Privacy Policy

1. Introduction

SparkMinds, operated by TwinAI Inc. (“we,” “us,” or “our”), is committed to protecting the privacy of our users, especially children. This Privacy Policy explains how we collect, use, disclose, and protect information when you use our website and services.

We comply with the Children's Online Privacy Protection Act (COPPA) and take additional precautions when handling data related to children under 13.

2. Information We Collect

From Parents/Guardians:

• Full name, email address, phone number
• Mailing address
• Payment information (processed securely by Stripe — we do not store credit card numbers)
• Account login credentials (password is hashed and encrypted)

About Students (Provided by Parents):

• Child's name, date of birth, grade level, school
• Medical information: allergies, medications, medical conditions
• Emergency contact information
• Doctor's name and phone number

Automatically Collected:

• Browser type and version
• IP address (anonymized)
• Pages visited and time spent on our website
• Referring website

3. How We Use Your Information

• Registration & enrollment: Process camp registrations and manage student enrollment.
• Payments: Process payments, refunds, and send receipts.
• Safety: Ensure student safety using medical and emergency contact information.
• Communication: Send camp confirmations, reminders, updates, and waitlist notifications.
• Improvement: Analyze website usage to improve our services.
• Legal compliance: Meet legal obligations, including Massachusetts youth program requirements.

4. COPPA Compliance (Children Under 13)

• We do not collect personal information directly from children under 13.
• All student information is provided by a parent or legal guardian during registration.
• We require verifiable parental consent before collecting any child's information.
• Parents may review, modify, or request deletion of their child's information at any time by contacting us.
• We do not condition a child's participation on the collection of more information than is reasonably necessary.

5. Information Sharing

We do not sell, trade, or rent personal information to third parties. We may share information with:

• Stripe: For secure payment processing only.
• Email service provider: For sending transactional emails (confirmations, receipts).
• Camp instructors: Limited student information necessary for safety (medical info, emergency contacts).
• Legal authorities: When required by law or to protect the safety of our students.

6. Data Security

• All data is transmitted over HTTPS (SSL/TLS encryption).
• Passwords are hashed using industry-standard algorithms.
• Payment information is handled entirely by Stripe (PCI DSS Level 1 compliant).
• Database access is restricted and protected by authentication.
• We regularly review our security practices.

7. Data Retention

• Account data is retained as long as your account is active.
• Payment records are retained for 7 years for tax and accounting purposes.
• You may request deletion of your account and associated data at any time.
• Upon account deletion, we will remove personal data within 30 days, except where retention is required by law.

8. Your Rights

You have the right to:

• Access the personal information we hold about you and your child.
• Correct inaccurate information.
• Request deletion of your data.
• Opt out of promotional communications.
• Withdraw consent for data collection at any time.

9. Cookies

We use essential cookies for authentication and session management. We do not use third-party tracking cookies. Analytics data is collected anonymously.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The latest version will always be available on this page.

11. Contact Us

For privacy-related questions or to exercise your rights, contact us at: hello@spark-minds.ai

TwinAI Inc.
Belmont, MA