Privacy Policy

1. Introduction

Sparq Academy (the "Platform") is operated by Sparq IT Services (India) ("we", "us", or "our"), operating from Lucknow, Uttar Pradesh, India. We are committed to protecting your personal data in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and other applicable Indian privacy laws.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use our Platform at https://www.sparqacademy.in. It covers all three ways you can engage with us:

• Self-paced online courses and bundles — purchased individually through the Platform.
• Membership subscriptions — recurring monthly or annual access to the course library.
• Offline coaching programmes — in-person classroom batches delivered at our Lucknow office.

Please read this policy carefully before registering, submitting an enquiry, or making a purchase.

2. Data We Collect

We collect the minimum personal data necessary to provide our services.

2.1 Account and platform data

• Identity Data: Full name and profile picture (obtained via Google OAuth on sign-up).
• Contact Data: Email address (used for account communication and course access notifications).
• Payment Data: Transaction IDs, subscription IDs, and payment status. We do not store card numbers, UPI IDs, or bank details — these are handled exclusively by Razorpay, our PCI-DSS-compliant payment processor.
• Usage Data: Course enrolment records, lesson progress, certificates earned, wishlist items, and login timestamps (stored securely in Supabase).
• Technical Data: IP address, browser type, and device information collected automatically for security and analytics purposes.
• Communications: Any messages, queries, or feedback you send us via our contact form, email, or WhatsApp.
• Newsletter Data: Your email address, if you voluntarily subscribe to our newsletter.

2.2 Offline coaching enquiry data

When you submit an enquiry for an offline coaching programme, we collect the information you enter in that form so that our counselling team can call you back:

• Name and mobile number (mandatory — your mobile number is how we reach you to schedule your free counselling session).
• Email address (optional).
• Programme of interest, your current education or work status, your experience level, your career goal, and your preferred time slot — all optional, and used only to make the counselling conversation useful to you.
• Enquiry status and internal counselling notes recorded by our team as we follow up with you.

By submitting a coaching enquiry, you expressly consent to being contacted by us by phone call, SMS, email, and WhatsApp in connection with that enquiry, including where your number is registered on the National Do Not Call registry (NCPR/DNC). You may withdraw this consent at any time by telling our team on the call, or by emailing support@sparqacademy.in.

2.3 Instructor application data

If you apply to teach with us, we collect the details you submit in that application — your name, contact details, professional background, area of expertise, and any links or materials you choose to share — solely to evaluate your application.

2.4 What we never collect

We do not collect biometric data, health data, caste or religious information, government identity numbers (Aadhaar, PAN, passport), or financial information beyond payment confirmation. Please do not send us such information; if you do, we will delete it.

3. Legal Basis for Processing (DPDP Act 2023)

Under the Digital Personal Data Protection Act, 2023, we process your data on the following lawful bases:

• Consent: You provide explicit consent during account registration, when submitting a coaching enquiry, when subscribing to our newsletter, and before purchase.
• Contractual Necessity: Processing required to fulfil your course enrolment or coaching admission, manage your subscription, issue certificates, and deliver our services.
• Legitimate Uses: Security monitoring, fraud prevention, dispute resolution, and improving our Platform.
• Legal Obligation: Where required by Indian law, including tax records and regulatory compliance.

4. How We Use Your Data

Your personal data is used exclusively to:

• Create and manage your account on the Platform.
• Process payments, grant access to purchased courses and bundles, and manage recurring subscription billing.
• Contact you about a coaching enquiry, schedule and conduct your counselling session, and administer your admission, batch allocation, and attendance if you enrol.
• Send transactional emails: course access confirmations, payment receipts, subscription renewal and failure notices, and certificate notifications.
• Respond to support queries and resolve disputes.
• Prevent fraud, abuse, and unauthorised access.
• Comply with applicable legal and regulatory obligations.
• Send product updates or promotional communications (you may opt out at any time via the unsubscribe link in any email, or by replying to ask us to stop).

We do not sell, rent, or trade your personal data to third parties for their marketing purposes.

