SparkIQ privacy policy

Who we are

SparkIQ is operated by VR DIGITAL SOLUTIONS PTY LTD (ABN 78 666 063 127), NSW 2145, Australia, trading as SparkIQ. In this policy, "SparkIQ", "we" and "us" mean that company.

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Some small businesses are exempt from the Privacy Act. SparkIQ is used by children, so we do not rely on that exemption, whether or not it would apply to us. We follow the APPs and the Notifiable Data Breaches scheme as if we were fully covered.

Privacy questions, requests and complaints go to: Privacy Officer, VR DIGITAL SOLUTIONS PTY LTD. See Questions and complaints for how to reach us.

The short version

• For a child, we ask for a nickname, school year and curriculum. We don't ask for a real name, photo, date of birth, school, address or phone number.
• A parent's email address is the only real-world identifier we ask for.
• By default, a child's learning history is stored in the browser on your device. Some optional features send information to our servers or to service providers. Each is described below, and most are off until you turn them on.
• Cloud backup is protected, but it is not end-to-end encrypted. The parent phone view is end-to-end encrypted.
• We show no ads, we do not sell or rent personal information, and we do not build marketing profiles of children or families.
• Some service providers store or process data outside Australia, mainly in the United States.
• You can delete a child's data in the app, and you can ask us to delete anything we hold.

What we collect

About a child

• Profile: nickname, school year and curriculum (for example, NSW). This lets the tutor pitch work at the right level. We ask for a nickname, not a real name, and the app never asks for anything else about who a child is.
• Learning activity: answers, levels, mastery, practice history, review schedule, session summaries (for example, "worked on fractions"), gems, badges and similar progress records. We do not keep chat transcripts.
• Safety events: if the app shows a child a safety message, it records the type of event and the date, not what the child typed. See Wellbeing and safety signals.
• An optional profile PIN a parent can set for a child who shares a device. It is stored as a hash.
• Feedback taps: if a child taps the feedback button, a face rating, optional reason chips and their school year. Children cannot type free text into feedback.

Even a nickname and learning history can be personal information when they are linked to a family, so we treat them as personal information and protect them accordingly.

About a parent or guardian

• Email address: used to reset your parent PIN on the device, to sign in to cloud backup, and, only if you opt in, for the weekly summary and product news emails.
• Parent PIN: stored as a salted hash on your device only. It is never put in the cloud backup, so each device has its own PIN. It keeps settings and payments away from children. It is a household lock, not a strong security control, so please don't reuse a PIN you use elsewhere.
• Feedback notes you choose to type, and any survey answers you give.
• Payment records, only once paid plans are switched on (they are not switched on today): see Payments.
• Messages you send us, such as emails.

Technical information

When your device talks to our servers or providers, they receive the technical information every web request carries, such as your IP address, browser type and the time of the request. We use it to deliver the service, apply usage limits and keep the service secure. Our AI and email usage limits keep a daily count against a scrambled (hashed) value, not your IP address. Our providers may keep short-lived technical logs under their own terms.

What we don't collect

• No child's real name, photo, date of birth, school, home address or phone number.
• No government identifiers.
• No precise location.
• No advertising identifiers, and no advertising or marketing pixels.

How we collect it

We collect information directly from the parent or guardian who sets up SparkIQ, and from a child's use of the app under that parent's setup. We collect technical information automatically when a device connects to our servers. We don't buy personal information or collect it from data brokers. If you sign in with a third-party account (this option is currently switched off), we keep only your email address from it, not your name or photo.

You don't have to give us your email address to try SparkIQ's sample lesson. You need one to set up a family, because it is how you get back into the parent area if you forget your PIN. You can't use SparkIQ anonymously as a parent. Children use SparkIQ under a nickname by design.

Why we use it, and what we don't do

We use personal information to:

• run SparkIQ: tutoring, practice, progress, review schedules and the parent area;
• provide the optional features you turn on, such as cloud backup, phone view, the AI helper and the weekly summary;
• keep children safe: safety messages, usage limits and moderation;
• answer your messages and requests, and tell you about important changes to the service;
• improve SparkIQ, using usage counts (not linked to a name or id) and feedback;
• take payments, once paid plans are switched on;
• protect the service from misuse, and meet our legal obligations.

We use or disclose personal information only for the purpose we collected it for, for a related purpose you would reasonably expect, with your consent, or where the law requires or allows it.

