Primer - Privacy Policy Update (9-8-21)

Privacy Policy

Effective as of September [[ ]], 2021

Spark Learning, Inc. d.b.a. Primer ("Primer", “we”, “us”, or “our”) develops software for homeschooling families to deliver exceptional education to their kids.

This Privacy Policy describes our practices regarding information we collect through our websites, including and any other interactive features or services owned or controlled by Primer that post a link to this Privacy Policy (each, a "Service" and collectively, the "Services"), as well as any information we collect offline and combine in our databases. Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time.

Note about Children: As required by applicable law and our Terms of Service, children under the age of 13 in the U.S. (and a higher age if required by the applicable law in another country) may only use our Services with the express prior consent of a parent or legal guardian (“Parent”).  If we learn that Personal Information of a child has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact us to request that we delete that child’s personal information from our systems.

For more information about how we treat information collected about children please review the “How does Primer protect children’s information?” section of this Privacy Policy.

1. What is this policy?


Information collection/How we use your information: Information that we collect is primarily used to communicate with you and to provide and maintain access to Primer’s Services. Please review the "What information does Primer Collect?” and "How does Primer use the information it collects?" sections of this Privacy Policy for a full description of the information we collect, including Personal Information (as defined below), and how we use that information.

Information Sharing: Remember that if you create a Profile (as defined below) or share Personal Information with other users on the Services, your information may be visible to others. Note that we do not share your Personal Information with third parties for their marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled "Will Primer share any of the information it collects?"

Third parties: We work with service providers to provide us with information regarding traffic on the Services, including the frequency of use and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.

2. What information does Primer collect?

Information Shared With Us

  1. Registration and Other Information You Provide
The Services may collect "Personal Information" (which is information that can reasonably be used alone or in combination with other reasonably available information, to identify or contact a specific individual).  Personal Information includes, but is not limited to, user (including child and Parent) data, metadata, and user content. This may include a name, e-mail address, physical address, or password. Any information combined with Personal Information will be treated as Personal Information.
  1. Your Account
Parent Account
  • First and last name
  • Physical address
  • E-mail address
  • Child information, as listed under Child’s Account below
Child’s Account
  • Parent’s email
  • Parent’s phone number
The following information may be collected once Primer obtains parental consent:
  • First and Last name
  • Physical address
  • Child photo(s)
  • Birthdate/age
  1. Third Party Services and Information Third Parties Provide About You
The Services may permit interactions between the Services and a third-party feature or service.  These third parties may provide us with information about you. Similarly, if you publicly post information on a third-party platform, such as a social media site, that references Primer or one of the Services, your post may be published on our Services in accordance with that third party’s terms. These features may collect your IP address or other unique identifier, which page you are visiting on our website, and may set a cookie to enable the third-party feature to function properly. When you use a third-party feature through the Services, the third party may also have access to information about you and your use of our Services. Your interactions with third-party links and features are governed by the privacy policies of the third parties.

Information We Collect Automatically

Like other websites and online services, we and our analytics providers, vendors and other third-party service providers may automatically collect certain "Usage Information" whenever you access and use the Services.  For example, we may collect information regarding how often a user accesses certain features.

Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit, and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.

In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

Usage Information is collected via tracking technologies.


Like many other websites and apps, we use “cookies” (a small file sent to your computer by a website or device to allow the website or app to store information which uniquely identifies you) or other similar software to collect data in order to assist our users and provide them with a more personal experience visits in our Website or apps. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them.  You can always disable cookies at your browser or device’s settings, but please note that if you do so, some (or all) of the features and functionality of our Services may not be available to you.

How We Respond To Do Not Track Signals:

Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit

3. How does Primer use the information it collects?

We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information for the following purposes:

  1. To provide the Services.
We use your personal information to verify your registration, allow you to participate in features we offer and contact you regarding the Services
  1. To operate the website.
Your personal information may be used to tailor content, recommendations and offers we display to you, both on the Services and elsewhere online, as well as to maintain or improve our Services.
  1. To send marketing communications.
Anyone may sign up to receive communications from us regarding new or existing offerings or other materials that may be of interest.  Recipients who have opted-in to such communications may unsubscribe at any time by clicking on the unsubscribe link in any e-mail.  Children under the age of 18 are prohibited from signing up for these communications and we will unsubscribe any person under the age of 18 that we become aware of signing up to receive these communications
  1. To create anonymous data for analytics.
We may make information anonymous by excluding information that makes it personally identifiable to you, and use that anonymous data for our lawful business purposes.
  1. For compliance, fraud prevention, and safety.
We use your Personal Information as we believe is necessary or appropriate to (a) enforce our terms and conditions; (b) protect our rights, privacy, safety or property, and that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
  1. To comply with law.
We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  1. With your consent.
In some cases, we may ask for your consent to collect, use, or share your personal information, such as when required by law or agreements with third parties.

Please note that information submitted on the Services via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.

4. Will Primer share any of the information it collects?

Primer does not share your Personal Information with third parties for their marketing purposes in compliance with all applicable laws. Primer may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties.

We also may share your Personal Information with third parties with your consent (if permissible under applicable law), as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy:

  1. Service Providers
We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations, which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our e-mails, or offering customer service.
  1. Administrative, Legal Reasons & Academic Integrity Investigations
We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of or as otherwise authorized by an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Service or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual.
  1. Business Transitions
Primer may share Personal Information with its parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that Primer goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred.
  1. Testimonials
We may display personal testimonials of satisfied users on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us.

