PRIVACY POLICY

1. Introduction

Welcome to SPARKi, an educational and entertainment technology platform designed exclusively for children. At [Company Name], we recognize the critical importance of protecting children’s privacy in the digital age. This Privacy Policy outlines the type of information we collect, how we use it, how it is stored, and the rights of parents and guardians regarding their child’s data.

This policy is in full compliance with the following laws and regulations:

• Indian Regulations:

  • Information Technology Act, 2000 (IT Act)

  • Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011

  • Digital Personal Data Protection (DPDP) Act, 2023

  • Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

• International Standards:

  • General Data Protection Regulation (GDPR) – GDPR-K (for children’s data in the EU)

  • Children’s Online Privacy Protection Act (COPPA – USA)

  • California Consumer Privacy Act (CCPA – USA, where applicable)

By using SPARKi, parents, guardians, and children (where applicable) agree to the collection and use of personal data as described in this policy. If you disagree with any part of this policy, please discontinue use of our services.

At SPARKi, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use the App.

Definitions

• “Child” refers to any user under the age of 18 as per Indian law or under 13 where international child protection laws like COPPA apply.

• “Personal Data” means any information that can identify an individual, including but not limited to name, email, or device identifiers.

• “Parental Consent” refers to verifiable parental approval before collecting, using, or disclosing a child’s personal information.

• “Processing” includes data collection, storage, analysis, transfer, and deletion.

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2. Information We Collect

We strictly collect only minimal and necessary data required for our services while ensuring compliance with child protection laws.

2.1 Personal Data (Limited and With Parental Consent)

For children under 13, we collect:

• First Name (optional, pseudonym recommended)

• Age/Date of Birth (to verify compliance with age restrictions)

• Parent’s or Guardian’s Email (to verify consent)

• User Avatar/Profile Picture (optional and only if parent-approved)

For users aged 13 and above, we may collect:

• Email Address (for account registration and notifications)

• Device Information (non-identifiable)

We do NOT collect:

• Precise Location Data

• Biometric Data

• Financial Information from Children

2.2 Non-Personal Data

We collect aggregated and anonymized data to improve user experience:

• App usage statistics (time spent, favorite features)

• Device and OS type

• IP Address (anonymized and not stored)

• Performance logs (to fix bugs and crashes)

2.3 Parental Information

To ensure compliance with verifiable parental consent, we collect the parent’s email address and limited parental details for:

• Account Management

• Parental Control Settings

• Communication of Privacy Updates

 

3. How We Use Your Information

We process data strictly within the legal framework and ensure data minimization principles:

• For Service Improvement

  • Personalizing learning experiences

  • Tracking academic progress (if applicable)

  • Adapting recommendations based on usage patterns

• For Safety and Compliance

  • Age verification to enforce age-appropriate content

  • Monitoring user behavior (to prevent cyberbullying or harmful activities)

  • Ensuring COPPA, GDPR-K, and DPDP Act compliance

• For Communication & Support

  • Customer service inquiries and resolving complaints

  • Security updates and important notifications

We DO NOT use children’s data for:
           Behavioral advertising
           Selling to third-party marketing agencies
           AI-based profiling

 

4. Sharing Your Information

4.1 With Whom We Share Data

We do NOT share children’s personal data with advertisers, social media networks, or unauthorized third parties.

However, we may share limited data with:

• Educational Partners (only with parental consent)

• Regulatory Authorities (if legally required)

• Service Providers (for cloud storage, customer support, analytics)

4.2 Third-Party Integrations

We strictly evaluate third-party vendors before integration. Our service providers must:
✔ Comply with Indian DPDP Act, COPPA, and GDPR
✔ Implement data protection and encryption
✔ Never use children’s data for ads or tracking

 

Service Providers: We may share personal data with trusted third-party service providers that assist us in operating the App, including payment processors, email marketing services, and analytics providers.
Legal Compliance: We may disclose your information to comply with applicable laws, regulations, or legal processes.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

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5. Data Retention and Security

Data Retention: We retain personal information only as long as necessary to provide services, comply with legal obligations, or resolve disputes.
Security Measures: We use industry-standard encryption and security protocols to protect your information from unauthorized access, use, or disclosure.

5.1 Data Security Measures

We implement state-of-the-art encryption and ISO 27001-certified security practices to protect all collected data:

✔ End-to-End Encryption (AES-256) for stored data
✔ Multi-Layer Firewall Protection for app servers
✔ Two-Factor Authentication (2FA) for parental accounts
✔ Strict Access Controls (only authorized personnel can handle data)

5.2 Data Retention Policy

• Child data is stored for active account duration and automatically deleted after 12 months of inactivity.

• Parents may request deletion anytime via [support@SPARKi.info].

 

6. Your Rights

6.1 Access and Update: You have the right to access, correct, or update your personal information.
6.2 Deletion: You can request that we delete your child’s account and associated data.
6.3 Data Portability: You may request a copy of your child’s data in a portable format.

6.1 Parental Consent Mechanism

Parents must verify their identity before granting permission. Verification methods include:
✔ Email verification with OTP
✔ Credit card verification (for age-check only, no charge applied)

6.2 Parents Have the Right To:

• Access their child’s data

• Modify incorrect information

• Delete the child’s account upon request

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To exercise these rights, contact [support@SPARKi.info].

 

7. Compliance with Global Laws

7.1 India-Specific Compliance

✔ IT Act, 2000
✔ DPDP Act, 2023
✔ Intermediary Guidelines, 2021

7.2 International Laws

✔ COPPA (USA) – No data collection without parental consent
✔ GDPR (EU) – Strict compliance with children’s rights under Article 8
✔ CCPA (California) – Right to opt-out for parents

 

8. Changes to This Privacy Policy

We update our Privacy Policy every 12 months or whenever legal regulations change. If we make significant updates, parents will receive a notification via email.

 

9. Contact Us

For privacy-related concerns, please reach out to:

📧 Email: support@sparki.com
📞 Phone: +91-98123-04568

📍 Address:    M/s Skyiris Infotech Media Pvt. Ltd.,

2218, Civil Lines, Jagadhri, Yamunanagar,

Haryana - 135003

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Last Updated: [01/04/2025]