Sparkler Privacy Policy

Drafted: May 9, 2017

Summary

The privacy of your data is extremely important to Sparkler. We will treat your data carefully, preserving your privacy according to the rules laid out in this document and to the best of our ability. Our Privacy Policy explains what information we collect, why we collect it, and how we use that information.

FERPA and other regulatory obligations

We will always abide by FERPA and other educational and data privacy regulations as they apply to your data. For more technical information on how we abide by FERPA please see this link.

What information we collect and why we collect it.

We collect information to provide better services to all of our users. We collect information in two ways:

Information you give us

For example, some of our services may require you to sign up for a Sparkler account. When you do, we’ll ask for personal information, like your name, email address, and a password.

Information we get from your use of our services

We may collect information about the learning services that you use and how you use them. This information includes:

Credential information

We may obtain and compare your provided login credentials with known credentials associated with your account in order to provide you access to your account. We may store and issue temporary credentials on your behalf for purposes such as password resets.

Device information

We may collect device­ specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). Sparkler may associate your device identifiers or phone number with your Sparkler account.

Log and application information

When you use our services or view content provided by Sparkler, we may automatically collect and store certain information in server logs. This may include: details of how you used our service, such as your activities on authorized learning websites, Internet protocol address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Sparkler account.

Network information

When you use a Sparkler service, we may collect and process information about your network, such as your IP address, your Internet Service Provider, your domain name, your bandwidth, your network route to the Internet and to our services.

Location information

When you use a location-­enabled Sparkler service, we may collect and process information about your actual location. When you do not use a location enabled service, we may infer your approximate location by examining your Network information.

Local storage

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Cookies and anonymous identifiers

We use various technologies to collect and store information when you use a Sparkler service or a partner who uses our technology, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with services we offer to our partners, such as Sparkler features that may appear on other sites.

How we use information we collect.

We use the information we collect from all of our services first and foremost to provide information to our customers and partners to help them provide services based on the information. We also use the information to provide, maintain, protect and improve the services we offer as well as to develop new services, to keep our system running effectively and to protect Sparkler and our users.

We will never sell information provided by, or about, our customers or partners to anyone.

We may share information about our customers or partners with partners for purposes of delivering our services. For example, we might share information about specific users to a data analytics partner who can analyze this information to provide predictions about the services a user might need (this is sometimes called "predictive analytics" or "collaborative filtering"). In cases where we do share information in this way to partners, we will ensure that the partner is bound by the same or similar privacy agreement as this one, so that your information cannot be used by that organization in a way that is different from how we use it, as described in this privacy policy.

We may use the name you provide for your Sparkler profile across all of the services we offer that require a Sparkler account. In addition, we may replace past names associated with your Sparkler account so that you are represented consistently across all our services. If other users already have your email, or other information that identifies you, we may show them your publicly visible Sparkler profile information, such as your name and photo. When you contact Sparkler, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements, or in the case of urgent updates.

We use information collected from cookies and other technologies, like pixel tags and web page events, to improve your user experience and the overall quality of our services. For example, we may track a website you visit and some information about what you do on that website, with your permission or the permission of your school or the organization providing Sparkler to you. We may combine personal information from one service with information, including personal information, from other Sparkler services – for example to improve our ability to provide relevant services to you.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy. Sparkler currently processes personal information on servers located in the United States. When we process your personal information, we do not guarantee it will be on a server located in the country where you live. Our management of your data will always be governed by this Privacy Policy.

Transparency and choice

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. In some cases your information may be managed by a third party such as a school, healthcare provider, or community organization. In those cases, your control over the use of your data at Sparkler may be the responsibility of that third party. We will always do our best to help you work with that third party to manage your information. In all cases where it applies, we will follow FERPA and other privacy and data use regulations.

We always aim to maintain our services in a manner that protects information from accidental disclosure or malicious interference. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems, but we will still follow this Privacy Policy when managing those residual copies.

Information we share

We do not share personal information with companies, organizations and individuals outside of Sparkler unless one of the following circumstances applies:

With your consent

We will share personal information with companies, organizations or individuals outside of Sparkler when we have your consent to do so. We require opt-­in consent for the sharing of any sensitive personal information.

With partner administrators

If your Sparkler account is managed for you by a Sparkler partner then your administrator and others who provide user support to your organization may have access to your Sparkler account information (including your email and other personal activity data). Your administrator may be able to view statistics regarding your account, like statistics regarding web and other applications you interact with. Please refer to your administrator’s privacy policy for more information.

With partner administrator authorized recipients

In some cases, partner administrators will authorize other parties to view or interact with your information, usually to improve the services you receive related to the information. For example, a partner administrator may make your data available to your teacher, so they can help you learn, or they may ask us to make your data available within an authorized Learning Management System.

For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate regulations, confidentiality and security measures.

For legal reasons

We will share personal information with companies, organizations or individuals outside of Sparkler if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Service, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues, protect against harm to the rights, property or safety of Sparkler, our users, employees or the public as required or permitted by law.

We may share aggregated, non­-personally identifiable information with our partners for purposes of improving our services. For example, we may share information publicly or with investors to show trends about the general use of our services. If Sparkler is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Information security

We work hard to protect Sparkler and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular, we encrypt many of our services using SSL. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We restrict access to personal information to Sparkler employees, contractors and agents who need to know that information in order to process or manage it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

When this Privacy Policy applies

Our Privacy Policy applies to all of the services offered by Sparkler and its affiliates, including services offered on other sites (such as our partners) where the data from those services are managed by Sparkler, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may include Sparkler services, or other sites linked to from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant, complementary or related services. Due to the design of the infrastructure services we provide, it may not always be obvious what is a Sparkler service covered by this policy and what is a third party service not covered by this policy. You can always inquire with Sparkler to find out if we are managing your data.

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks. Should we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent or giving you the opportunity to opt-out of any changes. Opting-out could require stopping your use of our services entirely.

We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review upon request. If you have questions regarding our privacy policy you can email help@playsparkler.com for more information.