Spark by Prixel Labs

Privacy Policy

Effective date: 2nd September 2026
This Privacy Policy is in continuation of the Terms of Service on our Platform (as defined below) and shall be read with the same. Please note that all the capitalized terms used in this Policy and not defined here shall have the same meaning as ascribed to them in the Terms of Service.
PRIXEL LABS, a sole proprietorship registered and operating in India with registered office at 4th Floor, 648/A, Om Chambers, Old Binnamangala Road, Indiranagar, Bengaluru, Karnataka — 560008, India ("PRIXEL LABS", "We", "Us" or "Our") operates Spark, an AI tutoring platform that teaches Maths and Science to school students and enables their parents and legal guardians ("Clients", "You", "Your" or "User") to use the services described in our Terms of Service. These Services are made available to you through our website ‘spark.prixellabs.com’ and the Spark mobile application, which shall be inclusive of any other website, media channel, mobile website or mobile application related, linked or otherwise connected thereto, which is owned by us ("Platform").
This Privacy Policy ("Policy") outlines our practices and policies, the kinds of information we may collect from you when you access or use the Platform, the reasons for and methods of collection, how we use and disclose the information we gather from you for your use of the Platform, as well as the security practices and procedures for safeguarding your privacy in relation to information shared with us. You agree to be bound by the terms and conditions of this Policy by accessing and using the Platform, which will be deemed to create a legal contract between you and PRIXEL LABS.
This Policy must also be read in conjunction with and construed in accordance with all applicable laws of the country from which you access and use the Platform, including the provisions of the (Indian) Information Technology Act, 2000 ("IT Act"), the Digital Personal Data Protection Act, 2023, the EU General Data Protection Regulation, and other similar laws as recognised in your jurisdiction. This Policy is officially recognised as an electronic contract between PRIXEL LABS and you.
We reserve the right to amend, change or update this Policy at our discretion. You agree to be bound by any updated policy with your continued access to and/or use of our Platform and subsequently our Services after any such changes have been duly notified to you in any form. Any such change to the Policy will be notified to your registered email address or registered mobile number with us. We recommend you keep your details active and correct for smooth communication. We will not be liable, in case the registered email or mobile number is inactive, incorrect or not updated, for any claims regarding and not limited to communication gaps, liabilities and legal claims with regard to this Policy.

1. Definitions

In compliance with jurisdictional requirements, we have listed below the terms repeatedly defined and referenced in this Policy.
"Account" shall have the same meaning as has been provided under the Terms of Service. An Account on the Platform is registered and operated by a parent or legal guardian, on behalf of the child who takes the classes.
"Child" or "Student" shall mean the school student for whom the parent or legal guardian registers an Account and who takes the classes delivered through the Platform.
"Non-personal Identification Information" shall include but is not limited to browser name, the type of device and technical information about your means of connection to the Platform such as the operating system, the internet service provider utilised and other similar information used in conjunction with the access or use of the Platform and subsequently the Services available thereof.
"Personal Identification Information" shall include such information as shall be voluntarily shared by you, in any format, whereby such information shall be deemed to ascertain a person’s identity, or can be reasonably ascertained from the information or opinion, including but not limited to when you visit the Platform and conduct any activity whereby you are required to share such information, regardless of whether the information provided is true or not. Further, it shall include but not be limited to the parent’s name, email address, phone number and residential address, and the child’s first name, board, class and chosen interests disclosed by you pursuant to the creation of an Account or the use or access of the Platform and the Services. In the event that you do not consent to share your Personal Identification Information with us, you shall be free to withhold it, but it may prevent us from providing complete and full access to and/or use of the Platform and the Services thereof.
"Sensitive personal data or information" / "SPDI" shall mean information relating to you which, directly or indirectly, is capable of identifying you, including but not limited to: (i) credentials for use of the Platform; (ii) financial information, including payment instrument and mandate details; and (iii) any other information which is considered sensitive personal data or information under the applicable law in your state.
"Third Party" shall refer to any party other than you and PRIXEL LABS.
Non-personal Identification Information, Personal Identification Information and SPDI shall together be referred to as "Information".