What we don't do: we show no ads. We don't sell, rent or trade personal information. We don't build behavioural or marketing profiles of children or families. We don't use a child's information to target them with anything. The app personalises learning only, based on what a child gets right and wrong.

Where it goes, feature by feature

On your device (the default)

A child's profile and learning history are stored in the browser on the device they use, in localStorage. SparkIQ can't see this data unless you turn on one of the features below. Anyone who can use that device and browser can reach the stored data, so the parent PIN keeps the parent area separate.

Cloud backup and sync (optional)

Your SparkIQ login (optional). You can choose to create a login, at family setup or later in Parents → Data, so you can sign in on your other devices with your email and a password you set. A login is only created if you choose it. One exception you also choose: if you forget your Parent PIN and ask for a reset code, and you have no login yet, a login is created for the parent email saved on that device, used only to send PIN reset codes. It has no password, does not turn on cloud backup and does not sign the device in. A login stores your email address and your password in hashed (scrambled, one-way) form in our sign-in system, run by our database provider, Supabase. SparkIQ never sees, stores or logs your password itself; the app keeps only a sign-in session on your device. A login collects nothing new about your children. Creating a login also turns on cloud backup (below), because signing in on another device is only useful if your family's data is there to bring across. Signing out on a device never deletes the backup; you can choose to keep the family's data on that device or remove it from that device only.

If you create a login or sign in with your email (by password, one-time link or code), SparkIQ keeps a copy of your family's app data on our database so it can sync between your devices. That copy includes children's nicknames, years, curricula, learning history and your email address. It never includes PINs, safety-event records (those stay on the device) or any AI key typed into the app. "Erase everything" in Parents → Data deletes this copy and signs you out; if that step fails (for example when offline), the app tells you and lets you try again. Your sign-in record (your email address, and your hashed password if you set one, in our sign-in system) is separate and stays until you ask us to delete it; see How long we keep it.

To look after pilot families, we can see a short list of families using backup: the parent email, when the family joined, when it last synced, how many child profiles it has, how many days it was active in the last two weeks, and its email preferences. It shows no nicknames, years or learning details, and only our administrators can see it.

This backup is not end-to-end encrypted. It is sent over encrypted connections, stored with our database provider, and locked so that only your signed-in account can read it through the app. People who administer our database could technically access it. We access it only when we need to: to fix a problem you report, to keep the service secure, or when the law requires it.

Parent phone view (optional, end-to-end encrypted)

If you turn on phone view, the child's device encrypts a progress snapshot (AES-GCM) with a key made from a random code that exists only in the private link you are given. Our server stores only the encrypted data and cannot read it. The link never goes into cloud backup. Before 25 September 2026 it could: if you used cloud backup and phone view together before then, press "Stop sharing" and share again once, so the old link stops working. The snapshot covers the last 90 days of progress and includes the date and type of any safety events in that time, so the parent reading it can check in. Anyone who has the link can read the snapshot, so share it only with people you trust. "Stop sharing" deletes the stored copy.

The AI helper

See The AI helper and automated decisions. In short: when it is on, the question a child types is sent through our server to an AI model for an answer. Before it is sent, we remove the child's nickname and common personal details. We don't store the question or the answer.

Usage counts, not linked to a name or id (on unless you turn them off)

The app sends daily totals such as "maths sessions: 3" or "fractions: 7 right, 2 wrong". Each total carries a school-year band, the week the device started using SparkIQ, the app version, the device type (phone, tablet or computer) and whether the app is installed. Some totals also carry a time-of-day band (such as "after school"), the day of the week or a session-length band (such as "15–30 minutes"). They contain no names, nicknames, child or family ids, typed text, exact times, or safety events. You can turn them off in Parents → Privacy.

Feedback

The feedback button sends a rating, reason chips, the screen it was sent from, a school year, the app version and the device type. A grown-up may add a typed note, so please don't include personal details in it. Feedback isn't linked to a child or family id.

Where usage counts and feedback are kept

Usage counts and feedback are kept in our Supabase database. We are moving them to a shared reporting store in the same database (tables named ik_feedback, ik_usage_daily and ik_family_usage). While we move, the same counts and feedback may be saved in both places. Nothing new is collected: the same Parents → Privacy switch controls both, the same deletion periods apply (usage counts 25 months, feedback 24 months), and only SparkIQ's administrators can see the totals.

