Privacy Policy

1. Introduction

1.1 Who We Are

Spark is an AI-powered platform operated by TriaLabs LLP ("Company", "we", "us", or "our"). We transform teaching recordings into structured learning experiences including courses, study notes, quizzes, and an AI tutor.

1.2 What This Policy Covers

This Privacy Policy describes how we collect, use, store, and protect personal information when you:

• Visit our website at sparknow.ai (when launched) and related domains
• Create a Teacher or Student account
• Upload content or access courses through Spark
• Use our AI services, payment features, or student portal
• Communicate with us or receive our emails

1.3 Acceptance of This Policy

By using Spark, you agree to the practices described in this Privacy Policy and our Terms and Conditions. If you do not agree, please do not use our services.

1.4 Beta Service Notice

Spark is currently in beta/early access. As we develop the platform, our data practices may evolve. We are committed to:

• Transparent communication about how we handle your data
• Building toward full compliance with major privacy regulations (GDPR, FERPA, COPPA) as we grow
• Protecting your data with reasonable security measures appropriate for our stage
• Never using your teaching content to train our AI models

If your use case requires specific compliance certifications (GDPR, FERPA, etc.) right now, please contact us at support@sparktutor.ai before using Spark.

2. Information We Collect

2.1 Information You Provide Directly

From Teachers:

• Account Information: Name, email address, password, profile details
• Payment Information: Billing details, payment processor account connections (Stripe or RazorPay)
• Teaching Content: Videos, audio recordings, documents, images, course titles, descriptions, and metadata you upload
• Course Settings: Pricing, access controls, student permissions, and course structure preferences
• Communications: Messages you send us, support requests, and feedback

From Students:

• Account Information: Name, email address, password, profile details
• Enrollment Data: Courses enrolled, subscription plans, payment information (processed by your teacher's payment processor)
• Learning Activity: Course progress, video watch time, quiz responses, AI tutor interactions, notes, and bookmarks
• Communications: Messages to teachers or support requests

2.2 Information Collected Automatically

When you use Spark, we automatically collect:

• Usage Data: Pages viewed, features used, time spent, clicks, and navigation patterns
• Device Information: Browser type and version, operating system, device type, screen resolution
• Log Data: IP address, access times, referring URLs, error logs
• Cookies and Tracking: Session identifiers, preference cookies, analytics cookies (see Section 10)

2.3 Information from Third Parties

We may receive information from:

• Payment Processors: Stripe or RazorPay may provide transaction status and payment verification
• Video Conferencing: If you connect Zoom or Google Meet, we receive meeting metadata (not recordings unless you explicitly upload them)
• Authentication Services: If you sign in with Google or other providers, we receive basic profile information you authorize

3. How We Use Your Information

3.1 To Provide and Improve Services

We use your information to:

• Process Content: Transcribe audio/video, identify chapters, generate notes and quizzes, power the AI tutor
• Deliver Courses: Host and stream content, manage access controls, track progress
• Enable Payments: Facilitate subscriptions, process payments through Stripe/RazorPay, manage refunds
• Provide Support: Respond to questions, troubleshoot issues, provide technical assistance
• Improve Platform: Analyze usage patterns (in aggregate), identify bugs, develop new features

3.2 For Communications

• Transactional Emails: Account verification, password resets, payment confirmations, subscription updates, course notifications
• Marketing Communications: Product updates, feature announcements, educational content, and promotional offers (teachers only, with opt-out option)
• Support Communications: Responses to your inquiries and support requests

3.3 For Legal and Security Purposes

• Comply with legal obligations and law enforcement requests
• Enforce our Terms and Conditions
• Protect against fraud, abuse, and security threats
• Resolve disputes and investigate violations

4. Our Key Commitment: No Training on Your Content

We do NOT use your uploaded content or student data to train, fine-tune, or improve our AI models or any third-party AI models.

Specifically:

• Your teaching videos, recordings, and documents are processed only to generate content for YOUR courses
• Student quiz responses, tutor conversations, and learning data stay within your course context
• We do not feed your content into training pipelines or allow AI providers to retain it for model improvement
• AI-generated content (notes, quizzes, tutor responses) is derived from YOUR content and remains tied to YOUR courses

We may use aggregate, anonymized data (e.g., "average course completion rate across all teachers") to improve our platform, but this never includes identifiable content or student information.