2. Information Collected

For access to and/or use of the Services, we have listed below the information we shall collect from you:
Information that you voluntarily provide us: This will include all the information you provide us when accessing and/or using the Platform, which will include but shall not be limited to the information you provide for the creation of your Account — the child’s name, the education board, the class, and the interests you choose during onboarding — along with the parent’s phone number and any additional Information provided during and/or for the provision of Services.
Information collected from Third-Party Sites: You may register for an Account using your existing Google or similar Third Party accounts and log-in credentials (your "Third-Party Site Account"). As part of the functionality of the Platform, you may link your Account with a Third-Party Site Account, either by (i) providing your Third-Party Site Account login information to us through the Platform, or (ii) allowing us to access your Third-Party Site Account, as is permitted under the applicable terms and conditions that govern your use of that Third-Party Site Account. It shall be your responsibility to read and keep yourself updated with the policies of the Third-Party Site Account from time to time.
Payment information: Where you register a UPI Autopay mandate or make a payment for the Services, the payment is processed by an authorised payment gateway. We receive and store only the identifiers and status of the mandate and the resulting charges — never your full card number, UPI PIN, bank credentials or any other authentication factor.
Learning information: We collect the answers, questions and interactions a child produces during a class — the questions asked of the tutor, the responses given, the lessons opened and the progress through them — so that the tutor can teach at the right level and the parent can be told how the child is doing.
Cookie Policy: A cookie is a tiny piece of data that a web server stores on a web browser to read later from that browser. Cookies help the browser remember information that is unique to a particular user. No information that can be used to identify you personally is stored in our cookies. Our cookies aid in extending the functionality of the website and enable more precise usage analysis. Every time you visit our Platform, we check your browser to see if our cookies are present. You may set your internet browser to reject cookies or to notify you when cookies are being used if you would prefer not to receive them; however, turning off cookies will prevent the great bulk of our Platform from working. PRIXEL LABS does not provide Third Party access to any cookie and does not disclose information from cookies to Third Parties except as listed in this Policy.
Sensitive Personal Data or Information ("SPDI"): For the sake of accuracy in providing Services on the Platform, you may additionally be asked to reveal or affirm certain SPDI. Depending on how you engage with the Platform, different types of Information may be gathered from you. PRIXEL LABS promises to protect the information you supply while adhering to reasonable security policies and procedures and all relevant privacy laws.
Aggregated Data: We may perform research on our customers’ demographics, interests, locations and usage patterns of the Services based on the Personal Data and other information submitted to us, in a continuing attempt to better understand and serve Users of the Services. We may aggregate this research and use it for any reason, including sharing the results with our affiliates, agents and business partners. Your personal information is not contained in this aggregate data. We may also disclose aggregated user statistics to describe our Services to existing and potential business partners as well as to other Third Parties for other legitimate objectives.
Device and Usage Information: While you use the Services, we might gather data about your device. Device type, device family, operating system, carrier, unique device id, time zone, browser type, version and language are some examples of this data. We might also keep track of the things you do when using the Services. These details may include the date and time of logins, the features used or visited, and searches conducted through the Services.
Push Notifications: In relation to your Account or the Platform, we might ask to send you push notifications — for example, a reminder about a scheduled class. You can disable these communications in your device’s settings if you prefer not to receive them.
Verification of Information: We may at certain times require you to provide additional information to confirm your identity before granting access to your own Information previously provided to us. Upon your exercise of the right to remove any and all information provided to us by you, we shall ask for additional information for verification purposes.

3. Use of Personal Data and Other Collected Information

PRIXEL LABS adheres to this Policy while using the Personal Data you supply. If you give us personal information for a particular reason, we will use it in connection with that particular reason. For instance, if you email us, we will use the Personal Data you send to get back to you and see if we can resolve the issue.
The Information collected is used, among other things, to create and maintain the Account, to deliver and personalise classes to the child’s board, class and interests, to keep the parent informed about the child’s classes, to process the registration of the UPI Autopay mandate and the subscription charges thereon, to provide support, and to improve the Platform and the quality of the teaching.
Other than as described above, we will notify you when we wish to provide Information about you to any Third Parties and give you the opportunity to choose not to share that Information. You have the option to allow or deny us permission to share such Information with a Third Party, but in the event you deny us such permission, we might not be able to provide the full extent of our Services. It shall be your responsibility to keep us updated and duly informed of any change in your email or mobile number for the receipt of any information as mentioned herein for the purpose of consent.

