Privacy

1. Who we are

EarnSparky is an app where children practise and Parents manage learning activities, screen-time rewards and Parent Reports.

Operator: [Legal operator name and registered trading name]
KVK: [Registration number]

For privacy questions, contact [email protected].

Updated in this version

2. Your Family, accounts and paired devices

“Family”, “Parent”, “Child” and “Device” are terms we use to describe how the app is organized, not real names. A Family account brings together the people and paired devices using EarnSparky, under the supervision of a Parent or another authorized caregiver.

Family, Parent and Child names are not stored as readable text on our servers or included as identity fields in AI report requests. Identity details are protected by encryption on paired devices; encrypted labels may also be processed by the backend to support account and pairing features. When a Parent chooses to share Insights, we temporarily store an encrypted copy of the Family, sharing Parent’s and Children’s display names, as explained below. Ages are not included in shared Insights.

The only personal contact detail we store is the Parent’s email address, used for account authentication and responding to requests. We also store technical account and device connections, learning results and reports needed to provide the service; the learning and report records use technical identifiers rather than name or age fields.

3. Learning activities

When a child practises, we store their answers, activity results and learning history. We use this information to evaluate answers, provide learning activities, process screen-time rewards and give Parents insight into practice.

4. Personalized practice

EarnSparky uses learning results to adjust the difficulty of future activities. As a child answers more questions correctly, practice can become more challenging.

5. AI-generated Parent Reports

We use artificial intelligence (AI) to turn recent learning activities into short, actionable summaries for Parents. The service receives relevant learning statistics and evidence about practice questions and answers. It does not receive names, ages, email addresses or other directly identifying personal details.

The summary is saved as a Parent Report and shown to the Parent. It may contain mistakes and is not a diagnosis or a replacement for professional educational advice.

Updated in this version

5a. Optional shared Insights

A Parent can create a read-only link for Insights covering all Children in their Family account. Anyone with the complete link can open it without an account. Recipients can see the shared Family, sharing Parent’s and Children’s display names, avatars, learning summaries, recent activities, and quiz questions, submitted and correct answers, explanations and associated images or audio. The link does not provide account-management access.

The app encrypts the display names with a fresh key for each link, separate from the Family’s encryption key. We store the encrypted names, a hash of the access token, technical Family and creating-Parent identifiers, encryption metadata, and creation, expiry and any revocation timestamps. The decryption key is carried in the link’s URL fragment and used in the recipient’s browser, rather than sent in requests to our API. The names reflect the time of sharing; learning information can update while the link remains active.

The viewer temporarily keeps link credentials, including the decryption key, in the browser tab’s session storage so the view can survive a reload. The viewer clears that stored session when it detects expiry. A copied original link can still be reopened before expiry; closing the browser tab does not revoke the link.

Access expires one hour after link creation, even if a recipient has not opened it. The backend checks expiry on requests. An hourly cleanup job removes expired link records, including the encrypted name copy, from the active database; cleanup may occur after access has already ended. This does not delete the underlying Family learning records. Backups and technical logs follow the retention rules below.

Recipients may forward the link or retain screenshots or other copies. Expiry cannot erase information already received or make those copies unreadable. Share only with trusted recipients and only where you are authorized to share the Children’s information.

6. Screen time and device status

We process configured screen-time rules and relevant status information from paired Companion devices. This supports rewards and restrictions and helps check whether the required device settings are working.

7. Subscriptions

Apple processes App Store purchases. Through RevenueCat, we process subscription products, transaction identifiers, subscription status and access periods. This information is associated with the Family account and determines which features and how many Learning Programs are available.

We do not receive payment-card or bank-account details from Apple. RevenueCat also processes subscription information for subscription and revenue reporting.

8. Notifications

We use an installation identifier and notification token to deliver push notifications to the correct device through Firebase Cloud Messaging, for example when a new report is available.

9. Our legal bases for processing

This draft proposes the following purpose-specific bases, subject to review before the policy takes effect:

• Parent accounts and subscriptions: performance of our agreement with the Parent, where processing is necessary to provide and manage the requested service.
• Updated in this versionProfile-linked learning, personalized practice and Parent Reports: our legitimate interests in providing a useful Parent-managed learning service and giving Parents insight into practice. This requires a necessity and balancing assessment that gives particular weight to children’s rights. Using technical identifiers instead of readable names or ages in learning records and AI requests is one safeguard, not an exemption from data-protection law.
• Updated in this versionParent-requested Insights sharing: performance of our agreement for the Parent’s request to create and deliver a link, and legitimate interests in enabling authorized caregivers to share relevant learning information. The processing of Children’s information requires a necessity and balancing assessment and any additional consent required by applicable law. A Parent’s click to share is not a substitute for those requirements.
• Security, device operation and support: legitimate interests in protecting accounts, operating the service reliably and responding to requests, or performance of the Parent’s agreement where the processing is necessary for that service.
• Legally required records: compliance with applicable legal obligations, such as accounting requirements.

