1. Information We Collect
We collect information you provide directly to us, such as when you create an account, update your profile, or contact us for support.
2. How We Use Your Information
We use the information we collect to provide, maintain, and improve our services, process transactions, and communicate with you.
WhatsApp Community
If you opt-in to join our WhatsApp founder community, we will use your phone number to add you to our WhatsApp group where you can connect with other entrepreneurs. This is based on your explicit consent, which you can withdraw at any time by leaving the group or contacting us. We only use your phone number for this specific community purpose and do not share it with third parties for marketing purposes.
3. Artificial Intelligence, Subprocessors, and Security Architecture
SparkCoach is built so you can focus on your business while we handle AI responsibly. Our approach combines enterprise-grade model partnerships, contractual protections against training on your content for general model improvement, and architecture that keeps each AI task scoped to the slice of context that step actually needs—including when we use provider-side caching for speed and efficiency. The remainder of this Section 3 describes those measures in a manner intended to be legally operative and transparent.
3.1 Scope; definitions
This Section 3 applies to processing carried out in connection with AI Features of SparkCoach (the “Service”). For purposes of this Section 3, the following capitalized terms apply:
- “User Content” means information you (or users on your account) submit to the Service, including text, selections, structured journey data, chat messages, and other materials processed through AI Features.
- “AI Features” means product capabilities that generate or assist with outputs by transmitting User Content (or derivatives thereof) to one or more Model Providers for processing.
- “Model Providers” means the third-party vendors identified in Schedule A (Section 3.4) that host or supply models used to provide AI Features.
- “No-Training Configuration” means the enterprise- or business-oriented API and subscription arrangements we maintain with Model Providers under which, subject to and as described in each Model Provider’s applicable terms, those providers commit not to use User Content submitted through the Service to train or fine-tune their foundation models for general improvement of models offered to other customers.
Third-party terms. Without limiting Section 7 (Changes to This Policy), the rights and obligations of Model Providers are governed by their respective agreements and trust materials as in effect from time to time. If you enter into a separate written agreement with us that addresses AI subprocessors or security, the terms of that agreement will govern to the extent they expressly conflict with this Section 3.
3.2 No-Training Configuration; training-related use
We configure AI Features to use No-Training Configuration with Model Providers to the extent commercially available and as reflected in our agreements with each Model Provider. Under those arrangements, User Content processed through AI Features is not intended to be used by Model Providers to train or fine-tune underlying models for general improvement, consistent with industry practice for enterprise-oriented AI services.
Subject to each Model Provider’s terms as in effect from time to time, processing may nonetheless include uses expressly permitted or required thereunder, including, without limitation, abuse prevention, security monitoring, compliance with applicable law, and other limited purposes described in the applicable Model Provider documentation.
3.3 Task-scoped processing, orchestration, and caching
Design. As an additional safeguard, the Service employs orchestrated, task-specific processing: work is divided into discrete steps, and where practicable we transmit to Model Providers only the subset of User Content and journey context reasonably necessary for the specific AI Feature invoked—not the entirety of your account or unrelated projects in a single unstructured export.
Caching. Where we use provider-hosted caching (including to reuse context for a particular journey or step and to reduce latency and cost), such caches are created, refreshed, and retained for defined product purposes, scoped to the relevant task and journey context, and operated consistently with the applicable Model Provider’s terms—not as a comprehensive mirror of all data the Service stores about you.
No expansion of scope. Nothing in this Section 3 obligates us to transmit more User Content to a Model Provider than we reasonably believe is required to fulfill the AI Feature you (or your account) initiate.
3.4 Schedule A — Model Providers (AI Features)
The following Model Providers may process User Content in connection with AI Features, depending on configuration and product settings:
- OpenAI, LLC — generative and related model services — documentation: API and data usage policies
- Anthropic, PBC — generative and related model services — documentation: Commercial terms and related notices
- Google LLC (Gemini / Generative Language API) — generative and related model services — documentation: Gemini API terms
International processing. Processing may occur in the United States and in other jurisdictions where Model Providers or their subprocessors operate. Where applicable law requires appropriate safeguards for cross-border transfers, we rely on mechanisms made available by Model Providers (for example, standard contractual clauses or equivalent instruments, as described in their documentation) together with any additional measures agreed in writing between you and us.
3.5 Encryption; security program
We implement technical and organizational measures that include encryption in transit (HTTPS/TLS between your browser and the Service, and TLS-protected connections to Model Providers where supported) and encryption at rest using capabilities provided by our hosting, database, and infrastructure partners, consistent with widely adopted practices for cloud software. Additional security measures applicable to the Service generally are summarized in Section 5 (Data Security).
No absolute guarantee. Notwithstanding the foregoing, no method of transmission or storage is completely secure. We maintain and improve our security program as the Service evolves. For questions regarding how a particular workflow processes User Content, please contact us using Section 10 (Contact Us).
4. Information Sharing
We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as described in this policy.
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Without limiting the generality of the foregoing, additional detail regarding encryption, Model Providers, and security measures applicable to AI Features is set forth in Section 3.5 above.
6. Cookies
We use cookies to enhance your experience on our platform. You can choose to disable cookies through your browser settings.
7. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of any changes by posting the new policy on this page.
8. Your Rights (GDPR)
If you are located in the European Union or United Kingdom, you have the following rights regarding your personal data:
- Right of Access: You can request a copy of the personal data we hold about you
- Right to Rectification: You can request correction of inaccurate personal data
- Right to Erasure: You can request deletion of your personal data in certain circumstances
- Right to Restrict Processing: You can request that we limit how we use your data
- Right to Data Portability: You can request a copy of your data in a structured format
- Right to Object: You can object to certain types of processing
- Right to Withdraw Consent: You can withdraw consent for data processing based on consent (such as WhatsApp community participation)
To exercise any of these rights, please contact us using the details below.
9. Data Retention
We retain your personal data for as long as necessary to provide our services and comply with legal obligations. For WhatsApp community participation, we will retain your opt-in preference until you withdraw consent or delete your account.
10. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us.