5. Google OAuth & Third-Party Services

Sparq Academy uses Google OAuth 2.0 for authentication. We request only the openid, profile, and email scopes — your name, email address, and profile photo. We do not request access to your Google Drive, Gmail, Contacts, Calendar, or any other Google service.

Our data sub-processors include:

• Supabase — Database and authentication infrastructure (hosted on AWS, with data residing in data centres selected for GDPR adequacy).
• Razorpay — Payment processing for one-time purchases and recurring subscriptions (PCI-DSS Level 1 certified, operates under RBI regulations).
• Resend — Transactional email delivery.
• Vercel — Web hosting and content delivery.

Each sub-processor is contractually obligated to process data only on our instructions and to maintain appropriate security measures.

If you choose to contact us using the WhatsApp link on our coaching pages, that conversation takes place on WhatsApp infrastructure and is additionally governed by the WhatsApp privacy policy. Using WhatsApp is always optional — you can email or call us instead.

6. Cookies & Tracking

We use strictly necessary cookies to maintain your authenticated session (managed via Supabase SSR), plus a local preference key that remembers your light/dark theme choice. We do not use third-party advertising trackers, Facebook Pixel, or Google Ads conversion cookies on this Platform.

Analytics, if any, is performed using privacy-respecting, aggregated data and does not involve individual user tracking across external sites.

7. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. Specifically:

• Account & Profile Data: Retained for the lifetime of your account and deleted within 30 days of a verified account deletion request.
• Payment & Subscription Records: Retained for 8 years as required under the Companies Act, 2013, the Income Tax Act, 1961, and GST regulations.
• Course Progress Data: Retained for the duration of your account.
• Coaching Enquiries: Retained for 24 months from our last contact with you if you do not enrol, after which the record is deleted. If you enrol, admission details become part of your student record.
• Coaching Student Records: Retained for 3 years after your batch ends, so that we can re-issue certificates and answer verification requests.
• Instructor Applications: Retained for 12 months from the decision date.
• Communication Logs: Retained for 2 years for dispute resolution purposes.

8. Your Rights as a Data Principal (DPDP Act 2023)

Under the Digital Personal Data Protection Act, 2023, you have the following rights:

• Right to Access: Request a summary of the personal data we hold about you.
• Right to Correction: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data (subject to our legal retention obligations).
• Right to Grievance Redressal: Raise a grievance with our Grievance Officer and receive a response within 30 days.
• Right to Nominate: Nominate another individual to exercise these rights on your behalf in the event of death or incapacity.
• Right to Withdraw Consent: Withdraw consent at any time — including consent to be contacted about a coaching enquiry. Note that withdrawal may affect your ability to use certain services.

To exercise any of these rights, email our Grievance Officer at support@sparqacademy.in with the subject line "DPDP Data Request". We may ask you to verify your identity before acting on a request, so that we never disclose your data to someone else.

9. Data Security

We implement industry-standard security measures including HTTPS/TLS encryption for all data in transit, row-level security (RLS) policies in Supabase, and access controls limiting data access to authorised personnel only. Coaching enquiry records and counselling notes are visible only to our administrators. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

In the event of a personal data breach, we will notify affected users and the Data Protection Board of India in accordance with the DPDP Act, 2023.

10. Children and Minors

Sparq Academy accounts and online purchases are intended for individuals aged 18 and above. We do not knowingly collect personal data from a minor without verified consent from a parent or lawful guardian, and we do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.

Where a student under 18 is admitted to an offline coaching batch, admission is completed by a parent or lawful guardian, who provides consent on the student behalf and remains our point of contact for fees and attendance.

If you believe a minor has provided us with personal data without such consent, please contact us at support@sparqacademy.in and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you via email or a prominent notice on the Platform at least 7 days before any material changes take effect.

12. Grievance Officer

In accordance with the Information Technology Act, 2000 and the DPDP Act, 2023, the details of our Grievance Officer are:

Grievance Officer: Admin, Sparq IT Services (India)
Email: support@sparqacademy.in
Address: Office No. 53 UGF, Prime Plaza, Munshipulia Chouraha, Sector 16, Indira Nagar, Lucknow, Uttar Pradesh 226016
Response Time: Within 30 days of receiving a grievance.