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SPARK Privacy Policy

Effective October 30, 2026Version 2026.10.3
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Explains how we measure which posts, ads, creators, and partners bring people to SPARK: Google Analytics on our public website pages (advertising features off) and a campaign cookie saved with new free accounts. Adds HubSpot for organization inquiries.

SPARK Privacy Policy

Effective October 30, 2026

Vantage Point Consulting, Inc. ("Vantage Point," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, share, and protect personal information when you use the SPARK adaptive learning platform, including the SPARK website at sparkcourses.org, the SPARK web application, and the SPARK mobile applications (together, "SPARK").

You can use SPARK with a free individual account you create yourself, or through an organization that has an agreement with us, such as an employer, school, training program, or government agency (an "Organization"). Where an Organization's agreement with us governs how its learners' information is handled, we follow that agreement in addition to this Policy.

This Policy is part of the SPARK [Terms of Service](/policy/tos).

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1. Information we collect

Information you provide. When you create an account and use SPARK, we collect:

  • Your name and email address;
  • Your date of birth or age when you sign up, used only to confirm you meet SPARK's minimum age (13 for the Free Plan, or your Organization's minimum if it is higher) and to place you in an age group (13 to 17, or 18 and older). We do not store your date of birth. We keep only that you passed the age check and your age group (see Section 6);
  • Your learning goals, preferences, and accessibility settings;
  • Test scores you choose to report, such as ASVAB scores, to help estimate your readiness; and
  • If you joined through an Organization, the profile details that Organization asks for. For military programs this can include your branch of service, component, and installation.

Free individual accounts are not asked for military or employment information unless you choose to provide it.

Information generated as you learn. We collect information about your activity, such as course and screen progress, assessment and practice results, time on task, goal and module selections, certificates earned, notes, and your conversations with the SPARK AI learning assistant.

Technical and usage information. We collect device and usage data such as device type and identifiers, app version, browser type, language, general (not precise) location derived from IP address, log and diagnostic data, and information collected through cookies and similar technologies. On SPARK's public website pages and the SPARK Free sign-up pages (the pages you see before you sign in), we also use Google Analytics and a SPARK campaign cookie to see which of our posts, ads, creators, and partners bring people to SPARK. If you create a free account, we save that campaign information (such as "a SPARK TikTok post") with it; it says nothing about who you are. See our [Cookie Notice](/policy/cookie-notice).

We do not ask for more sensitive information than we need to run SPARK.

Mobile app. When you use the SPARK mobile app, and only with the device permissions you grant, we also collect:

  • Push notification identifiers from Apple (APNs) or Google (FCM), so we can send reminders. You can turn notifications off in your device settings.
  • On-device data. To support offline use, SPARK stores course content and your progress on your device. It is removed when you delete the app or your account.
  • Crash reports through Google Firebase Crashlytics. These reports describe the error and your device and app version; they do not include your name or email.
  • Voice and photos, if you use them. If you choose to talk to the AI learning assistant, the app uses your microphone and sends the audio to Amazon Transcribe to convert it to text. The app does not keep a copy of your voice. The assistant's spoken replies are kept for up to 30 days so you can replay them. If you choose to share a photo with the assistant, the app uses your camera or photo library and uploads that image to our secure storage, linked to your session. Photos are deleted after 30 days.

Voice and photos on the website. The same voice and photo features are available on the SPARK website. On the website, we also keep a copy of what you say to the assistant, along with its spoken replies, for up to 30 days so you can replay the conversation. Photos are deleted after 30 days. The text of your conversation is kept as part of your assistant history.

Live tutoring (Organization plans only, website only). Where your Organization includes live tutoring, you can schedule one-on-one sessions with a human tutor, hosted through our video provider, Zoom. The mobile app cannot join a live session.

