SparkPath Privacy Policy

Last Updated: April 13, 2026

This Privacy Policy is effective as of May 13, 2026.

Our Privacy Commitment

SparkPath is committed to the mission of helping people reach their potential.

This mission includes the responsible handling of personal information. In this age of generative AI and other new technology tools, it is especially important to prioritize our students, clients, schools and institutions by putting their needs first. This is why SparkPath is committed to creating purpose-first technology that exceeds industry standards when it comes to privacy. 

In particular:

• We do not sell personal information to third parties.
• We do not use student personal information for advertising or targeted marketing.
• We limit the collection of personal information to what is reasonably necessary to provide our services.
• We implement administrative, technical, and organizational safeguards designed to protect personal information.
• We only share personal information with trusted service providers or institutions as described in this Privacy Policy.

By submitting personal information to SparkPath, you expressly consent to the processing of your personal information in accordance with this Privacy Policy. We are committed to limiting the use of your personal information collected through SparkPath to the purposes described in this Privacy Policy.

Welcome to SparkPath

SparkPath is provided by SparkPath Inc., located at 7984 Décarie Dr, Orleans, ON, Canada, K1C 2C4.

We are committed to protecting your personal information and satisfying all applicable requirements through our compliance with this Privacy Policy. If any translated version of this policy conflicts with the English version, the English version shall prevail.

Who This Policy Applies To

This Privacy Policy applies to individuals who access SparkPath directly, as well as students and users who access SparkPath through a licensed educational institution. References to “you” in this Privacy Policy apply to both individual users and student users, unless otherwise specified.

Why We Collect Your Information

We use your personal information and the content that you upload, submit, store, and send to SparkPath for the purpose of helping you create your successful future.

We process personal information based on user consent, contractual necessity in providing our services, our legitimate interests in operating and improving SparkPath, and compliance with legal obligations.

How We Protect Your Information

SparkPath is committed to protecting the data and content we store on your behalf.

SparkPath uses Google Firebase to support data storage and infrastructure. Firebase maintains compliance with major security and privacy standards, including GDPR. To learn more about their data privacy measures, please visit: https://firebase.google.com/support/privacy

While SparkPath uses commercially reasonable safeguards to protect personal information, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of any information transmitted to or stored within SparkPath.

In the event of a security incident involving personal information, SparkPath will investigate the incident, take appropriate steps to mitigate potential harm, and provide notice to affected users or educational institutions in accordance with applicable legal requirements.

Information Collected Through Technology

When you use SparkPath, we collect information about how you use SparkPath (e.g., the pages you view, the links you click, and other actions you take on SparkPath) and your usage of SparkPath over time. When using SparkPath, our servers automatically collect technical and usage information that may include your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, number of clicks, how you interact with links on SparkPath, pages viewed, and other such information. We may also collect analytics data or use third-party analytics tools to help us measure traffic and usage trends for SparkPath. We do not allow any third-party advertising networks to collect information about the users of SparkPath.

We may collect personal information when you:

• create or update an account
• submit responses, assessments, or other content
• interact with features of SparkPath
• contact us for support
• access SparkPath through an educational institution
• participate in surveys or feedback requests

Categories of Personal Information We Collect

We limit the collection of personal information to what is reasonably necessary to provide and improve SparkPath and to fulfill the purposes described in this Privacy Policy.

Depending on how SparkPath is used, we may collect the following categories of personal information:

• Identifiers, such as name, email address, school affiliation, or account username

• Educational and interest-related information, such as preferences, goals, interests, and other inputs provided to generate personalized recommendations

• User-generated content, including responses entered into text fields and AI-interactive prompts

• Account information, such as login credentials and profile settings

• Usage data, including browser type, device information, IP address, and interactions with the platform

• Payment information, when applicable, is processed securely through third-party payment providers

• AI-generated outputs, including personalized recommendations created based on user inputs

• Inferences, such as insights, preferences, or characteristics derived from user inputs, interactions, and AI-generated analysis

SparkPath does not control the specific content that users choose to submit through text fields, uploads, or other platform features.

We collect this information directly from users, from educational institutions that license SparkPath, and automatically through cookies and similar technologies.

Users should exercise caution when submitting personal information through the platform. SparkPath does not require sensitive personal information and discourages submitting it in free-text fields.

Payment Information

If you purchase SparkPath services directly, payment information is processed by third-party payment processors. SparkPath does not store full credit card numbers. Payment processors handle your payment information in accordance with their own privacy policies and security standards.

AI-Powered Recommendations

SparkPath uses artificial intelligence technology to generate personalized recommendations, including career paths, job suggestions, learning options, and company recommendations.

