Privacy Policy

Oracy Spark · Last updated 9th October 2026

1. Who we are

Oracy Spark is operated by David Currie, a sole trader trading as David Currie Education. David Currie is the controller of the personal information described in this policy.

Contact: hello@oracyspark.com

2. Who this policy covers

This policy explains how we use personal information about website visitors, individual members, school and organisation contacts, account users, people who request free resources, people requesting or participating in free school trials, and people who contact us.

Oracy Spark is designed for use by adults supporting children’s education. It is not designed for children or pupils to create accounts or submit personal information. Do not enter children’s or pupils’ names, responses, safeguarding information or other personal data into the website or Spark Generator.

3. Information we collect

Depending on how you use Oracy Spark, we may collect:

Identity and contact details: name, role, email address, telephone number if provided, school or organisation where relevant, and correspondence.
Account details: login email, membership or subscription and access status, account preferences, and security information.
School free-trial details: school name, contact name, email address, selected membership type, trial request date, activation and expiry dates, account access status, follow-up communications and whether the school subsequently purchases a paid membership.
Purchase details: plan purchased, payment status, receipts, renewals, cancellations and refund records. Stripe processes payment details; we do not ordinarily receive or store full card numbers.
Website and usage details: IP address, device and browser information, access times, pages and features used, referral information, cookie identifiers, and diagnostic or security logs.
Spark Generator inputs: the topic, age range, settings and any text you choose to enter, together with the generated result where it is needed to provide the feature or investigate a problem.
Marketing details: resource requests, communication preferences, campaign interactions, and records of consent or objections where relevant.

We obtain information directly from you, from a school or organisation you represent, automatically through the website, and from providers involved in operating the service.

For school outreach, we may also use publicly available school contact information.

4. Why we use information and our lawful bases

We use personal information to:

Provide memberships and subscriptions: create accounts, give access, process purchases, manage renewals and cancellations, deliver included resources and provide support. For an individual buying personally, this is generally necessary to perform our contract with them. For school staff and contacts, we generally rely on our legitimate interests in delivering and administering the school’s subscription.
Manage free school trials: process trial requests, create member accounts, provide temporary access, record trial dates, send activation instructions and trial-related communications, and manage the transition to a paid subscription or the expiry of trial access. We generally rely on steps taken at the request of the individual before entering into a contract, or our legitimate interests in administering trials requested on behalf of schools, as appropriate.
Operate the Spark Generator: process the information entered to produce the requested result. This is generally necessary to provide the feature to an individual member or supports our legitimate interests in providing it to school users.
Maintain records: keep financial, tax and business records and respond to lawful requests. We rely on legal obligations and, where appropriate, legitimate interests.
Protect and improve the service: maintain security, diagnose faults, prevent misuse and understand how the service performs. We rely on legitimate interests, except where consent is required for a particular cookie or similar technology.
Respond to enquiries: answer questions and manage our relationship with members, schools and prospective customers. We rely on legitimate interests or steps taken towards a contract, as appropriate.
Send service communications: send receipts, access information, included resources, security messages and renewal notices. We rely on contract or legitimate interests. These messages are separate from optional marketing.
Send marketing: use consent where required by electronic-marketing law, or legitimate interests where that law permits business-to-business marketing. Marketing messages include a way to unsubscribe or object.
Use non-essential cookies: rely on consent where required, as explained in our Cookie Policy.

Where we rely on legitimate interests, we consider the impact on individuals and their rights. You may object to relevant processing as described below.

5. The Spark Generator

When you use the Spark Generator, the information you enter is processed to create a suggested prompt or activity. It may be processed by a technology provider used to operate the feature.

Do not include information that identifies a child, pupil or another person, or any confidential or sensitive school, family or personal information.

Generated content should be checked by the adult responsible for using it before it is used with children or pupils. We do not use the Spark Generator to make decisions about children or pupils.

6. Who receives information

We share personal information where reasonably necessary with:

Wix, for website hosting and website or account functions;
Stripe, for checkout, payment processing, memberships, subscriptions and payment-related fraud prevention;
providers of email, workspace, website analytics, cookie management, technical support and any technology used to operate the Spark Generator;
professional advisers and bookkeeping providers;
HM Revenue & Customs, regulators, courts or other authorities where required or permitted by law; and
a genuine purchaser or successor if the business is sold or reorganised, subject to appropriate safeguards.

We do not sell personal information.

7. International transfers

Some providers may process personal information outside the United Kingdom. Where UK data-protection law restricts a transfer, we use an applicable adequacy arrangement, approved contractual safeguards or another lawful transfer mechanism.

You may contact us for information about relevant safeguards.

8. How long we keep information

We keep information only for as long as needed for its purpose, subject to legal requirements:

Account and membership or subscription information: for the membership or subscription and normally up to 24 months afterwards, unless needed longer for a dispute, security issue or legal claim.
Free school-trial records: normally up to 12 months after the trial ends, unless the school becomes a paying subscriber, an earlier deletion is appropriate, or longer retention is reasonably necessary for a legal obligation, dispute or legitimate business record-keeping purpose.
Financial and transaction records: for at least five years after the relevant 31 January Self Assessment submission deadline, or longer where required.
Routine enquiries and support correspondence: normally up to 24 months after the matter closes.
Marketing consent, unsubscribe and objection records: as long as reasonably necessary to respect the choice and demonstrate compliance.
Technical and security records: according to the relevant system’s settings and for no longer than reasonably needed for security, diagnosis or analysis.
Spark Generator inputs and results: only for as long as needed to provide the feature, maintain security or investigate a reported problem, subject to the retention practices of the technology providers involved.

We may retain information longer where needed to comply with a legal duty, investigate fraud, resolve a dispute or establish, exercise or defend a legal claim. When no longer needed, information is deleted or anonymised.

9. Cookies

We use cookies and similar technologies for website operation, security, account access, preferences and, subject to the visitor’s choices where required, analytics or marketing.

See our Cookie Policy for details.

10. Security

We use reasonable technical and organisational measures, including access controls, account authentication and reputable service providers.

No online service can guarantee absolute security. Please protect your login details and tell us promptly if you suspect unauthorised access.

11. Your rights

Depending on the circumstances, you may have the right to:

be informed about how your information is used;
request a copy of your personal information;
have inaccurate information corrected;
request deletion or restriction of its use;
object to processing based on legitimate interests, and object at any time to direct marketing;
receive certain information in a portable format; and
withdraw consent at any time, without affecting earlier lawful use.

These rights are not absolute.

To exercise one, email hello@oracyspark.com. We may ask for proportionate information to confirm your identity and will respond within the period required by law.

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects.

12. Complaints

Please contact us if you have a concern so we can try to resolve it.

You also have the right to complain to the Information Commissioner’s Office at ico.org.uk.

13. Changes

We may update this policy when the service, its providers or the law changes. The current version and update date will be published on the website.

We will give appropriate notice if a change materially affects individuals.