  • Scheduling. We give Zoom your email address and first name to set up the session.
  • During the session. You join as your first name and last initial (for example, "Sam L."). Zoom processes your audio, video, and in-session chat so you and your tutor can meet.
  • Optional recording. A session is recorded only if recording is on for that session and only after you agree before joining. The recording is used only to create a written transcript. It is moved to deletion in Zoom as soon as the transcript is made and is fully deleted within 30 days; we do not keep the recording. We keep the transcript in SPARK and delete it automatically 30 days after the session.
  • AI session notes. We use our AI provider to write a recap of the session from the transcript and save it to your notes. It stays until you delete it.

Support. When you contact support by email, through the in-app feedback form, or, on Organization plans, by phone, we collect what you send us and your contact details, and we keep a record of your request so we can help you and track the issue. For calls, our phone-line provider makes a transcript of the call, and we receive the transcript, your name and your callback number. We keep a summary and transcript of the call as part of the support record, with phone numbers removed. Your callback number, and the provider's copy of the call, are deleted within 90 days.

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2. How we use information

We use information to:

  • Deliver adaptive learning: personalize your learning path, recommendations, and AI assistance based on your goals and activity;
  • Run your account: create and maintain your account, save progress, issue certificates, confirm your age, and turn on the extra protections for learners 13 to 17 described in Section 6;
  • Support your Organization's program, if you joined through one: show your progress and readiness to the counselors and administrators your Organization authorizes, and produce the reports your Organization's agreement requires;
  • Communicate with you: send reminders, announcements, and policy updates through the channels you turn on;
  • Help you when you contact support or our team about SPARK for your organization;
  • Understand how people find SPARK: measure which of our posts, ads, creators, and partners bring visitors to our public website and lead to free sign-ups and organization inquiries, using campaign tags and website analytics with Google's advertising features turned off;
  • Measure and improve SPARK using aggregated, de-identified statistics, such as how many people sign up and keep learning;
  • Keep SPARK secure: detect and respond to fraud, abuse, security incidents, and technical problems; and
  • Meet legal and contractual obligations.

AI features. SPARK uses AI for adaptive recommendations, the AI learning assistant, voice transcription, and session notes, and to help create course content. AI features use your profile, activity, and conversation data to personalize guidance. We may use this data to improve SPARK's own features. We do not use your learning activity or conversations to train AI models that other organizations use, and we do not allow our AI providers to use your data to train their general-purpose models. SPARK personalizes learning by profiling your activity; it does not make decisions with legal or similarly significant effects about you solely by automated means. Where the GDPR applies, you may object to processing based on our legitimate interests.

The AI learning assistant is a study helper, not a counselor, therapist, or doctor. If a learner of any age writes something that suggests they are in distress or thinking about harming themselves, the assistant points them to the 988 Suicide and Crisis Lifeline (call or text 988 in the United States). SPARK staff do not monitor conversations as they happen, and the assistant does not contact anyone on a learner's behalf. If you or someone you know is in immediate danger, call 911.

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3. What we do not do

  • We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
  • We do not show third-party advertising in SPARK.
  • We do not use your learning activity to train AI models that other organizations use.
  • We do not use military service information, if you provide it, to market or recruit you.
  • We do not give any learner's information to military recruiters, the military services, or anyone else for recruiting or marketing.
  • We do not send text messages (SMS) to learners.

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Where laws such as the EU or UK General Data Protection Regulation ("GDPR") apply, we rely on: performance of a contract (to provide SPARK to you or your Organization); consent (for example, certain cookies, optional communications, voice and photo features, and tutoring recordings); legitimate interests (such as security, abuse prevention, and improving SPARK, balanced against your rights); and legal obligation. You may withdraw consent at any time; this does not affect processing that already happened.