Natural voices (on by default; a parent can turn them off)

With Natural voices on, the buddies read aloud using recordings that come with the app. Some of SparkIQ's own spoken lines (never anything your child types or says) may be sent to Cloudflare to be turned into speech; SparkIQ keeps only a cache of that audio for its own words, with nothing that identifies your child. A parent can switch this off in Parents → Children; the device's own voice is then used, fully on-device.

Voice input (optional, parent-enabled)

If a parent turns on the microphone, the app uses the speech recognition built into your browser. Depending on your browser, the audio may be sent to the browser maker (for example Google or Apple) to be turned into text, under that company's own privacy terms. SparkIQ receives only the resulting text, and treats it like typed text. Where your browser supports on-device recognition, SparkIQ asks for it, so the audio stays on the device. SparkIQ never records or stores audio.

Payments (not switched on yet)

SparkIQ is free during the pilot. When paid plans start, payments will be handled by Stripe on Stripe's own checkout page. We never see or store your card details. We will keep a random family id, Stripe's customer and subscription ids, your plan, the number of children, and when your paid period ends. Stripe will receive your email address and payment details, and handles them under its own privacy policy.

Shared exercise packs (optional, parent area)

In Parents → Teacher tools, a parent, tutor or teacher can share their own custom exercises as a pack with a short code. The pack holds only the exercise text (questions, options, answers, hints and worked solutions), a subject, a year band and the pack name. It never includes a nickname, a child id or any results. Links, email addresses and phone numbers are rejected. Anyone who is given the code can copy the pack, so please don't put a child's name or other personal details in your exercises. Packs are stored with our database provider and deleted after 90 days.

Links to other websites

The parent area links to some external learning sites. They have their own privacy policies. The app doesn't contact them from a child's device unless a parent opens a link.

Service providers and overseas storage

We use these providers to run SparkIQ. They process information on our behalf, and we choose providers whose terms commit them to protecting it.

• Supabase (database and server functions): cloud backup, encrypted phone view, feedback, usage counts, website visit totals, shared exercise packs, email subscription records, AI usage counters and payment records. Supabase is a US company; our database may be hosted outside Australia and can be accessed from the United States for support and operations.
• Cloudflare (website hosting, network and AI): serves this website and the app, and runs the AI helper and its safety check on Cloudflare Workers AI. Cloudflare is a US company that processes data in data centres around the world. Before the AI helper answers, the app also uses Cloudflare Turnstile, a bot check that reads browser signals (such as how the page is used) to tell people from automated scripts. It is not used for ads or tracking, and the app gives it no nickname, school year or anything a child types.
• Resend (email delivery): receives your email address and the content of emails we send you, such as the weekly summary. Resend is a US company, and email is processed in the United States.
• Stripe (payments, once switched on): receives payment details and your email address. Stripe processes data in the United States and other countries.

This means personal information may be disclosed to, stored in or accessed from the United States and other countries where these providers operate. Before disclosing personal information overseas, we take reasonable steps (including relying on each provider's contractual data-protection terms) to make sure it is handled consistently with the APPs. We remain accountable for how these providers handle your information on our behalf.

Wellbeing and safety signals

SparkIQ watches for signs that a child may be upset or at risk, for example distress, self-harm or an eating-disorder signal. No filter catches everything: SparkIQ is a learning tool, not a monitoring or crisis service. When it recognises one, it pauses and points the child to a trusted adult and Kids Helpline (1800 55 1800). The app records the type of event and the date so a parent can check in. It never records what the child typed. If a child discloses abuse, the app deliberately doesn't show it in the parent log, because the person responsible could be in the home.

A record like this could reveal something about a child's health or wellbeing, so we treat it as sensitive information. It stays on the device and is never copied into cloud backup. If you turn on the parent phone view, the date and type of events from the last 90 days are included in its end-to-end encrypted snapshot, which only someone with your private link can read. If you have opted into the weekly summary, the email may include a line saying we suggested talking to a trusted adult on a certain date. We collect this information only with the parent's consent, given at setup, and use it only to support the child.

SparkIQ is not a health or counselling service, and it doesn't diagnose or treat anything. If a child may be in danger, call 000.

NSW's Privacy and Personal Information Protection Act 1998 and Health Records and Information Privacy Act 2002 mainly apply to NSW public-sector agencies, and HRIPA also to health service providers. SparkIQ is neither. We handle any wellbeing information to the standard of the federal Privacy Act's rules for sensitive information.

