Privacy Policy

Introduction

HardSplash Media Inc., operating as ClearSpark AI ("ClearSpark," "we," "us"), provides the website at clearspark.ai and the AI Adoption Hub at app.clearspark.ai. This policy explains what information we collect, how we use it, and the choices you have. It applies to both our website and the Adoption Hub.

By using our services you agree to this policy. If you do not agree, please do not use the services.

Definitions

• Service. Our website, the AI Adoption Hub, and related features.
• Account. A registered user identity used to access the Adoption Hub.
• Organization. A workspace created when an account signs up, which may include additional members.
• Member. A user who belongs to an organization under a paid or free seat.
• Guest. A user invited to participate in specific activities within an organization without occupying a billed seat.
• App. An interactive tool or piece of guided content within the Adoption Hub.
• Personal data. Information that identifies, or can reasonably be linked to, an individual.

Information we collect

Information you provide

• Account and profile information, including details you give us when you sign up or fill out your profile, and responses you provide during onboarding (such as your role, team size, and goals for using the Adoption Hub).
• Organization information, including details about your organization and its members.
• Information you submit to the Service, including content you enter into apps within the Adoption Hub and information you provide when you communicate with us. We may use information you have already shared to pre-fill and personalize your experience across the Service.
• Billing information. When you subscribe to a paid plan, our payment processor collects payment details directly. We receive a record of the transaction and limited subscription metadata, and do not store full payment card numbers on our systems.

Information collected automatically

• Usage information about how you interact with the Service.
• Device and connection information, such as IP address, approximate location derived from IP, and basic details about your browser and device.
• Cookies and similar technologies. See the "Cookies" section below.

How we use your information

• To provide, operate, and maintain the Service.
• To create and manage your account and organization, including authentication and member management.
• To personalize your experience, including pre-filling information you have already shared so you do not need to enter it again.
• To communicate with you about the Service, including transactional messages, security notices, and product updates.
• To let you know about ClearSpark products, features, and offerings that may be relevant to you. You can opt out of marketing communications at any time.
• To improve and develop the Service.
• To protect the Service and our users, prevent fraud and abuse, and enforce our terms.
• To comply with legal obligations.

We do not sell your personal data, and we do not use it for third-party advertising or interest-based remarketing.

AI processing

Some apps within the Adoption Hub use third-party AI infrastructure to generate responses. When you use these apps, the inputs you submit may be transmitted to and processed by that infrastructure on our behalf so that a response can be generated and returned to you.

We work with AI providers under terms that do not permit your inputs or outputs to be used to train their general models. AI providers may retain content briefly for abuse-prevention and service-quality purposes, after which it is deleted on their systems.

Please do not paste highly sensitive personal data, regulated data, or confidential third-party information into apps unless you have a clear basis to do so. The Adoption Hub is designed for business productivity and learning, not as a system of record for sensitive data.

Organization and team visibility

The Adoption Hub is a team product. Information you create or save within an organization may be visible to others in that organization based on the role they hold:

• Members can see content that is shared at the organization level (for example, shared prompt collections or shared assessments) and the names of other members.
• Organization administrators can additionally see seat assignments, plan and billing details, and aggregate usage information for their organization. Administrators do not have direct access to the contents of another member's private apps unless those apps were shared with the organization.
• Guests have access only to the specific activity they are invited to and do not have visibility into the broader organization.

If you are invited to an existing organization, the administrator of that organization controls your seat and may have visibility into your usage of the Service within that organization. If you do not want to be subject to that visibility, do not accept the invitation, or use a separate personal account.

How we share information

We share information only as needed to operate the Service or as described below. We share with:

• Service providers that support our operations, including cloud hosting and infrastructure, AI inference, authentication, transactional email, analytics, payment processing, and customer support tooling. These providers process information on our behalf under contractual confidentiality and security obligations.
• Other members of your organization as described in "Organization and team visibility."
• Parties to a business transaction in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.
• Authorities or other parties when we believe in good faith that disclosure is required by law, necessary to protect the rights, safety, or property of ClearSpark or others, or necessary to investigate or prevent fraud, abuse, or security incidents.

Data retention

We retain personal data for as long as your account is active and for a reasonable period afterward to support legitimate business needs (such as account recovery, dispute resolution, regulatory compliance, and security). Some categories may be retained for shorter or longer periods based on their purpose. When data is no longer needed, we delete or anonymize it.

International transfers

ClearSpark is based in Vancouver, British Columbia, Canada. The providers we work with may store and process information in Canada, the United States, or other jurisdictions where they or their sub-processors operate. Where required, we rely on appropriate safeguards for cross-border transfers.

Self-serve signup for the Adoption Hub is currently available to users in the United States and Canada. Members invited to an existing organization may join from other locations.

Your rights and choices

Depending on where you live, you may have rights under laws such as the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the General Data Protection Regulation (GDPR) in Europe, and the California Consumer Privacy Act / CPRA in California. These rights may include:

• Access to the personal data we hold about you.
• Correction of inaccurate or incomplete data.
• Deletion of your personal data.
• Objection to or restriction of certain processing.
• Portability of data you provided to us.
• Withdrawal of consent where processing is based on consent.
• Opting out of marketing communications.

Account deletion. All registered users can delete their account at any time from within the Adoption Hub. Deleting your account removes your personal profile and content that is not subject to a legitimate retention obligation. Some records may be retained where required by law or to resolve outstanding obligations (such as billing records).

To exercise any of your rights, or for any other privacy question, please reach out through our chat page or email info@clearspark.ai. You may also have the right to lodge a complaint with your local data protection authority.

Security

We use reasonable administrative, technical, and physical safeguards to protect personal data, including encryption in transit, encryption at rest for stored data, access controls, and tenant-level isolation between organizations. No system is perfectly secure, and we cannot guarantee absolute security of information transmitted to or stored on our systems. You are responsible for keeping your account credentials confidential.

Cookies and similar technologies

We use a small set of cookies and similar technologies for the following purposes:

• Necessary. Required to operate the Service, including signing you in and protecting against fraud and abuse.
• Functional. Remembering your preferences and settings.
• Analytics. Understanding how the Service is used so we can improve it.

We do not use advertising cookies, and we do not allow third-party advertising networks to track you across sites through our Service.

You can change your cookie preference at any time on our Cookie Preferences page, linked from the footer.

Age

The Service is intended for users who are at least 16 years old. We do not knowingly collect personal data from children under 16. If you believe a child has provided personal data to us, please contact us and we will take steps to delete it.

Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the "Last updated" date above and provide additional notice where appropriate (such as a notice in the product or by email). Your continued use of the Service after a change becomes effective means you accept the updated policy.

Contact us

For questions about this policy or to exercise your privacy rights, please reach out through our chat page or contact:

• HardSplash Media Inc. (operating as ClearSpark AI)
• 170 - 422 Richards St, Vancouver, BC, Canada V6B 2Z4
• info@clearspark.ai