4. Disclosure of Collected Information

PRIXEL LABS hereby represents that it does not sell, and does not involve itself in businesses related to selling, information. We assure you that any disclosure we do make is encrypted to avoid unauthorised access and leaks and is permissible under applicable data privacy and protection laws. The exceptions are listed as follows:
Business Transfers: Your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with a transaction, and transferred to a successor or affiliate as part of that transaction. Personal Data may be included in the transferred assets in the event of a corporate sale, merger, reorganisation, dissolution or another similar event.
Service Requirements: In order to teach a class that fits the child, PRIXEL LABS uses the child’s Personal Data — the board, the class, the chosen interests and the record of the child’s questions and answers — to select what is taught, to shape the examples used, and to adapt the explanation while the class is running. Where this teaching is generated with the help of Third Party artificial intelligence service providers, only the information necessary to produce the lesson is shared with them under contractual confidentiality and data-protection obligations, and it is not used by them to identify the child or to advertise to the child.
Service Providers: We share Information with the service providers who make the Platform work — hosting and infrastructure providers, payment gateways, communication providers and analytics providers — strictly to the extent needed for them to perform their function for us.
Analytics: We use Google Analytics to understand how the Platform is used — which pages are opened, how far through signing up people get, and which steps they abandon — so we can improve it. Google receives the pages you visited, the actions you took on them, and technical details such as your device, browser, approximate location and how you arrived. Google’s measurement tag additionally detects contact details typed into forms on our site and sends them to Google converted into a one-way code that cannot be read back into the original value; on our booking form that is the phone number you enter, and it may include the child’s name entered beside it. Nothing else about your child — their class, their board, their interests, their class timings, or their questions and answers — reaches Google, and none of this is used to advertise to you or to your child.
Session Recording: We use Microsoft Clarity to record how the booking site is used — the pages opened, where a cursor moved, what was clicked and how far a page was scrolled — so we can see where the site is confusing or broken. What you type into a form is masked in these recordings, though text displayed on the page may be visible in them. To make a recording findable when you contact us about a booking, we also send Clarity your phone number, which Clarity converts into a one-way code rather than storing, together with your child’s first name as a label for the recording. This is the only purpose for which your child’s name is shared with an analytics provider; it is not used to advertise to you or to your child.
Advertising Measurement: When you reach our booking site from an advertisement, we share a limited set of information with Meta Platforms (Facebook and Instagram) so we can tell which advertisements led to a booking. What we share is your phone number converted into a one-way code that cannot be turned back into your number, a similar code for your account, and the advertising identifiers Meta itself sets in your browser.
Never about your child: We never share anything about your child with advertising partners — not their name, their class, their board, their interests or their class timings. Only the parent contact details described above are used for measuring advertisements. Nothing about your child’s learning — their class, their board, their interests, their class timings or their questions and answers — is shared with any analytics or session-recording provider either. Your child’s name is the one exception, and only in the two ways described above: as a label so that a session recording can be found, and where our analytics provider’s tag detects it as a contact detail typed into a form, in which case it is sent as a one-way code.
Requirement under applicable law: The Information may be disclosed to any person if such disclosure is required for a lawful purpose connected with a function or activity of the Platform. The Personal Information may be disclosed where the disclosure is necessary for compliance with a legal obligation under applicable law.
A child’s Information is never sold, and is never used to serve behavioural or targeted advertising.