5. How does Primer work with third parties?

Third-Party Advertising

Primer does not currently use any user data to target advertisements or marketing on behalf of third parties. We do not mine user data for any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to children or their Parents is prohibited.

Third-Party Sign-In

You may choose to connect the Services to third party services, such as Facebook.  We do not control these third parties’ use of your personal information.  The information collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service.

Third-Party Providers

We work with service providers like Amazon Web Services and similar organizations to provide us with information regarding traffic on the Services, including the features used when visiting the Services and to provide us with information regarding the use of the Services.

Third-Party Content, Links to Other Sites, and Primer Content Found Outside of the Services

Certain content provided through the Services may be hosted and served by third parties. In addition, the Services may link to third party websites or content over which Primer has no control and which are governed by the privacy policies and business practices of those third parties.

Please also note that Primer content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may independently collect data. Primer is not responsible or liable for the privacy practices or business practices of any third party.

For more information about data we receive from third parties, please refer to “Third Party Services, Social Media Platforms, and Information Third Parties Provide About You” above.

6. What happens if I access Primer’s services through a mobile device?

If you use the Services through a mobile device, you agree that Primer may store and use that information for security purposes (for example, for user verification or authentication).

7. How does Primer protect children’s information?

Protecting the privacy of young children is especially important to Primer. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 13 years of age or older if required by applicable law (“Child Users”).

Primer does not knowingly permit Child Users to use our Services without prior, express consent from a Parent, or as otherwise permitted under the Children’s Online Privacy Protection Rule (“COPPA”). If we learn that Personal Information of a Child user has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a Parent and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact Primer to request that we delete that child’s personal information from our systems.

How does a child use the Services?

A child may sign up for an account by creating a username and password, but no personal information about a child is collected until the necessary parental consent is obtained. Parents will be alerted via phone and email when their child registers to begin the process of obtaining the necessary parental consent. Primer requires parental consent before permitting children to continue using the Services.

Once Child Users have access to the Services, they can join clubs with other users in which they post content and provide mutual feedback and comments, participate in live events using voice and chat features and a shared visual space, and work on project teams with other Child Users.

What children’s information is visible to others?

No child’s information is made available or visible to the public through Primer unless the Child User voluntarily decides to post something publicly on Primer’s journal feature, which shows the Child User’s username.

Other users may be able to view information that Child Users choose to display with their projects, comments, or posts. This may include a first name, profile photo, a bio written by the user, and information about the projects on which the Child User has worked.

8. How does Primer protect and store my information?

Primer takes data security very seriously.  Primer takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and upon receipt, and at rest.  Such measures vary depending on the sensitivity of the information at issue.

Please note that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

How will Primer handle a data breach or security incident?

In the event that Primer becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Service, and may e-mail you at the e-mail address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Primer has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. Primer will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, Primer will follow its internal procedures, which articulate how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and children may have been impacted, the data that may have been accessed, Primer’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.

In the unlikely event of an unauthorized disclosure of Data, Primer has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.

If you have any questions about security on our Services, you can contact us at [email protected].

9. How can I opt-out of sharing, providing, or receiving certain information?

Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of Primer’s features may not be accessible, or may not function properly - for example, we may not be able to remember your language preferences for you.

E-mail Communication: You can opt-out of receiving further communications by clicking the unsubscribe button at the bottom of an e-mail. Primer may continue to send you Service-related e-mails as we believe necessary to provide the Services.  Primer will never e-mail children.

10. How can I access and manage my Personal Information?

You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. Note that certain accounts may have limitations regarding the ability to delete information.  Even after information is deleted, we may maintain it in backup or archive form unless you request permanent deletion or the account is terminated.

11. What communications will I receive from Primer and how do I limit them?

Primer may post notices on the homepage.

Primer may send users information by e-mail. You may choose to stop receiving certain e-mails from Primer by using the unsubscribe button at the bottom of the Primer e-mail. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account for that Service.

12. How do I close my account?

If you have an account and you wish to close your account with one of our Services, please contact us via email at [email protected], and we will remove your Personal Information and Profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and, if applicable, send your request using an e-mail account that you have registered with Primer under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it.

13. How long does Primer keep my information?

Upon termination of your Account, Primer will take commercially reasonable steps to delete any Personal Information, excluding information relating to messages you sent to active users, from our live databases in a reasonable amount of time not to exceed ninety (90) days.  You understand and agree that Primer may continue to have Personal Information in archive files or similar databases.  You further agree that Primer has no obligation to delete aggregated or de-identified information.  Primer may retain and use aggregated and de-identified information for any purpose consistent with laws and regulations.

Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law.  All retained data will continue to be subject to the applicable privacy policy for the Service.

14. How will Primer notify me of changes to this policy?

We will notify you of material changes to the Privacy Policy on our Website and/or by e-mail, and make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services.

Primer may update this Privacy Policy at any time and any changes will be effective upon posting.  Upon any update the date at the top of this policy will be updated.  In the event that there are material changes to the way we treat your Personal Information, you are responsible for regularly reviewing this Privacy Policy and your Primer account for notice of such modifications. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy.

15. What if I do not live in the U.S.?

The Services are not currently intended for users outside the United States.  If you are located outside of the United States, please be aware that the Services are operated in the United States and any information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

16. How can I contact Primer?

If you have questions or comments about this Privacy Policy, please contact us via e-mail at [email protected] or by mail at 2180 Bryant St, STE 201, San Francisco, CA, 94110.