Privacy Policy

Spark Lit ("we", "us") is a tutoring service operated as a division of IO IT Services Corporation, an Ontario corporation. This policy explains how we collect, use, and protect personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). It is organized around the ten fair-information principles that PIPEDA is built on.

What sets us apart: we do not use advertising trackers, remarketing pixels, or behavioral ad networks — on our website or anywhere else. We never sell or rent personal information, and we never share children's information for marketing of any kind. Our website analytics are cookieless and cannot identify you.

Principle 1 — Accountability

We are responsible for all personal information in our possession, including information handled by service providers on our behalf. Accountability rests with our Privacy Officer, reachable at [email protected]. Service providers are selected only where they provide a comparable level of protection for your information.

Principle 2 — Identifying purposes

We collect personal information only to:

• schedule, deliver, and improve tutoring sessions;
• communicate about bookings, progress, and account matters;
• process payments and issue receipts;
• maintain student learning records and progress notes;
• meet legal, tax, and accounting obligations.

We do not use your information for advertising, profiling, or any purpose beyond operating the tutoring service.

Principle 3 — Consent

We collect, use, or disclose personal information only with knowledge and consent, except where permitted by law. You may withdraw consent at any time, subject to reasonable notice; we will explain what withdrawing means for the services we can continue to provide.

Children's information and parental consent. We provide services to minors. Accounts, bookings, and any information about a student under 18 must be provided by a parent or legal guardian, who consents on the student's behalf. We collect only what is needed to deliver tutoring — typically first name, grade, subjects, and learning notes. If a parent or guardian learns that a child provided us information directly without consent, contact us and we will delete it. We never share children's information with third parties for marketing or advertising purposes.

Principle 4 — Limiting collection

We collect only what the purposes above require, by fair and lawful means. Typically that is: parent/guardian contact details (name, email, phone), student learning information, scheduling details, and payment confirmations. Payment card numbers are handled entirely by our payment processor and never touch our systems. Our website uses cookieless, privacy-respecting analytics that cannot identify or trace individual visitors.

Principle 5 — Limiting use, disclosure, and retention

Personal information is used only for the purposes identified at collection and is never sold or rented. We disclose it only to service providers that help us operate, each limited to what their function requires:

• Cloudflare — website hosting, security, and email routing;
• Cal.com — session scheduling;
• Stripe — payment processing;
• Resend — transactional email delivery;
• MongoDB Atlas — secure database hosting;
• Google — optional sign-in to our portal, if you choose it.

Storage outside Canada. Some of these providers store information on servers located outside Canada (primarily the United States). Information stored there may be subject to the laws of that jurisdiction. We require all providers to protect personal information to standards consistent with this policy and applicable Canadian privacy law.

We keep personal information only as long as needed for the purposes above or as law requires (for example, financial records for tax purposes), after which it is securely deleted or anonymized. Student records are deleted on request once a family is no longer enrolled, subject to legal retention requirements.

Principle 6 — Accuracy

We keep personal information as accurate, complete, and current as its use requires. Tell us about corrections at any time and we will update our records and notify any service provider holding the affected information where appropriate.

Principle 7 — Safeguards

We protect personal information with safeguards appropriate to its sensitivity: encryption in transit (TLS) on all our systems, encryption at rest in our database, access on a need-to-know basis, passwordless or multi-factor-protected accounts, and secure disposal. Children's information is treated as sensitive and held to the highest of these standards. No internet transmission is perfectly secure, but we monitor security developments and reassess our measures on an ongoing basis.

Principle 8 — Openness

This policy is publicly available and written to be understandable. Questions about our practices — including what types of information we hold and how they are used — can be directed to the Privacy Officer at [email protected].

Principle 9 — Individual access

On written request and verification of identity, we will tell you whether we hold personal information about you or your child, provide access to it, explain how it has been used, and list anyone it has been disclosed to. We respond within 30 days at no cost in most cases. If you show that information is inaccurate or incomplete, we will correct it and pass the correction to any third party that holds it.

Principle 10 — Challenging compliance

Complaints or challenges about our handling of personal information can be addressed to the Privacy Officer at [email protected]. We investigate all complaints and, where justified, fix our practices. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

Changes to this policy

We may update this policy as our services evolve. If a change would materially expand how we use or disclose personal information, we will notify affected individuals and give them the opportunity to withdraw consent before the change applies to them.

This policy reflects our current practices and is reviewed periodically, including with professional advisors as the service grows.