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5. How we share information

We share personal information only as described here:

  • With your Organization, if you joined through one. We share your progress, readiness, completion, and related information with your Organization and the counselors and administrators it authorizes, as its agreement and settings provide. Free individual accounts are not shared with any Organization.
  • With service providers (subprocessors) that host and operate SPARK for us. They act only on our instructions, are bound by confidentiality and data-protection obligations, and may use your information only to provide services to us. Our principal subprocessors are:

    • - Amazon Web Services (AWS): cloud hosting and storage in the United States; sign-in; email delivery; push notifications; speech-to-text (Amazon Transcribe) and text-to-speech (Amazon Polly); and the AI processing behind adaptive features, the AI learning assistant, and tutoring session notes; - Zoom Video Communications, Inc.: live one-on-one tutoring sessions, and, only with your consent, the temporary recording used to make a transcript; - Apple Inc.: push notifications to Apple devices; - Google LLC (Firebase): push notifications to Android devices and crash reports; - Google LLC (Google Analytics): measures visits and actions on SPARK's public website pages and sign-up pages, with advertising features, Google signals, and ad personalization turned off. It is not used inside SPARK after you sign in; - Atlassian: support ticket tracking for feedback, help requests, support email, and tutoring requests; - Slack Technologies, LLC: internal notifications that let our team see and respond to support requests and contact-form inquiries; - HubSpot, Inc.: records the inquiries organizations send through our website contact form, so our team can follow up; - Retell AI, Inc.: the support phone line on Organization plans, including call handling and transcription, with telephony through its carrier partners.

Where an Organization's agreement requires it, we notify the Organization of subprocessor changes.

  • For legal and safety reasons, when we believe in good faith it is necessary to comply with law or legal process, enforce our Terms, or protect the rights, safety, or security of users, the public, or Vantage Point.
  • In a business transfer, such as a merger, acquisition, or sale of assets, subject to this Policy.

We do not share personal information with third parties for their own marketing.

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6. Age requirement, teens, and parents

Minimum age. You must be at least 13 years old to use SPARK. An Organization may set a higher minimum age for its own learners, and some Organizations allow only adults.

Children under 13. SPARK is not directed to children under 13, and we do not knowingly collect personal information from them. If the age you enter at sign-up is under 13, we do not create an account and we do not keep the date of birth or age you entered. If we learn that we have collected personal information from a child under 13, we close the account and delete that information promptly, except for the minimum record needed to prevent the account from being re-created. If you believe a child under 13 is using SPARK, contact us at the address in Section 14.

Learners 13 to 17. Teens may use SPARK with the permission of a parent or legal guardian. We collect the same information from teens as from every learner (Section 1), and nothing extra because they are teens. We do not ask teens for military service information. For every learner whose age group is 13 to 17, we also:

  • Never sell or share their information, including for targeted or cross-context behavioral advertising. SPARK shows no ads.
  • Never give their information to military recruiters, the military services, or anyone else for recruiting or marketing.
  • Never send them text messages. Reminders come by email or in-app notification, and the teen can turn them off.
  • Use personalization only to help them learn. We do not build profiles of teens to sell or to target them, and we do not use their information to make decisions with legal or similarly significant effects.
  • Never collect precise location.

Mobile app stores and parent approval. On iPhone and Android, the app store may tell us a teen's age range and whether a parent or guardian has approved the teen's use of SPARK. We receive only that signal, not the teen's birthday. If a parent or guardian withdraws approval through the app store, we lock the teen's account: the teen cannot sign in, and nothing is deleted. The account unlocks if approval is given again. A parent who wants the information deleted instead can ask us (see "Parents and guardians" below).

Parents and guardians. A parent or legal guardian of a learner aged 13 to 17 may ask us to see the teen's information, correct it, delete the account and its information, or stop reminders and notifications. A teen can do all of this in Privacy and Terms in Settings. A parent who does not have access to the teen's account can email support@sparkcourses.org with the subject "Privacy request" and the teen's account email address. Before we act, we take reasonable steps to confirm that you are the teen's parent or guardian, for example by contacting the teen's account email or asking for information that only the account holder or a parent would know. We respond within the time limits in Section 12.