You can object to processing based on legitimate interests by emailing [email protected]. We will assess your request and weigh your privacy interests against our reasons for processing, as required by applicable law. Where processing relies on your consent, you can withdraw that consent through the same email address. We will then stop the processing covered by that consent. Withdrawal does not affect the lawfulness of processing carried out before it was withdrawn. If we stop processing information that is necessary for a particular feature or for providing the service, that feature or the app may no longer work for your account. We will explain any such consequences when handling your request.

10. Our service providers

We work with specialist providers:

• Supabase: sign-in, database and backend processing.
• RevenueCat: subscription management and reporting.
• Firebase Cloud Messaging: push notifications.
• OpenAI: generating Parent Reports.
• Updated in this versionCloudflare: hosting and delivering our website, shared Insights viewer and learning media.
• Apple: app distribution and App Store purchases.

Providers receive the information needed for their role. Some also process information for their own purposes, such as payment administration, security or service reporting, under their applicable terms and privacy notices.

OpenAI’s published API policy states that API inputs and outputs are not used for model training by default, unless the customer opts in. We configure report requests with response storage disabled. This is not a guarantee of zero retention: OpenAI’s standard abuse-monitoring logs may retain content for up to 30 days, with longer retention in the circumstances described in its policy.

Providers may process information outside the European Economic Area. Such transfers require applicable safeguards, such as an adequacy decision or Standard Contractual Clauses, and appropriate processing agreements where required. We do not claim that all processing takes place in the EU. Contact us for information about the arrangements applicable to your data.

Provider information: Supabase, RevenueCat, Firebase, OpenAI API data controls, Cloudflare and Apple.

11. Retention and deletion

Cancelling or downgrading a subscription does not automatically delete programs, associated learning activities or reports. Programs beyond a lower plan’s limit remain stored; a higher plan can make them available again.

Cancelling a subscription and requesting deletion of information are separate actions.

One-year inactive-account policy: we intend to retain the Family account, its program assignments, learning history and Parent Reports while the Family uses the service or has an active subscription or access grant. After that, the retention period is one year from the later of the Family’s last activity or the end of its subscription/access grant. This allows a Family to return without immediately losing its history. At the end of that period, these records are to be deleted or irreversibly anonymized. Background technical messages alone do not count as Family activity.

You can request account and associated learning-data deletion earlier by emailing [email protected]. We may need to verify that you are the Parent authorized to act for the Family. We will explain any records that must be retained and the reason. Account deletion does not cancel an Apple subscription; manage that separately through Apple.

Notification tokens are retained while needed to deliver notifications and removed when no longer needed. Technical logs and support correspondence are retained only as necessary for security, troubleshooting and handling requests. Records required for legal obligations or a specific dispute may need to be retained longer, with use restricted to that purpose.

Deleted information may remain in restricted backups until those copies expire under the applicable backup schedule. Provider-controlled security and transaction records follow the provider’s applicable retention rules and legal obligations; the one-year rule is not a promise that every provider record is erased on the same date.

12. Security

Updated in this versionWe use technical access controls to restrict information to authorized accounts and processes, including holders of an active sharing link for the limited read-only view. Identity details are encrypted on paired devices; the display names stored for sharing are encrypted with a separate per-link key. Anyone holding the complete link also holds the means to display those names. No system can guarantee complete security.

13. Your privacy rights

Depending on the circumstances, you may request access, correction, deletion, restriction or portability of personal data. You may object to certain processing. Where we rely on consent, you can withdraw it.

We may ask for information to verify your authority to make a request. We normally respond within one month. If a permitted extension is necessary, we will explain it within that month.

You can also complain to the Dutch data-protection authority, the Autoriteit Persoonsgegevens, or another competent supervisory authority.

Email [email protected] with your request and enough account information for us to locate the relevant Family. Tell us if you are acting on behalf of a child. Do not send passwords or identification documents unless we explain why additional verification is necessary and how to provide it safely.

14. Our website

Updated in this versionOur website contains no advertising or analytics scripts of our own. It includes informational pages and the shared Insights web viewer. Cloudflare processes connection information to deliver and secure the website and media; Supabase handles the viewer’s authorized requests for shared learning information.

Connection information can include an IP address, browser information and technical request details. Cloudflare may use security technologies, including cookies where applicable to its protections. Its processing is described in the Cloudflare Privacy Policy. We do not use this website to track visitors across other companies’ websites for advertising.

15. Changes and questions

We update this policy when our practices change and notify users of important changes where required. A policy update does not itself authorize a new use of information without an appropriate legal basis.

For questions, email [email protected]. This version remains a draft and has no effective date until the operator details, review and implementation prerequisites are resolved.