SPARK littlies Privacy Policy
Last updated: 28/04/2026
1. About this policy
This Privacy Policy applies to the SPARK littlies mobile application and website (together, "SPARK littlies" or "the service"). It explains how FF4L PTY LTD ("we", "us", "our") collects, uses, stores and discloses personal information in connection with the service.
We handle personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). This policy is available free of charge in the app and on our website at all times.
Contact: support@spark-app.com.au
2. Who this policy applies to
This policy applies to educators, directors and other authorised users of SPARK littlies ("you"). It also describes how we handle information about children entered by authorised users.
This policy does not govern how early childhood services manage personal information in their own operations. Services using SPARK littlies are independently responsible for complying with their own privacy obligations to parents, guardians and other individuals — including under applicable state and territory legislation and the National Quality Framework.
3. Personal information we collect
We may collect the following types of personal information:
- Account and service details: name, email address, role (educator or director), and centre or service name.
- Centre and service settings: director-managed configuration settings, including AI feature preferences.
- App content: lesson plans, observations, notes, templates and other content entered by educators.
- Children's information (assessment/class feature): a child's initials and date of birth, used to support age-appropriate assessment and reporting.
- Photo uploads: photos uploaded by educators and attached to observations.
- Observation PDFs: PDFs generated from observations, stored in the app and available for download or printing by authorised users.
- Ask Sam AI content: text entered into Ask Sam AI and the responses returned.
- Payment and billing details: subscription and billing administration information. Payments are processed by Stripe; we do not store full card details.
4. Children's personal information
SPARK littlies is designed for use by educators and early childhood services. It is not intended for direct use by children.
The app allows services to store limited information about children — including initials and date of birth — and to upload photos for the purposes of educational documentation and assessment.
Service responsibility: Services are solely responsible for ensuring they hold appropriate authority, including any required parental or guardian consent, to:
- enter children's information into SPARK littlies;
- upload and store children's photos; and
- generate, download or print observation PDFs containing children's information and photos.
Photos: Photos of identifiable children should be treated with care. Services should have a clear, documented consent process in place before uploading children's photos to the app.
Data minimisation: We recommend using a child's initials rather than their full name wherever practicable, and only entering information that is necessary for the educational purpose.
5. How we use personal information
We collect and use personal information to:
- create and manage accounts and centre or service access;
- provide core app features, including planning, observations, assessment and reporting;
- generate and store observation PDFs for download and printing;
- provide Ask Sam AI features;
- provide customer support and respond to requests;
- manage subscriptions and billing;
- maintain security, prevent misuse and improve the service; and
- comply with our legal obligations.
6. Ask Sam AI
Ask Sam AI is an AI feature powered by a large language model (LLM) provided by OpenAI. Responses are generated based on the text you enter.
Important: Do not enter children's full names, dates of birth or any other information that could identify a child or another individual into Ask Sam AI.
When you use Ask Sam AI, your text is sent to OpenAI and may be processed on servers located outside Australia, including in the United States. Directors can manage certain AI feature settings for their centre or service but cannot view individual educator AI chat histories.
We have entered into contractual arrangements with OpenAI designed to protect information shared with that service. See Section 9 (Overseas disclosure) for further detail.
7. Printing and exporting
Authorised users can download or print observation PDFs.
Once exported, observation PDFs may be stored in systems outside SPARK littlies and will be subject to the service's own policies and practices. Services should:
- store printed or exported observation PDFs securely;
- restrict access to authorised personnel only; and
- maintain clear internal procedures for the retention, sharing and destruction of physical and digital copies.
8. Who we share personal information with
We may share personal information with the following categories of third-party service providers who assist us in operating SPARK littlies:
- Hosting and infrastructure: Base44
- Content delivery and security: Cloudflare
- AI features: OpenAI (Ask Sam AI)
- Payment processing: Stripe
We may also disclose personal information where required or authorised by law, or where you have consented to the disclosure.
We do not sell personal information.
9. Overseas disclosure
Some of our service providers store or process personal information outside Australia, including in the United States. These providers include:
- OpenAI — Ask Sam AI processing
- Cloudflare — content delivery and security
- Stripe — payment processing
- Base44 — hosting and infrastructure
Before disclosing personal information to overseas recipients, we take reasonable steps to satisfy ourselves that those recipients handle information in a manner consistent with the APPs, including through contractual arrangements and security controls.
