Privacy Policy

SparkEd is a learning platform that helps high school learners connect their daily studies to a specific career destination. SparkEd is operated by Scalevine (Pty) Ltd (“Scalevine”, “we”, “us”, “our”), a company registered in South Africa.

When you use SparkEd, Scalevine is the responsible party (data controller) for your personal information under the Protection of Personal Information Act, 2013 (“POPIA”).

Our contact details:

• Postal address: P O Box 699, Ferndale, Randburg, South Africa, 2160
• Information Officer: Stanford Chabayanzara
• Email: stanford@scalevine.co.za

You can contact our Information Officer at any time about your personal information, including to ask questions about this policy, request access to your data, ask for corrections, or ask for your data to be deleted.

This policy explains:

• What personal information we collect and why
• How we protect learners under 18 through parental consent
• Who we share your information with
• How long we keep your information
• Your rights under POPIA and how to exercise them

This policy applies to everyone who uses SparkEd, including learners, parents and guardians, teachers, and school administrators.

When you create a SparkEd account, we collect:

• Your first name and last name
• Your email address
• Your date of birth (used to determine whether parental consent is required)
• Your school name, country, curriculum, current form or grade, and term
• Your career goals and the subjects you are studying
• Your academic results (when you record them in Term Navigation Reports)
• Your interactions with Ask Spark, our AI study assistant
• Payment reference information when you pay for individual access (we do not store full card details — payment is processed by Paystack)

For learners under 18, we additionally collect:

• The first name, surname, and email address of a parent or guardian, who must give consent before the learner can use the platform

We do not use tracking cookies, third-party analytics, advertising pixels, or any other behavioural tracking on our website or platform.

We collect personal information for the following purposes:

1. To provide the SparkEd service. Your name, school details, subjects, and career goals allow us to generate your personalised study plans, term reports, university matches, and Ask Spark conversations.
2. To verify parental consent for learners under 18, as required by POPIA.
3. To communicate with you about your account, including consent emails and (in future) password reset emails.
4. To process payments when a learner subscribes to individual Ask Spark access.

We will not use your personal information for any purpose other than those listed above without telling you first.

We do not send marketing emails, newsletters, or promotional communications. Resend, our email provider, is used only to send essential account emails (parental consent requests, account confirmation, and password resets).

Under POPIA, the personal information of children under 18 may only be processed with the consent of a competent person — usually a parent or legal guardian.

When a learner signs up, we ask for their date of birth.

If the learner is 18 or older, the account is created normally. No parental consent is required.

If the learner is under 18, we follow this process:

1. We ask the learner to provide the email address of a parent or guardian.
2. We send the parent or guardian an email explaining that the learner has signed up for SparkEd and asking for consent.
3. The learner cannot sign in to SparkEd or access any learning content while consent is pending. They are shown a screen explaining that we are waiting for parental approval.
4. The parent or guardian clicks a secure link in the email and chooses either “I give permission” or “I don’t give permission”.
5. If consent is given, the learner can sign in and start using SparkEd.
6. If consent is declined, the learner’s account and all associated personal information are immediately and permanently deleted from our systems.
7. If the parent or guardian does not respond within 14 days, the consent link expires, the learner’s account is automatically deleted, and the learner can sign up again with a new consent request if they wish.

A parent or guardian who has given consent and later wishes to withdraw it can contact our Information Officer at stanford@scalevine.co.za. We will delete the learner’s account and personal information within a reasonable time of receiving the request.

Your personal information is stored on Supabase (operated by Supabase Inc.), which uses industry-standard encryption in transit (TLS) and at rest (AES-256). Access to your information is restricted by row-level security policies that prevent users from seeing each other’s data.

We require strong passwords for all accounts and do not store passwords in plain text — Supabase handles password hashing using bcrypt.

While we take reasonable steps to protect your information, no online service can guarantee absolute security. If a security incident affects your personal information, we will notify you and the Information Regulator as required by POPIA.

SparkEd uses the following third-party operators (data processors) to deliver the service. Each operates under a data processing agreement with Scalevine and is required to keep your information confidential and use it only for the purposes we specify.

• Supabase — hosts our database and authentication system. Located in the United States.
• Vercel — hosts the SparkEd website and application. Located in the United States.
• Resend — sends our consent and account emails. Located in the United States.
• Anthropic — provides the AI model (Claude) that powers Ask Spark and our Career Discovery feature. Located in the United States. Conversations with Ask Spark are processed by Anthropic in real time but are not used by Anthropic to train its models.
• Paystack — processes payments for individual Ask Spark subscriptions. Located in South Africa and Nigeria.

Some of these operators are located outside South Africa. By using SparkEd, you consent to your personal information being processed in these jurisdictions. We have satisfied ourselves that each operator provides an adequate level of protection for personal information.

We do not sell, rent, or trade your personal information to anyone for any purpose.

We may disclose your personal information if we are legally required to do so — for example, in response to a court order or a lawful request from a regulator.

• Active accounts: we keep your information for as long as your account is active.
• Pending under-18 accounts: deleted automatically 14 days after signup if parental consent is not received.
• Declined under-18 accounts: deleted immediately when the parent or guardian declines consent. No data is retained.
• Deleted accounts: when you ask us to delete your account, we remove your personal information from our active systems within a reasonable time. Some information may persist in encrypted backups for up to 90 days before being permanently overwritten.
• Payment records: where we are required by South African tax law to retain transaction records, we keep payment reference numbers for the period required (typically 5 years), but no other personal information is retained for this purpose.

You have the following rights in relation to your personal information:

• The right to be told what personal information we hold about you.
• The right to access that information.
• The right to correct information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully.
• The right to ask us to delete information that is no longer needed for the purpose it was collected for.
• The right to object to the processing of your personal information.
• The right to withdraw consent at any time, where we are processing your information on the basis of consent.
• The right to complain to the Information Regulator (see below).

To exercise any of these rights, contact our Information Officer at stanford@scalevine.co.za. We will respond within a reasonable time and at no charge.

If you believe we have not handled your personal information in line with POPIA, you can lodge a complaint with the Information Regulator of South Africa:

• Website: https://inforegulator.org.za
• iSupport platform: https://inforegulator.org.za (the Regulator’s preferred channel for complaints)
• Telephone: 010 023 5200 or 08000 17 160 (toll-free)
• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

We would prefer the chance to address your concern first, so please consider contacting our Information Officer before approaching the Regulator. But you are free to go directly to the Regulator at any time.

We may update this policy from time to time as the SparkEd service evolves. The “Last updated” date at the top will tell you when the policy was last changed. For significant changes, we will notify users by email.

If anything in this policy is unclear, or if you want to know more about how your personal information is handled, please contact us:

• Information Officer: Stanford Chabayanzara
• Email: stanford@scalevine.co.za
• Post: P O Box 699, Ferndale, Randburg, South Africa, 2160