To provide these services, we process information you submit, including interest data, location, learning preferences, job interests, employer interests, and free-text responses. This information is transmitted for processing on our behalf and is returned to SparkPath to generate your recommendations. This processing may involve third-party service providers acting on our behalf. 

Both the information you submit for AI processing and the AI-generated outputs are stored as part of your account data and retained for the life of the account, unless deleted in accordance with this Privacy Policy.

AI-generated recommendations are automated and may not be accurate, complete, or appropriate for every individual user.

SparkPath uses automated processing to generate personalized recommendations. These recommendations do not constitute legally binding decisions, educational placement decisions, employment decisions, or professional advice.

Users should not submit sensitive personal information, including but not limited to health information, racial or ethnic origin, religious beliefs, sexual orientation, or financial information in free-text fields. If submitted, such information may be processed and stored as part of your account data. 

We take reasonable steps to work with providers that are aligned with applicable privacy and data protection standards. However, the way these providers process data may be governed by their own terms and privacy practices.

We do not use your personal information to train our own AI models without providing clear notice and, where required, obtaining consent.

Due to the nature of AI-powered systems, certain processed data may persist in logs or system backups for a limited period of time, even after deletion requests, subject to applicable law.

How We Share Your Information

We may permit certain trusted third parties to track usage, as well as analyze data such as the source address that a page request is coming from, your IP address or domain name, the date and time of the page request, the referring website (if any), and other parameters in the URL. This is collected in order to better understand usage of SparkPath, and enhance the performance of services to maintain and operate SparkPath.

We may use third parties to host portions of SparkPath’s delivery infrastructure, operate various features of SparkPath, store content, send emails, and store and analyze data.

We may also share information about you in connection with a merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.

In such transactions, personal information will remain subject to protections consistent with this Privacy Policy, and users will be notified where required by applicable law.

We provide certain user inputs to third-party services for the purpose of generating AI-powered recommendations. The third-party services process this information on our behalf and we retain both inputs and outputs in our system.

Third-Party Services

The information we collect and store on your behalf may be provided to third parties that deliver additional services related to the purpose of creating your successful future. 

When SparkPath is provided through an educational institution, certain optional features or third-party integrations may be enabled at the request and approval of the institution. SparkPath also uses third-party service providers to operate, maintain, and improve the platform for both institutional and direct users. 

A list of significant third-party service providers may be provided upon request.

SparkPath may contain links to websites or services operated by third parties. These websites operate independently from SparkPath and have their own privacy policies. We are not responsible for the privacy practices or content of third-party sites and encourage users to review the privacy policies of any external sites they visit.

How We Use Your Information

We do not sell or rent the personal information you submit through SparkPath. Nor do we disclose or provide any of the personal information or content you provide to third parties for any purpose except as described in this Privacy Policy.

In addition, we do not use, sell, or rent your personal information or the content you provide for the purpose of advertising.

We may disclose your information in certain special cases, including the following:

• We are required to do so by law or as ordered by a court
• To investigate a possible violation of our Terms of Use
• To resolve a technical problem
• When directed to do so by an educational institution that has licensed SparkPath
• To establish, exercise, or defend legal claims and protect the rights, property, or safety of SparkPath, our users, or others

In the future, our goal is to use non-personal, de-identified, and aggregate information to help educational institutions and companies better understand the challenges that students want to work on.

SparkPath will not use personal information for purposes that are materially different from those described in this Privacy Policy without providing notice and obtaining consent where required by applicable law.

If you access SparkPath directly, we may send you service-related communications and, where permitted by law, information about product updates or new offerings. You may opt out of non-essential communications at any time.

De-Identified and Aggregated Information

We may de-identify or aggregate personal information so that it can no longer reasonably be linked to an identifiable individual (“De-Identified Information”). De-Identified Information is not considered personal information and may be used for research, analytics, product improvement, reporting, and other lawful purposes.

We will not attempt to re-identify De-Identified Information except as permitted or required by law.

Your Choices About Your Information

Information provided by schools and districts is controlled by the educational institution. SparkPath is not responsible for the privacy or data practices of educational institutions, which may differ from those described in this Privacy Policy. 

If you have any questions about reviewing, modifying, or deleting the personal information they have provided us, please contact your educational institution directly.

Educational institutions may update account information and modify SparkPath by signing in to the administrator account.

When SparkPath is provided through an educational institution, the institution acts as the data controller and SparkPath acts as a service provider or data processor on its behalf.

When individuals access or purchase SparkPath services directly, SparkPath Inc. acts as the data controller and is responsible for determining how and why personal information is processed.

Users are responsible for maintaining the confidentiality of their account credentials, including usernames and passwords, and for restricting access to their devices. SparkPath is not responsible for unauthorized access resulting from a user’s failure to safeguard account credentials.