5. Security

We work hard to protect your information against unauthorised access, unlawful alteration, disclosure or destruction. We also work to maintain its security, integrity and privacy. To protect data and to aid in preventing unauthorised access, we put in place the necessary physical, electronic and managerial safeguards. As no method of data transmission or protection is 100% safe, we cannot guarantee perfect security. Additionally, we are not liable for any security lapses or the acts of any Third Parties who obtain your information due to uncontrollable internal and external factors.
Password protection is a crucial component of the security of your information. You must take care not to reveal your account login information to any other party and must keep your login information, including your password and any one-time passwords, private. You are ultimately in charge of protecting the confidentiality of your Account login details, even though we will do everything we can to ensure the highest level of security for your information. If you suspect someone else knows your password, you discover unauthorised use of your Account, or you become aware of any other security lapse, kindly let us know right away at support@prixellabs.com.
We restrict access to personal information to those of our employees who: (i) need it to fulfil our obligations under this Policy and agreements concluded with us; (ii) have received the necessary and ongoing training on how to process, handle and care for personal information; and (iii) are subject to confidentiality obligations as required by applicable law. We take measures to make sure that any employees who have access to personal data are trustworthy, capable and regularly trained. We also hold documentation regarding compliance.
PRIXEL LABS cannot guarantee security in transfers and transactions of your information through the internet. We suggest you take adequate safety measures to protect your personal information, as information on and through the internet is not fully secure. Any unauthorised use of your personal information or any suspicious activity on your Account is not our responsibility and cannot be held against us. By utilising our Platform, you acknowledge and accept that we are not responsible for any disclosure of your information caused by transmission mistakes or unauthorised acts of Third Parties.

6. Children and Parental Consent

Spark teaches children. The Platform is therefore built on the premise that an Account is always registered, consented to and controlled by a parent or legal guardian who is at least 18 years of age, on behalf of the child who takes the classes.
Registration by an adult only: A child may not register an Account, provide payment details or agree to these policies on their own. By creating an Account you confirm that you are the parent or legal guardian of the child named in it and that you consent, on the child’s behalf, to the collection and processing of the child’s information as described in this Policy.
What we ask about a child: We deliberately collect the minimum needed to teach: the child’s first name, education board, class and chosen interests, and the record of the child’s learning on the Platform. We do not ask a child for their address, their school, their financial details, or any information about their health.
No advertising or profiling of children: We do not use a child’s information for behavioural advertising, do not sell it, and do not build profiles of a child for any purpose other than teaching that child.
Parental control: A parent or legal guardian may at any time review the information held about their child, correct it, ask us to delete it, or withdraw consent, by writing to support@prixellabs.com. Withdrawing consent will end the Services for that child.
Information reaching us without consent: If you believe a child has provided PRIXEL LABS with personal information without the consent of their parent or legal guardian, please get in touch with us and we will do our best to remove that information from our records.
Unsolicited Information. Any personal data that we collect other than through the Services is not covered by this Policy. Any unsolicited information you send to us via the Services or by any other method — including suggestions for new features or improvements to existing ones (collectively, "Unsolicited Information") — is not covered by this Policy. All Unsolicited Information will be regarded as non-confidential, and we may distribute, disclose and use it without restriction or credit.

7. Links to Third Parties

Only the Services are covered by this Policy. The Services may link to other Third-Party websites or mobile applications (the "Third-Party Applications") that are not under our control or operation. Such websites and Third-Party Applications are not covered by this Policy. The privacy policies of any Third-Party websites or mobile applications are not our responsibility, and you shall be responsible for reading and keeping yourself updated with the terms and conditions and privacy policy of such Third-Party platforms.
As previously mentioned, you have the option to log in through a Third-Party Site. Please be informed that, by choosing to access our Platform through such a Third-Party Site, you will be given the option to share the information contained under that Third-Party Site account, and you may opt out of sharing such information barring information which is essential for us to allow you access to the Services and the Platform. It shall be your responsibility to keep yourself updated with the terms of use and privacy policy of the Third-Party Site for the protection of your data.
There may be links on the Platform to other programmes or websites. You accept and recognise that these applications and websites, with the exception of other platforms owned by us, are run by Third Parties and are not under our control, affiliated with us, or associated with us unless clearly stated. As a result, we have no control over the privacy practices or policies of the software and websites that can be accessed via links from this Platform. You should get in touch with the organisations in charge of those websites directly if you have any questions about their privacy practices and policies.