The AI helper and automated decisions

Most of SparkIQ, including the diagnostic, adaptive tutoring, quizzes and spaced review, runs in the app itself. For open-ended questions, an AI helper answers instead. In this pilot the AI helper is switched on by default, and a parent can switch it off at any time (see below).

• Requests go through our server, which applies daily limits and fixed child-safety rules. The app never holds an AI key.
• Before a question leaves the device, the app checks it for things like phone numbers, emails, addresses and school names, and removes them. It also removes the child's nickname.
• The answer comes from an AI model on Cloudflare Workers AI. A separate safety model (Llama Guard) checks the question and the reply. If the check fails or can't run, the child gets a safe message instead.
• We don't store questions or answers. Cloudflare states that it does not use data sent to Workers AI to train models.
• Parent translation (optional): if a parent picks a language in the Parents area, the English summary text there is sent the same way to be machine-translated, with the child's nickname removed first. The translation is kept on the device only. Children's screens are never translated.
• Homework photo (optional, off until a parent turns it on in Parents → AI): a child can photograph one homework question. The app shrinks the photo on the device and the child crops it to just the question (no faces or names). Only that crop is sent the same way, to Cloudflare Workers AI, to be turned into text. The photo isn't stored anywhere, and the child checks the text before the tutor helps.
• Drawing photo (optional, off until a parent turns it on in Parents → AI): in the Art Studio, a child can photograph a paper drawing. The app shrinks it on the device, which also removes location data, and sends it once the same way to Cloudflare Workers AI. There it's checked for faces and worrying content, and then gets short feedback. The photo isn't stored anywhere. Drawings made in the app stay on the device and are never sent.
• AI answers can be wrong, and the app says so.
• You can turn the AI helper off in Parents → AI → Built-in (offline). Tutoring and practice keep working.

What the computer decides. A fixed rule in the app, not the AI, decides a child's working level, whether a skill counts as mastered, what to practise next, and the scores for practice papers and writing. These rules use the child's answers, and they run on the device. They adjust learning only. They don't decide access to the service, prices or anything outside SparkIQ. A parent can see the learning level for each subject in the parent area and can tell us if they think something is wrong. The AI only drafts explanations, hints and tutoring prompts.

Emails from us

• Weekly summary (optional): you must turn it on and confirm by clicking a link in your inbox. The summary is written on your device, with children called "Your learner" rather than by nickname, and our server passes it to our email provider. The server keeps your email address, a hashed device code, the subscription state and send dates. It doesn't keep the summary.
• Product news (optional): a separate opt-in with its own confirmation. Signing up for one doesn't sign you up for the other.
• Service messages: we may email you about your account, sign-in, security or important changes to this policy.

Every marketing or summary email identifies SparkIQ and contains a one-click unsubscribe link that works without logging in. You can also turn the weekly summary off in the parent area. We act on an unsubscribe straight away, and always within 5 business days, as the Spam Act 2003 requires. We keep a record that an address has unsubscribed so that we don't email it again.

Cookies, browser storage and site analytics

The app doesn't use cookies to track you or your child. It stores its data with localStorage, a standard browser feature. Signing in to cloud backup stores sign-in tokens in the same way on your device.

Our hosting provider, Cloudflare, counts visits to this website as part of hosting. Cloudflare may also add its Web Analytics script to our web pages. Cloudflare states that this script measures page views and performance without cookies and without tracking visitors across other websites. It can see information such as the page, the referring site, your browser and your approximate country. We use it only to understand overall site traffic, never for advertising.

We also count visits to this website ourselves: which page was viewed, the kind of site you came from (for example "Google" or "direct"), phone or computer, and whether you clicked through to the app. These are daily totals only. There is no cookie, no stored visitor id, and no full web address or referrer. If your browser sends Do Not Track or Global Privacy Control, we count nothing at all.

Security and data breaches

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, change or disclosure. These include:

• collecting as little as possible;
• encrypted connections (HTTPS);
• database access controls, so each family can read only its own backup;
• end-to-end encryption for phone view;
• keeping keys on the server, away from the app;
• rate limits, and restricted access for our own staff.

No system is completely secure, and we can't guarantee that information will never be accessed without permission. Please protect your devices, email account and phone-view link.

If we suspect a data breach, we will contain it and assess it promptly (within 30 days at most). If it is likely to cause serious harm, we will notify affected families and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, as the Notifiable Data Breaches scheme requires. We keep a written data breach response plan for this.

