Privacy Policy

Who we are

SparkBrain is a family app for chores, tasks, homeschooling lists, points and rewards, a family calendar and a reading log. It is operated by SparkBrain Labs, Inc., based in the USA ("SparkBrain", "we", "us").

We are the controller of the personal information described here. The person in charge of the protection of personal information is our Privacy Officer, reachable at privacy@sparkbrain.net.

This policy explains what we collect, why, who we share it with, how long we keep it and the rights you have. Our Children's Privacy Notice explains the same for children's information in plain words.

The short version

• A parent creates the account. Children never sign up and never give us information themselves — a parent sets up each child's profile and hands the device over.
• We collect only what the app needs to work for your family.
• We never sell personal information, show advertising, share data for advertising, build profiles of children or use your family's data to train artificial intelligence.
• You can see, download, correct and delete your family's information at any time in Settings, or by writing to privacy@sparkbrain.net.

What we collect

About you (the parent or guardian):

• your name, sign-in email and contact email;
• your date of birth and country (to confirm you are an adult where you live), and, if you choose, your province or state (for public holidays);
• your time zone and language;
• your password (stored only as a secure hash) or, if you sign in with Google, Apple or Microsoft, the identifier that service gives us;
• your two-factor settings, if you turn two-factor authentication on;
• your subscription and invoices (your card details are handled by our payment provider, Stripe — we never see or store them);
• the messages you send to our support team;
• the record of the consent you gave for each child.

About your children (entered by you):

• first name, year of birth and, if you choose to add them, last name, nickname, grade, gender and school name;
• what your family does in the app: activity lists and their check-offs and approvals, points and rewards, the reading log (books, minutes, ratings) and calendar events.

We do not collect a child's address, phone number, email, precise location or contacts. A child's photo is collected only with photo proof: when a parent has given the separate photo consent and chosen a task that asks for one, the child sends a photo of the finished task (redrawn smaller on the device, its hidden camera data such as location removed). Only the family's parents can see it, and it is deleted once reviewed, after 7 days at most — see our Children's Privacy Notice.

Technical information:

• cookies that keep you signed in and remember your language (see "Cookies and similar storage");
• a security log of sign-ins and changes, with your browser type and a shortened IP address;
• error reports when something breaks, with browser, device type and the page — never names, emails, account identifiers or full IP addresses;
• usage statistics (which features are used, how often), recorded without any account identifier.

Why we use it

• To provide the app — your account, your family's lists, points, calendar and reading log, reminders and notifications. Legal basis (where one is required): performance of our contract with you.
• To get consent for and protect children — verifying you are an adult and recording your consent before a child profile is created. Legal obligation; consent.
• To bill you — subscriptions, invoices, receipts. Contract; legal obligation (tax).
• To keep the service safe — preventing abuse, securing accounts, investigating incidents. Legitimate interests; legal obligation.
• To support you — answering your messages. Contract; legitimate interests.
• To improve the app — understanding which features are used and fixing errors, without identifying anyone. Legitimate interests.
• To send you service emails — sign-in and security codes, receipts, reminders you turned on, and important changes. We do not send marketing email unless you ask for it.

We do not use automated decision-making that has legal or similarly significant effects on you or your children.

Who we share it with

We share personal information only with service providers that process it for us, under contracts that require them to protect it and to use it only to provide their service to us:

We may also disclose information if the law requires it, to protect the safety of a child or anyone else, or to a successor if SparkBrain is reorganised or sold — in which case this policy will continue to protect your information and we will tell you first.

We do not disclose children's information to any third party for any purpose other than running the app. We do not sell or "share" personal information as those terms are used in US state privacy laws.

International transfers

During the beta we host the app and its databases in [HOSTING REGION], in the Americas, close to our families in Canada, the United States and Brazil. Files you upload (such as book covers and proof photos) are stored by Cloudflare in the European Union, and email is sent through Resend's EU region. Some providers above process information in other countries, including the United States. Where the law requires it, we rely on safeguards such as the European Commission's Standard Contractual Clauses, we assess transfers of personal information outside Québec as Québec law requires, and we follow Brazil's rules for international transfers. When we open in Europe, European families' information will be hosted in the European Union.

How long we keep it

How we protect it

Encryption in transit; passwords stored only as secure hashes; two-factor authentication (required for our staff); access limited to the people who need it; the app's database account cannot change or delete the consent and audit records; regular backups; and a record of any security incident. If an incident puts your information at risk, we will tell you and the authorities as the law requires.

Your rights

Wherever you live, you can ask us to:

• see the information we hold about you and your children, and get a copy (Settings → Security → Download my data gives you a file straight away);
• correct it (most of it you can edit yourself);
• delete it (Settings → Security → Delete my account, or remove a single child's profile);
• withdraw consent for a child at any time (the child's profile is then suspended);
• stop any processing you object to, and ask how a decision about you was made.

Write to privacy@sparkbrain.net. We answer within 30 days (sooner where the law requires) and may need to confirm your identity first. We will not treat you differently for using your rights.

Additional rights where you live:

• United States — residents of California and other states with privacy laws have the rights to know, delete and correct, and to opt out of sale, sharing and targeted advertising; we do none of those. You may use an authorised agent. If we refuse a request, you can appeal by replying to our answer.
• Canada — you may also complain to the Office of the Privacy Commissioner of Canada, or, in Québec, to the Commission d'accès à l'information. The French version of this policy is available in the app.
• Brazil — you have the rights in article 18 of the LGPD, including confirmation of processing, anonymisation, portability and information about sharing; you may complain to the Autoridade Nacional de Proteção de Dados (ANPD).
• European Union, United Kingdom — you have the rights to access, rectification, erasure, restriction, portability and objection, and you may complain to your data protection authority.

Children

SparkBrain is used by children only through an account their parent controls. We ask for verifiable consent from the parent before a child's profile is created, collect only what the app needs, and never use a child's information for advertising or profiling. The Children's Privacy Notice has the details, including how to review or delete your child's information.

Cookies and similar storage

We use only what the app needs to work:

We use no advertising or analytics cookies and no third-party trackers, so there is nothing to opt in or out of.

Credits

Public holiday data: © the date-holidays contributors, licensed under CC BY 3.0.

Changes to this policy

When we change this policy, we update the date and version above. If a change is significant, we tell you by email and in the app before it takes effect, and we ask for your consent again where the law requires it.

Contact

• Privacy questions and requests: privacy@sparkbrain.net
• Security reports: security@sparkbrain.net
• Everything else: contact@sparkbrain.net or our support page

SparkBrain Labs, Inc., USA.