5. How We Share Your Information

5.1 With Your Students (Teachers Only)

When you create courses as a Teacher:

• Your name, profile, and course materials are visible to enrolled students
• You control what content students can access based on their subscription plans
• Student activity data (progress, quiz scores) is visible to you in your teacher dashboard

5.2 With Service Providers

We share information with trusted third-party service providers who help us operate Spark:

• AI Processing: OpenAI and Google Gemini for transcription, content generation, and tutor responses (under strict data protection agreements that prohibit using your data for training)
• Payment Processing: Stripe and RazorPay to process teacher subscriptions and student payments
• Cloud Hosting: Amazon Web Services (AWS) and Google Cloud for data storage and video hosting (US-based servers)
• Video Delivery: Content delivery networks (CDNs) for fast, secure video streaming
• Email Services: Email delivery providers for transactional and marketing communications
• Analytics: Analytics providers to understand usage patterns (aggregate data only)

All service providers are contractually required to protect your data and use it only for the specific services they provide to us.

5.3 For Legal Reasons

We may disclose information when required by law or when we believe it's necessary to:

• Comply with legal process, court orders, or government requests
• Enforce our Terms and Conditions or investigate potential violations
• Protect the safety, rights, or property of Spark, our users, or others
• Detect, prevent, or address fraud, security, or technical issues

5.4 Business Transfers

If Spark is acquired, merged, or undergoes a business restructuring, your information may be transferred to the new entity. We will notify you via email and/or prominent notice on our website before this happens.

5.5 What We Never Do

We do NOT:

• Sell your personal information to third parties
• Share your teaching content with other teachers or make it publicly available
• Use student data for advertising or marketing purposes
• Provide your data to AI companies for model training

6. Third-Party Services

Spark integrates with third-party services that have their own privacy policies:

• Stripe: stripe.com/privacy
• RazorPay: razorpay.com/privacy
• Zoom: zoom.us/privacy
• Google Meet: policies.google.com/privacy
• OpenAI: openai.com/privacy
• Google Cloud: cloud.google.com/privacy

We are not responsible for the privacy practices of these third parties. We encourage you to review their policies.

7. Data Security

7.1 Security Measures We Take

We implement reasonable security measures to protect your information:

• Encryption of data in transit (HTTPS/TLS) and at rest
• Access controls limiting who can view or modify data
• Regular security assessments and updates
• Secure authentication and password hashing
• Monitoring for suspicious activity and unauthorized access

7.2 Limitations

No system is completely secure. While we strive to protect your data:

• We cannot guarantee absolute security against sophisticated attacks
• You are responsible for keeping your password confidential and reporting unauthorized access
• As a beta service, our security practices are evolving and may not match enterprise-grade standards yet

7.3 Data Breaches

If we discover a data breach that affects your personal information, we will notify you promptly via email and take steps to mitigate harm.

8. Your Rights and Choices

8.1 Access and Correction

You can access and update your account information through your Spark dashboard at any time. If you need assistance, contact us at support@sparktutor.ai.

8.2 Download Your Content

Teachers can export their uploaded content and AI-generated materials. Students can export their course progress and notes. Contact support if you need help with data export.

8.3 Delete Your Account

You can delete your account at any time through account settings. When you delete your account:

• Teachers: Your content will be removed from our active systems. Students may lose access to your courses unless you provide alternative access. You remain responsible for any outstanding student obligations.
• Students: Your learning data will be removed. Your enrollment and payment records may be retained for accounting and legal compliance.
• Backup Retention: Deleted data may remain in backup systems for up to 90 days, then is permanently deleted.

8.4 Marketing Communications

Teachers receive marketing emails about product updates and features. You can opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Adjusting your email preferences in account settings
• Emailing us at support@sparktutor.ai

You will continue to receive transactional emails (account notifications, payment confirmations) even if you opt out of marketing.

8.5 Cookies and Tracking

You can control cookies through your browser settings. Note that disabling cookies may affect your ability to use certain features of Spark. See Section 10 for details.

8.6 Beta Limitations on Rights

As a beta service, we are still building full compliance with data protection regulations. Currently:

• We honor access, correction, and deletion requests manually - response time may be 10-15 business days
• We do not yet have automated tools for data portability in machine-readable formats
• We are working toward implementing full GDPR rights (right to object, right to restrict processing, etc.)

If you need immediate assistance exercising your rights, contact support@sparktutor.ai.