8. Amending or Updating User Information

You have the right to request access to the information we hold about you and about your child. Even though there may be some exceptions, we shall grant access to the Information in compliance with the relevant legislation. We reserve the right to charge a reasonable fee for allowing access to information. Additionally, we will make a good-faith effort to accurately record the data you give us, including any modifications. You have the right to review, modify and update the information we have on file. You may also ask us to remove any personal data that is unreliable, irrelevant or processed unlawfully in light of any applicable laws. Your ability to inspect, correct and delete information is also governed by any statutory retention obligations as well as any applicable legislation.
Retention. We retain Information for as long as the Account is active, and thereafter only for as long as is needed to meet the purpose it was collected for, to resolve disputes, and to comply with our legal, tax and accounting obligations. Information that is no longer needed for any of these purposes is deleted or anonymised.

9. Rights of Users

You fully accept and agree that your Personal Data and other information will be processed in India and other countries if you are using our Services from outside of India. Laws governing privacy and data security may differ from, or be less strict than, those in force in your country of residence. You hereby give your explicit approval for this Policy to be followed in the processing of your Personal Data and other data.
Users have various data protection rights with respect to the personal information that businesses and organisations may gather about them. We value openness and are dedicated to upholding all of our users’ privacy rights. Each user of our Services, and each parent or legal guardian acting for a child, has the following rights:
The Right to Access: You have the right to request copies of your personal data, subject to a reasonable fee charged by us.
The Right to Rectification: In the event of any inaccurate or incomplete information, you have the right to rectification or completion of the information, as the case may be.
The Right to Erasure: Subject to certain conditions, upon your request, we will erase the information you have provided.
The Right to Restrict Processing: Upon fulfilment of certain conditions, you can restrict PRIXEL LABS from processing your information. Please be advised that the same may result in the restriction of the Services and of access to our Platform.
The Right to Notification: You have the right to be notified regarding any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort.
The Right to Data Portability: You have the right to request that PRIXEL LABS transfer the data we have collected to another organisation, or directly to you, under certain conditions.
The Right to Object to Processing: You have the right to object to PRIXEL LABS processing your personal data, under certain conditions.
The Right to Certain Protections related to Automated Individual Decision-making, including Profiling: You have the right not to be the subject of a decision based solely on automated processing, including profiling, under certain conditions.
You are entitled to exercise your rights as per the applicable law of your respective state.

10. User Declarations

You understand and have the knowledge that Information is being collected.
You understand and have the knowledge of the purpose for which your Information is being collected.
You understand and have the knowledge of the intended recipients of the Information.
You understand that you have the option not to provide the data or information sought to be collected by PRIXEL LABS and the Platform.
You understand that you have an option, while availing the Services or accessing the Platform or otherwise, to withdraw the consent earlier given to PRIXEL LABS, and you understand and accept that such withdrawal of consent shall be sent in writing, and that in such an event PRIXEL LABS shall have the right, at its discretion, not to provide the Services for which the information was derived or collected.
Where the Account is registered for a child, you declare that you are the parent or legal guardian of that child and that you give the consents in this Policy on the child’s behalf.
You have read and understood this Privacy Policy and all other policies governing the usage of the Platform.

11. Grievance Redressal

In accordance with applicable Indian laws (including the Information Technology Act, 2000 and the rules thereunder), PRIXEL LABS has designated a Grievance Officer to handle user complaints, concerns and redressal requests. Grievances in relation to this Policy can be sent to the Grievance Officer at PRIXEL LABS.
Name: Pranjal Jain
Email: pranjal@prixellabs.com
Support: support@prixellabs.com

12. Contact

For support, legal notices or other communications:
PRIXEL LABS (Spark)
Address: 4th Floor, 648/A, Om Chambers, Old Binnamangala Road, Indiranagar, Bengaluru, Karnataka — 560008, India
Email: support@prixellabs.com
BY AGREEING TO THE TERMS OF THIS POLICY, YOU AGREE TO OUR PROCESSING OF YOUR PERSONAL INFORMATION, AND THAT OF THE CHILD FOR WHOM YOU REGISTER, FOR THE PURPOSES GIVEN HEREIN.