How long we keep it

• On your device: kept until you delete a child or erase everything. Nothing expires on its own.
• Cloud backup: kept while you use cloud backup. Deleting a child in the app removes that child from the backup at the next sync. "Erase everything" in Parents → Data deletes the whole backup. Your sign-in record (your email address, and your hashed password if you set one, in our sign-in system) stays until you ask us to delete it: contact us and we will delete it. The app doesn't have a button for that part yet.
• Shared exercise packs: deleted automatically after 90 days.
• Phone view: overwritten about once a minute while it is on, and deleted when you tap "Stop sharing", delete a child, or erase everything. We automatically delete copies nobody has updated for 180 days.
• Usage counts: deleted automatically after 25 months. They aren't linked to a name or child id, so deleting your data in the app doesn't affect them.
• Feedback: deleted automatically after 24 months. If you think your feedback note contains personal details, ask us and we will delete it sooner.
• Website visit totals: deleted automatically after 12 months.
• Long-term monthly totals: before usage counts, website totals and feedback are deleted, we add them to monthly totals, such as "March 2027, Years 5–6, maths sessions: 412" or "81% of ratings happy". These keep only the month, the school-year band and the count, never a device, family, child or written note, so they can't be linked to anyone. We keep them to see how SparkIQ changes over the years.
• Email subscriptions: kept while you are subscribed. After you unsubscribe, we keep only the address and its unsubscribed status, so that we don't email it again. You can ask us to delete that record completely. Sign-ups that were never confirmed are deleted automatically 30 days after the confirmation link expires.
• AI questions: not stored by us. Daily usage counters hold only a count against a scrambled (hashed) value, with a new counter each day, and are deleted automatically after 60 days.
• Payment records (once switched on): kept for as long as tax and accounting laws require.

When we no longer need personal information for any purpose allowed by law, we take reasonable steps to delete it or make it anonymous.

Seeing, correcting and deleting your information

In the app, at any time:

• See and export: Parents → Data lets you export everything stored on the device.
• Correct: the app doesn't have an edit screen for a child's nickname, year or curriculum yet. Ask us for help, or delete the child and add them again.
• Delete one child: Parents → Children → Delete this child's data, then type their nickname to confirm. This removes the child's profile and learning history from the device straight away, and it can't be undone. If phone view is on, it is switched off and the encrypted copy is deleted, because the link is shared by the whole family.
• Delete everything: Parents → Privacy → Delete everything for this family.

By asking us: you can ask for access to, or correction or deletion of, any personal information we hold about you or your child, including your cloud backup or email records. We will reply within 30 days. We may need to confirm that you are the account holder, usually by email, before we act. We don't charge for a request. If we refuse a request, we will tell you why in writing and how to complain.

Children, consent and best interests

SparkIQ is for children in Years 3 to 12, and it is set up by a parent or guardian. During setup, the parent confirms they are the child's parent or guardian, consents to the child using SparkIQ, and provides the parent email. A child never creates an account, never gives an email address, and can't reach payments or settings without the parent PIN.

We design SparkIQ around children's best interests. That means:

• collecting as little as possible;
• no ads and no profiling;
• no loss-framed streaks, guilt messages or endless feeds;
• break reminders that make stopping feel fine;
• high-privacy settings for children.

The OAIC is developing a Children's Online Privacy Code under the Privacy and Other Legislation Amendment Act 2024. It must be registered by 10 December 2026. We will review SparkIQ against the final Code and update this policy.

Older children can contact us about their own information. We will involve their parent or guardian where appropriate, taking into account the child's age and interests.

If you see harmful content or behaviour online, you can report it to the eSafety Commissioner at esafety.gov.au.

Questions and complaints

Contact the Privacy Officer, VR DIGITAL SOLUTIONS PTY LTD, by email using the button below, or through the Feedback button inside the app. Please tell us what your concern is and how we can reach you.

We will acknowledge a complaint promptly and aim to respond in full within 30 days. If you aren't satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992. You may also have other rights under Australian law, including the statutory action for serious invasions of privacy.

Changes to this policy

We will update this policy when SparkIQ or the law changes, and change the date at the top. If a change affects how we use information we already hold, we will tell parents in the app or by email before it takes effect. Where the law requires, we will ask for your consent again.

For kids, in simple words