Privacy Policy

1. Who we are

Sparrway is an interactive language-learning and scenario-creation platform. For the purposes of applicable data protection law, the controller of personal information described in this Policy is Reckon Labs Limited, a private company limited by shares registered in Ireland under company number 815224, trading as “Sparrway”, with its registered office at Workhub, 6 Fern Road, Sandyford, Dublin 18, D18 FP98, Ireland (“Sparrway”, “we”, “us” or “our”).

Privacy contact: info@sparrway.com. Data Protection Officer: not appointed, as we are not required to appoint one; privacy questions are handled through the contact above. EU representative: not applicable, as Reckon Labs Limited is established in Ireland. UK representative: not appointed at present; users in the UK can contact us directly at the address above.

2. Scope

This Policy applies to Sparrway websites, web and mobile applications, accounts, interactive scenarios, creator tools, support, waitlists and related services that link to it (the “Services”). It does not govern third-party services that have their own privacy notices.

3. Information we collect

Depending on the features you use, we may collect:

• Account and identity information: name, email address, username, password in hashed form, account identifiers, age or age band where needed, country, language and authentication records.
• Profile and learning information: language, proficiency level, interests, learning goals, scenario history, responses, scores, Action IDs, Learning Outcomes, progress and preferences.
• Conversation and AI content: prompts, typed responses, scenario context, AI outputs and, if a voice feature is enabled, audio and transcripts. Do not include health, financial or other sensitive information unless a feature clearly asks for it.
• Creator and user content: scenarios, characters, dialogue, images, links, portfolio or social-profile links, reviews, ratings, moderation records and publication settings.
• School, teacher and company information: organisation, role, group membership, assignments and administrator-managed account information.
• Applications and communications: Creator Program application details, waitlist email, support request type, subject, message, attachments, demo requests and correspondence.
• Transaction information: product, subscription, transaction status, receipt number, billing country and limited payment metadata. Full card details should be collected directly by an authorised payment provider, not by Sparrway. Paid features are not available yet. Before they launch, we will name the payment provider in this Policy.
• Technical and usage information: IP address, device and browser type, operating system, app version, language, timestamps, diagnostic logs, pages and features used, referring URL and security events.
• Cookie and consent information: essential cookies, consent choices and, only with required consent, preference, analytics or external-media identifiers. See our Cookie Policy.

We receive information directly from you, automatically from your device, from an organisation that provides your managed account, and from service providers or sign-in partners you choose to use. If you give us information about another person, you must be authorised to do so.

4. How and why we use information

Where we rely on legitimate interests, we balance those interests against your rights and reasonable expectations. You may ask for further information about that assessment.

5. AI features

Sparrway uses artificial intelligence to respond within scenarios, assess communication against learning goals, assist with scenario creation and support safety moderation. Your prompts, responses and relevant scenario context may be sent to our contracted AI service providers to generate an output.

Our AI service providers act as our processors under written contracts and may use this information only to provide their service to us. Depending on the provider, it may be processed in the European Union or the United States, with the safeguards described in section 7. You can ask us at info@sparrway.com for the current list of AI providers, where they process information and how long they keep it.

AI output may be inaccurate or inappropriate. We use safeguards and moderation, but users should review important output. Sparrway does not use AI to make decisions that produce legal or similarly significant effects about you unless we provide a separate notice and any rights required by law.

6. How we share information

We may share information only as needed with:

• hosting, content-delivery, database, security, authentication, email, customer-support, analytics and file-storage providers;
• AI model and safety-service providers for the AI functions described above;
• payment processors, app stores, fraud-prevention providers and payout providers when commerce launches;
• a school, teacher, company or group administrator where your account is managed by that organisation, subject to the notices shown for that account;
• other users when you intentionally publish a profile, scenario, review or other public content, or share content by link or code;
• professional advisers, auditors, insurers, courts, regulators and authorities when legally necessary; and
• a buyer or successor in a merger, financing, reorganisation or sale, subject to appropriate safeguards.

We do not sell personal information for money. We do not use advertising or remarketing technologies, and we do not “sell” or “share” personal information for cross-context behavioural advertising as those terms are used in California law.

Current core processors of the website and their locations: OVHcloud (website hosting and email, European Union); Google (Google Analytics, only with your consent, and reCAPTCHA form protection; European Union and United States). Apple and Google distribute the Sparrway apps through the App Store and Google Play under their own terms. The providers behind the Sparrway platform, including AI providers, are available on request at info@sparrway.com.

7. International transfers

Because Sparrway is international, information may be processed outside your country. Where required, we use an adequacy decision, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, or another lawful transfer mechanism, together with supplementary safeguards where appropriate. You may contact us for information about the relevant safeguards.

The Sparrway website is hosted in the European Union. Google may process analytics and reCAPTCHA information in the United States; for these transfers we rely on the EU–U.S. Data Privacy Framework and the European Commission’s Standard Contractual Clauses.

8. How long we keep information

We keep personal information only for as long as needed for the purposes above, including legal, accounting, dispute and security requirements. Our intended schedule is:

We may retain de-identified information that can no longer reasonably identify you.

9. Your privacy rights

Depending on your location, you may have rights to access, correct, delete, restrict or object to processing, receive a portable copy, withdraw consent, appeal a refusal, and complain to a regulator. Withdrawing consent does not affect earlier lawful processing.

Residents of California and certain other US states may also have rights to know the categories and specific pieces of personal information collected, request correction or deletion, opt out of sale, sharing or targeted advertising where applicable, limit certain uses of sensitive personal information, and receive equal service when exercising rights. Authorised agents may submit requests where local law permits.

To exercise a right, email info@sparrway.com with the subject “Privacy Request”. We may verify your identity and authority. We will respond within the period required by applicable law. You may unsubscribe from marketing using the link in an email.

If you are in the EEA, you may complain to the supervisory authority where you live or work, or to the Data Protection Commission in Ireland, our lead supervisory authority. If you are in the UK, you may complain to the Information Commissioner’s Office. We encourage you to contact us first so we can try to resolve the issue.

10. Children

Individual accounts are not intended for children under 16. A child may use a school-managed experience only where Sparrway has a suitable agreement and the school or parent has provided any authorisation required by law. We do not knowingly collect personal information directly from a child under 13 without verifiable parental consent. If you believe a child has provided information contrary to these rules, contact us so we can investigate and delete it where required.

11. Security

We use administrative, technical and organisational measures designed to protect information, including access controls, encryption in transit, monitoring, backups and service-provider reviews where appropriate. No online service is completely secure. Please use a unique password and notify security@sparrway.com if you suspect unauthorised access.

12. Changes to this Policy

We may update this Policy when our Services or legal obligations change. We will post the updated version and revise the date above. If a change materially affects your rights, we will provide additional notice where required.

13. Contact us