You may request changes or deletions to personal information and content you provide by emailing us at jp@mysparkpath.com. We will respond to your request, when permitted by law, within 30 days.

Data Retention

For active accounts, SparkPath retains personal information, including AI-generated content and related inputs, for the duration of the account unless deletion is requested by the individual, the educational institution, or otherwise required by law.

Following termination or deactivation of an educational institution’s account, SparkPath will retain your information for a period of 90 days. Should the educational institution decide to renew their contract within this 90-day period, your account and all related information will be restored. At the end of 90 days, all of your information will be permanently deleted.

At any time upon termination of an agreement or otherwise at their discretion, an educational institution can request we delete all student data. We will follow these instructions within 30 days of receipt.

After deletion of your data, we may maintain anonymized or aggregated data, including usage data, for analytics purposes only.

We periodically review inactive accounts and may delete or de-identify personal information associated with accounts that have not been accessed for an extended period of time, subject to legal, contractual, and operational requirements.

International Data Transfers

SparkPath is a Canadian company, and your personal information may be processed and stored in Canada, the United States, or other jurisdictions where we or our service providers operate.

These jurisdictions may have data protection laws that differ from those in your country of residence.

When we transfer personal information across borders, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with applicable privacy laws.

For individuals located in the European Economic Area (EEA), the United Kingdom, or other regions with data transfer restrictions, these safeguards may include:

• entering into Standard Contractual Clauses approved by the European Commission or UK authorities
• relying on adequacy decisions issued by relevant regulators
• implementing additional contractual, technical, and organizational measures where required

By using SparkPath, you acknowledge that your personal information may be transferred to and processed in countries outside of your country of residence, including countries that may not provide the same level of data protection.

Where required by law, we will obtain your consent to such transfers or provide alternative safeguards to ensure your rights and protections are maintained.

Cookies and Tracking Technologies

SparkPath uses cookies and similar technologies for essential platform functionality, analytics, and user experience improvement. These technologies may collect technical information such as IP address, device type, browser type, pages visited, session duration, and interaction data.

We use third-party analytics providers, such as Google Analytics and Hotjar, to better understand how users interact with our platform. These providers may set their own cookies and process information in accordance with their respective privacy policies.

Where required by applicable law, we obtain user consent before placing non-essential cookies. Users may manage cookie preferences through their browser settings or, where available, through in-platform cookie consent tools.

Personal Information of Children

SparkPath is not intended for direct use by children under the age of 13 without parental consent. Individuals under 13 may only access SparkPath through a licensed educational institution that has obtained appropriate parental consent. If we become aware that we have collected personal information directly from a child under 13 without appropriate consent, we will take steps to delete such information.

Student accounts are created under the direction of educators at a licensed educational institution. Only educators with an educational interest in a student have access to that student’s personal information and content.

In the United States, we are required under the Children’s Online Privacy Protection Act (“COPPA”) to obtain verifiable parental consent in order to collect, use, or disclose personal information from children under the age of 13. As provided for by COPPA, SparkPath relies upon the educational institution to obtain parental consent for the online collection of personal information from children who are students of the educational institution.

When SparkPath provides services to schools or educational institutions, we may process student information on behalf of the institution. In such cases, the school or district remains the data controller for purposes of applicable education privacy laws, including the U.S. Family Educational Rights and Privacy Act (FERPA), and SparkPath acts as a service provider.

SparkPath does not knowingly collect personal information directly from children under 13 without appropriate school authorization or parental consent, as required under applicable law, including the Children’s Online Privacy Protection Act (COPPA).

Additional Rights for U.S. State Residents

Residents of certain U.S. states, including California, Virginia, Colorado, Connecticut, and Utah, may have additional privacy rights under applicable state laws. These rights may include:

• The right to know what personal information we collect, use, and disclose

• The right to request access to or correction of personal information

• The right to request deletion of personal information, subject to certain exceptions

• The right to obtain a portable copy of personal information

• The right to opt out of certain types of data processing, where applicable

SparkPath does not sell personal information as defined under applicable state privacy laws. To exercise any applicable rights, please contact us at jp@mysparkpath.com.

Changes to Our Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform functionality. When material changes are made, we will update the “Last Updated” date. 

Where appropriate or required by law, we may provide notice of material changes to SparkPath users or educational institutions. Users are responsible for keeping their account contact information up-to-date.

Educational institutions that license SparkPath for their students will be notified by email of material changes at least 30 days prior to any changes.

In the event of a sale, merger, or transfer of all or part of our business, users will be notified and given an opportunity to opt out where required by law.

How to Contact Us

If you have any questions regarding this Privacy Policy, please email us at jp@mysparkpath.com.