Privacy Policy

Last Updated: January 21, 2025

1. Introduction

QubiLearn Technologies Private Limited ("we", "us", or "our") operates Spark School AI, an educational technology platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Children's Online Privacy Protection Act (COPPA), and Indian data protection regulations.

2. Information We Collect

2.1 Personal Information

  • Account Information: Name, email address, password, user type (student/teacher/parent)
  • Profile Information: Grade level, subjects, school affiliation, curriculum type
  • Contact Information: Phone number (optional), emergency contacts for minors
  • Payment Information: Billing address, payment method details (processed by secure third-party providers)

2.2 Educational Data

  • Learning Progress: Quiz scores, assignment completion, time spent on activities
  • Content Interactions: Questions asked, answers provided, materials accessed
  • Adaptive Learning Data: Learning patterns, difficulty preferences, performance analytics
  • User-Generated Content: Notes, assignments, projects created using our tools

2.3 Technical Information

  • Device Information: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages visited, features used, session duration, click patterns
  • Cookies and Tracking: See our Cookie Policy for detailed information

3. Children's Privacy (COPPA Compliance)

We take special care to protect children's privacy and comply with COPPA requirements:

3.1 Parental Consent

  • We obtain verifiable parental consent before collecting personal information from children under 13
  • Schools may provide consent on behalf of parents for educational use under COPPA's school exception
  • Parents can review, modify, or delete their child's information at any time

3.2 Limited Data Collection

  • We collect only information necessary for educational purposes
  • No behavioral advertising to children under 13
  • Enhanced security measures for children's accounts
  • Regular deletion of unnecessary data

3.3 Parental Rights

Parents have the right to:

  • Review all personal information collected from their child
  • Request deletion of their child's personal information
  • Refuse to allow further collection or use of their child's information
  • Contact us at privacy@qubilearn.in for any privacy concerns

4. How We Use Your Information

4.1 Educational Purposes

  • Provide personalized adaptive learning experiences
  • Track learning progress and generate performance analytics
  • Create customized study plans and recommendations
  • Generate educational content and assessments
  • Facilitate communication between students, teachers, and parents

4.2 Service Operations

  • Maintain and improve our AI algorithms and platform functionality
  • Provide customer support and respond to inquiries
  • Process payments and manage subscriptions
  • Send important service updates and notifications
  • Ensure platform security and prevent fraud

4.3 Research and Development

  • Conduct educational research to improve learning outcomes (anonymized data only)
  • Develop new features and educational tools
  • Analyze usage patterns to enhance user experience

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share information in the following circumstances:

5.1 Educational Context

  • With teachers and school administrators for educational purposes
  • With parents/guardians regarding their child's progress
  • With authorized educational institutions and curriculum partners

5.2 Service Providers

  • Third-party services that help us operate our platform (cloud hosting, payment processing)
  • AI and machine learning service providers (with appropriate data protection agreements)
  • Customer support and analytics tools

5.3 Legal Requirements

  • When required by law, court order, or government request
  • To protect our rights, property, or safety, or that of our users
  • In connection with a business transfer or acquisition

6. Data Security

We implement comprehensive security measures to protect your information:

  • Encryption: Data encrypted in transit and at rest using industry-standard protocols
  • Access Controls: Strict access controls and authentication requirements
  • Regular Audits: Security assessments and vulnerability testing
  • Staff Training: Regular privacy and security training for all employees
  • Incident Response: Procedures for detecting and responding to security incidents

7. Data Retention

We retain your information only as long as necessary for the purposes outlined in this policy:

  • Account Data: Retained while your account is active and for a reasonable period after closure
  • Educational Records: Retained according to educational record-keeping requirements
  • Children's Data: Deleted when no longer needed for educational purposes or upon parental request
  • Analytics Data: Anonymized and aggregated data may be retained for research purposes

8. Your Rights and Choices

8.1 Access and Control

  • Access and review your personal information
  • Update or correct inaccurate information
  • Delete your account and associated data
  • Export your data in a portable format
  • Opt-out of non-essential communications

8.2 Regional Rights

  • GDPR (EU): Right to rectification, erasure, portability, and objection
  • CCPA (California): Right to know, delete, and opt-out of sale of personal information
  • India: Rights under applicable Indian data protection laws

9. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place, including:

  • Standard contractual clauses approved by relevant authorities
  • Adequacy decisions by data protection authorities
  • Certification schemes and codes of conduct

10. Third-Party Services

Our Service may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to such third parties. We encourage you to review their privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or through our Service. The "Last Updated" date at the top indicates when the policy was last revised.

12. Contact Us

For questions about this Privacy Policy or to exercise your rights, contact us:

13. Supervisory Authority

If you have concerns about our privacy practices, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.