Education records. SPARK is a test-preparation and workforce-readiness platform, not a school or an education-records system, and it does not generally act as a "school official" under the Family Educational Rights and Privacy Act ("FERPA"). If an educational institution provides SPARK in a way that involves FERPA, we handle those records as that institution authorizes and as the law requires.

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7. Military and government program information

If you use SPARK through a military or government Organization, we may process information such as branch of service and installation that the Organization provides or that you supply. We use it to deliver and support your learning and to meet the Organization's reporting requirements. We do not use it for recruiting or marketing, and we share it only as described in this Policy or as the Organization directs under its agreement with us. Records we create for a government Organization may also be subject to federal records and privacy laws that apply to that Organization.

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8. Data retention

We keep your personal information while your account is active and as needed to provide SPARK to you and, if applicable, your Organization. After that, we keep information only as long as needed to meet recordkeeping obligations (such as policy-acceptance history and certificate records), resolve disputes, enforce our agreements, and comply with law. Aggregated, de-identified information that does not identify you may be kept for reporting and improvement. We may close Free Plan accounts that have been inactive for a long time, after notice to the account email. When you, or a parent or guardian of a learner 13 to 17, ask us to delete an account, we close it right away and delete its personal information after a 30-day waiting period, in case the request was a mistake, except for the records described above.

Specific periods: voice recordings and the assistant's spoken replies are deleted after 30 days; photos you share with the assistant are deleted after 30 days; live tutoring transcripts are deleted 30 days after the session; callback numbers and our phone-line provider's call records are deleted within 90 days; AI session notes stay until you delete them.

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9. Your rights and choices

Use Privacy and Terms in Settings, or contact us, to:

  • Access and portability: get a copy of your personal information, including an in-app data export;
  • Correction: fix inaccurate profile information;
  • Deletion: close your account and delete your personal information, subject to the retention exceptions above;
  • Communications: choose which reminders and announcements you receive;
  • Cookies: manage cookie settings as described in the Cookie Notice; and
  • Device permissions: turn microphone, camera, photo, and notification access on or off in your device settings.

Depending on where you live, you may have additional rights, and we will not discriminate against you for using them. If your account is through an Organization, some requests may be coordinated with that Organization. A parent or guardian of a learner 13 to 17 can make these requests for the teen as described in Section 6.

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10. International users

SPARK is operated from the United States, and your information is processed there. If you use SPARK from outside the United States, your information is transferred to and processed in the United States. If you are in the European Economic Area, the United Kingdom, or another place with data-transfer rules, you have the rights to access, correct, delete, and export your data and to withdraw consent. Where required, transfers are protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses, together with technical protections such as encryption. You may complain to your local data protection authority (in the UK, the Information Commissioner's Office). For data-protection questions, contact support@sparkcourses.org with the subject "Privacy request." We have not appointed an EU or UK representative because our processing does not meet the thresholds that require one; if that changes, we will update this Policy.

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11. Data security

We use industry-standard technical and organizational measures, including encryption in transit and at rest, access controls, and monitoring. No system is completely secure. Protect your account by keeping your email account secure and signing out on shared devices. If a data breach affects your personal information, we will notify you, the relevant authorities, and your Organization (if any) as required by law.

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12. Your California and other U.S. state privacy rights

This section is for California residents under the California Consumer Privacy Act, as amended ("CCPA"), and supplements the rest of this Policy.

We do not sell your personal information and do not share it for cross-context behavioral advertising. We have not done so in the preceding 12 months. SPARK is available to learners 13 and older, so we do collect personal information of consumers aged 13 to 15. We never sell or share it, so the CCPA's opt-in consent for selling or sharing the information of consumers under 16 is never needed. We do not knowingly collect personal information of consumers under 13.