9. Student Data and Teacher Responsibilities

9.1 Teachers Are Data Controllers

If you are a Teacher using Spark to deliver courses:

• You are the data controller for your students' personal information
• Spark is a data processor acting on your behalf to deliver your courses
• You are responsible for obtaining necessary consents from students for collecting and processing their data
• You must comply with applicable education privacy laws (such as FERPA in the US, GDPR in the EU)
• You must have a lawful basis for processing student data (e.g., consent, contract, legitimate interest)

9.2 Teacher Obligations

As a Teacher, you agree to:

• Inform students about data collection and use through your own privacy policy or notice
• Obtain parental consent for students under 18 (or applicable age in your jurisdiction)
• Use student data only for legitimate educational purposes
• Protect student privacy and confidentiality
• Respond to student data rights requests (access, correction, deletion)

9.3 Student Data We Process on Behalf of Teachers

When processing student data as a data processor, we:

• Process student data only as instructed by the Teacher
• Do not use student data for our own purposes (except as necessary to provide the service)
• Implement appropriate security measures
• Assist Teachers in responding to student data requests
• Delete or return student data when requested by the Teacher (subject to legal retention requirements)

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit Spark. We use cookies and similar technologies (web beacons, local storage) to enhance your experience.

10.2 Types of Cookies We Use

• Essential Cookies: Required for Spark to function (authentication, security, load balancing). You cannot opt out of these.
• Functional Cookies: Remember your preferences (language, video quality, dashboard layout)
• Analytics Cookies: Help us understand how you use Spark (pages viewed, features used, errors encountered). We use aggregate data only.
• Marketing Cookies: Track effectiveness of our marketing campaigns (for teachers only)

10.3 Managing Cookies

You can control cookies through your browser settings:

• Most browsers allow you to view, delete, and block cookies
• Blocking essential cookies will prevent you from using Spark
• Blocking functional and analytics cookies may degrade your experience

Learn more about cookies: allaboutcookies.org

11. International Data Transfers

Spark is operated from the United States, and your data is hosted on US-based servers (AWS and Google Cloud US regions).

If you use Spark from outside the United States:

• Your information will be transferred to, stored, and processed in the US
• The US may have different data protection laws than your country
• We take reasonable steps to protect your data regardless of where it is processed
• By using Spark, you consent to this transfer

We are working toward implementing appropriate safeguards for international transfers (Standard Contractual Clauses, etc.) as we grow.

12. Children's Privacy

12.1 Age Restrictions

Spark is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

• If you are under 13, you may not use Spark under any circumstances
• If you are between 13 and 18, you must have verifiable parental or legal guardian consent
• Teachers who enroll students under 13 are responsible for obtaining parental consent and complying with COPPA

12.2 If We Discover Child Data

If we learn that we have collected information from a child under 13 without proper consent, we will delete that information as quickly as possible. If you believe a child under 13 has provided information to us, contact support@sparktutor.ai immediately.

13. Data Retention

We retain your information for as long as necessary to provide services and fulfill the purposes described in this policy:

• Active Accounts: We retain your data while your account is active
• Deleted Accounts: After account deletion, data is removed from active systems and remains in backups for up to 90 days
• Legal Compliance: We may retain certain information longer when required by law (e.g., financial records for tax purposes)
• Legitimate Interests: We may retain aggregate, anonymized data indefinitely for analytics and platform improvement

As an early-stage service, we do not yet have detailed retention schedules for every data type. We will develop more specific policies as we grow.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service features.

When we make changes:

• We will update the "Last updated" date at the top of this page
• For material changes, we will notify you via email or prominent notice on the Platform
• We will give you an opportunity to review the new policy before it takes effect
• Continued use of Spark after changes indicates your acceptance of the updated policy

We encourage you to review this policy periodically to stay informed about how we protect your information.

15. Your Privacy Rights by Region

15.1 For California Residents (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request details about what personal information we collect, use, and share
• Right to Delete: Request deletion of your personal information (with certain exceptions)
• Right to Opt-Out: We do not sell personal information, so no opt-out is needed
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact support@sparktutor.ai.

15.2 For European Residents (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

• Right of Access: Obtain a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

Important Beta Limitation: We are working toward full GDPR compliance but do not yet implement all GDPR requirements. If you need GDPR-compliant data processing, please contact us before using Spark.

To exercise these rights or lodge a complaint with a supervisory authority, contact support@sparktutor.ai.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:

TriaLabs LLP
Email: support@sparktutor.ai
Website: sparknow.ai (when launched)

For privacy-related inquiries, data protection questions, or legal notices, use the email address above. We will respond to your request within a reasonable timeframe, typically 10-15 business days.