You acknowledge that, despite these steps, overseas recipients may handle information in jurisdictions where privacy laws differ from those in Australia and where the APPs may not directly apply.
10. Data retention and deletion
We retain personal information for as long as necessary to provide the service and meet our legal and contractual obligations.
- In-app deletion: Educators and directors can delete child records, observations, photos and PDFs within the app.
- Deleted data window: Deleted content may remain recoverable within a restoration window before it is permanently removed from our active systems.
- Ask Sam AI chats: Ask Sam AI chat histories may be retained for the life of the account unless deleted (where that functionality is available in the app) or unless you contact us to request deletion.
- Backups: Some information may remain in backup systems for a limited period following deletion from active systems.
To request deletion of your personal information, contact us at support@spark-app.com.au.
11. Security
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Our security measures include:
- encryption of data in transit;
- access controls limiting access to authorised personnel; and
- security controls implemented by our third-party hosting and infrastructure providers.
No method of data transmission or storage over the internet is completely secure.
Data breach notification: In the event of an eligible data breach under the Notifiable Data Breaches scheme (Privacy Act 1988 (Cth), Part IIIC), we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law.
If you become aware of or suspect a security or privacy incident involving your SPARK littlies account, contact us immediately at support@spark-app.com.au.
12. Access and correction
You have the right to request access to, or correction of, personal information we hold about you.
To make a request, contact us at support@spark-app.com.au. We may need to verify your identity before processing your request. We aim to respond within 30 days.
In some circumstances, we may be unable to provide access to certain information — for example, where doing so would unreasonably affect another person's privacy, or where an exception under the Privacy Act applies. If we decline a request, we will explain the reasons in writing.
13. Complaints
If you have a privacy concern or complaint, contact us at support@spark-app.com.au. We will review your complaint and aim to respond within a reasonable time.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
14. Changes to this policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email. Continued use of SPARK littlies after notice of a change constitutes your acceptance of the updated policy.
The current version of this policy is available in the app and on our website at all times.
Collection Notice — Sign-Up
When you create a SPARK littlies account, FF4L PTY LTD collects your name, email address, role and centre or service details. We use this information to set up and manage your account, provide the service and deliver customer support.
We use third-party service providers to operate the app, including for hosting, security, payment processing and AI features. Some providers may process your information outside Australia.
Providing your email address and other required details is necessary to create an account. If you do not provide this information, we may not be able to create your account.
You can request access to or correction of your personal information by emailing support@spark-app.com.au. Read the full Privacy Policy in the app.
Collection Notice — Children's Information
The assessment and class feature collects a child's initials and date of birth to support age-appropriate assessment and reporting.
Your service is responsible for ensuring it holds appropriate authority, including any required parental or guardian consent, before entering children's information into SPARK littlies.
Use initials rather than full names wherever practicable.
Read the full Privacy Policy in the app.
Collection Notice — Photo Uploads
Photos you upload will be stored in SPARK littlies and may be attached to observations and included in observation PDFs that can be downloaded or printed by authorised users.
Your service is responsible for ensuring it holds appropriate authority, including any required parental or guardian consent, before uploading and storing children's photos.
Only upload photos that are necessary for the educational purpose. Handle printed or exported observation PDFs securely and restrict access to authorised personnel.
Read the full Privacy Policy in the app.
Collection Notice — Ask Sam AI
Ask Sam AI is powered by a large language model (LLM) provided by OpenAI. Responses are generated from the text you enter. Your input may be processed outside Australia, including in the United States.
Do not enter children's full names, dates of birth or any other identifying information into Ask Sam AI.
Read the full Privacy Policy in the app.
Child Safety and Safeguarding Statement
SPARK littlies is committed to supporting child safety and the responsible handling of children's information.
Services using SPARK littlies must:
- only enter children's information and upload photos where they hold appropriate authority and any required parental or guardian consent;
- use initials rather than full names wherever practicable and minimise the amount of identifying information stored in the app;
- store and share observation PDFs securely and restrict access to authorised personnel; and
- report any concerns about child safety or suspected misuse of children's information to support@spark-app.com.au promptly.
We may suspend or terminate access to SPARK littlies where we reasonably believe the service is being misused, or where we are required to do so by law.
For child safety concerns or to report suspected misuse, contact us at support@spark-app.com.au.