Categories of personal information we collect (in the preceding 12 months; see Section 1 for detail):

| CCPA category (Cal. Civ. Code § 1798.140(v)(1)) | Collected | Examples in SPARK | | --- | --- | --- | | A. Identifiers | Yes | Name, email address, account identifier, device identifiers, push token, IP address; phone number if you call support | | B. Customer records (§ 1798.80(e)) | Yes | Name and email address | | C. Characteristics of protected classifications | Yes, limited | Age group (13 to 17, or 18 and older), from the date of birth or age you enter at sign-up, which we do not store; military service status if you or your Organization provide it | | D. Commercial information | No | Individuals do not purchase anything in SPARK; Organization plans are purchased by the Organization | | E. Biometric information | No | We do not collect biometric identifiers | | F. Internet or other electronic network activity | Yes, limited | How you interact with SPARK, app version, browser type, log and diagnostic data | | G. Geolocation data | Yes, limited | General location from IP address; no precise geolocation | | H. Audio, electronic, or visual information | Yes | Voice input to the AI learning assistant and its spoken replies (kept up to 30 days); photos you choose to share (kept 30 days); live tutoring audio and video and, with consent, a temporary recording; support call audio (kept by our phone-line provider up to 90 days) | | I. Professional or employment-related information | Yes, limited | Branch of service and installation, for military Organizations | | J. Education information | Yes | Goals, progress, assessment and practice results, reported test scores, certificates, AI assistant conversations, notes, tutoring transcripts and session notes | | K. Inferences | Yes | Adaptive recommendations, readiness, and predicted scores drawn from your activity | | L. Sensitive personal information (§ 1798.140(ae)) | No | See below |

We do not collect "sensitive personal information" as the CCPA defines it. We do not collect government identifiers such as a Social Security number or DoD ID, precise geolocation, or information about racial or ethnic origin, religious or philosophical beliefs, union membership, health, or sexual orientation. Learners sign in with one-time sign-in codes, not passwords. Messages to the AI learning assistant and to tutors are sent to us as the intended recipient and are used to provide the service. Because we do not use sensitive personal information for purposes that would trigger it, the right to limit its use does not apply.

Sources: you, your device, and, if you joined through one, your Organization.

Purposes: the purposes in Sections 2 and 5.

Disclosures for a business purpose: to the service providers in Section 5 and, for Organization accounts, to your Organization, for the purposes in this Policy. We do not disclose personal information to third parties for their own purposes.

Your California rights. Subject to verification and the CCPA's exceptions, you may know and access the personal information we have collected about you, the categories of sources, purposes, and recipients; correct it; delete it; and not be discriminated against for exercising these rights. Because we do not sell or share personal information or collect sensitive personal information, no opt-out of sale or sharing and no request to limit is needed.

How to exercise your rights: use Privacy and Terms in Settings, including data export and account deletion, or contact us below. You may use an authorized agent; we may ask the agent to show authority and ask you to verify your identity.

Response times and appeals. We acknowledge requests within 10 business days and respond within 45 days, which we may extend once by 45 days with notice. Residents of states with comprehensive privacy laws may appeal a declined request by replying to our privacy contact; we respond within 60 days. If we deny your appeal, you may contact your state Attorney General.

Shine the Light. We do not disclose personal information to third parties for their direct marketing purposes.

Other U.S. states. Residents of other states with comprehensive privacy laws may have similar rights, which you may exercise and appeal using the same contacts. Some states give additional protections to the information of minors. The protections for learners 13 to 17 in Section 6 apply to every teen, wherever they live.

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13. Changes to this Policy

We may update this Policy. For material changes, we will update the effective date and give prominent notice, such as an in-app message, an email, or a prompt to accept on your next sign-in.

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14. Contact us

Vantage Point Consulting, Inc. 19700 Derby St West Linn, OR Email: support@sparkcourses.org (use the subject "Privacy request" for privacy questions and requests)

If you joined through an Organization, its support contact is in Settings.

Vantage Point is the controller of personal information processed under this Policy, except where it acts as a processor for an Organization, in which case the Organization directs that processing.