, we comply with FERPA requirements:
- We act as a "school official" under institutional agreements
- Educational records are protected and controlled by institutions
- We do not use student data for non-educational purposes
- Parents and eligible students may access their records
6. Data Security
We implement robust security measures including:
- AES-256 encryption for personal data at rest
- TLS 1.2+ for data in transit
- AWS infrastructure with SOC 2 compliance
- Regular security audits and penetration testing
- Employee access controls and training
- Incident response procedures
7. Data Sharing
We may share information with:
- Service Providers: AWS, Cognito (authentication), for platform operation
- Educational Institutions: As directed by school agreements
- Parents/Guardians: For linked child accounts
- Legal Requirements: When required by law or to protect safety
We do NOT sell personal information to third parties.
8. Your Rights
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate information
- Deletion: Request deletion of your data ("right to be forgotten")
- Portability: Export your data in a standard format
- Opt-out: Unsubscribe from marketing communications
- Restrict Processing: Limit how we use your data
To exercise these rights, contact us at privacy@sparkaly.com
9. Data Retention
We retain data according to these guidelines:
- Active Accounts: Data retained while account is active
- Inactive Accounts: Deleted after 24 months of inactivity
- Deleted Accounts: Data removed within 30 days
- Backup Data: Removed within 90 days of deletion
- Educational Records (FERPA): Retained for 7 years to comply with federal requirements
- Audit Logs: Retained for 7 years for compliance and security purposes
- Legal Requirements: Some data may be retained longer if required by law
10. Cookies and Tracking
We use cookies for:
- Essential: Authentication and security
- Preferences: Theme and language settings
- Analytics: Understanding usage patterns
You can control cookies through your browser settings. Disabling essential cookies may affect functionality.
11. International Data Transfers
Our services are hosted in the United States. If you access the Service from outside the US, your data will be transferred to and processed in the US. We implement appropriate safeguards for international transfers.
12. California Privacy Rights (CCPA)
California residents have additional rights:
- Right to know what personal information is collected
- Right to delete personal information
- Right to opt-out of sale (we do not sell data)
- Right to non-discrimination for exercising rights
13. Changes to This Policy
We may update this Privacy Policy periodically. We will notify you of material changes via email or in-app notification at least 30 days before changes take effect. The "Last updated" date at the top indicates when revisions were made.
14. Contact Us
For privacy questions or concerns:
Email: privacy@sparkaly.com
Phone: 1-844-466-0284
Avanzado Technologies LLC
Attn: Privacy Officer
515 N Flagler Dr
West Palm Beach, FL 33401
United States