Version 1.0 | Last updated: 12 September 2026 | Explorium Ltd trading as Lights On Learning
This Privacy Notice explains how personal information is handled when you use Lights On Sparkie, our AI companion for parents and carers.
It should be read alongside our main Privacy Policy and the CoachVox privacy information shown when you create your account.
Lights On Sparkie is an AI companion based on Julia Black's Lights On methodology. It is designed to help parents and carers think more clearly about parenting, behaviour, learning, family relationships and decision-making.
Sparkie is for adults aged 18 and over only. It is not designed for children to use directly.
Sparkie is not a therapist, doctor, safeguarding service, emergency service or substitute for appropriate professional support.
When you use Lights On Sparkie, we may process information including:
Because Sparkie is used by parents and carers, conversations may sometimes contain information about children, family members or other people.
Please do not provide information Sparkie does not need.
You generally do not need to provide your child's full name, school name, address, telephone number or other identifying information.
Descriptions such as "my 14-year-old" will usually be enough.
We do not ask you to provide sensitive personal information in order to use Sparkie. However, parents may voluntarily mention information relating to matters such as physical health, mental health, neurodiversity, disability, safeguarding, sexuality or other personal circumstances while discussing a situation with Sparkie.
Please only share information that is genuinely necessary for the conversation and avoid unnecessary identifying details.
Where conversation content includes information classed as special category personal data under UK data protection law, additional legal protections apply. We rely on your explicit consent as the legal condition for processing such information, given voluntarily when you choose to share it. You can withdraw this consent at any time by contacting us at teamlightson@lightsonuniverse.co.uk.
Lawful basis: Article 6(1)(b) contract and Article 6(1)(f) legitimate interests. Where special category data appears in conversations: Article 9(2)(a) explicit consent.
We may use information from Sparkie conversations to:
Lawful basis: Article 6(1)(b) contract (providing and operating Sparkie); Article 6(1)(f) legitimate interests (quality monitoring, safety, service improvement, aggregate insight).
We may analyse Sparkie conversations to identify broader patterns and themes — for example, common questions about helping versus taking over, school disengagement, motivation or parent-child communication.
These insights may inform the development of Sparkie and Lights On resources. We will not deliberately publish identifiable family stories or conversation content. Before using conversation insights publicly, we will remove information that could identify a parent or child. We will not publish a verbatim personal conversation or identifiable testimonial without appropriate permission.
Lawful basis: Article 6(1)(f) legitimate interests (service development and improvement).
Your Sparkie conversations cannot be seen by other members of the Lights On community.
Your conversations may be accessed by authorised members of the Lights On team where necessary to operate, review, support, monitor or improve the Sparkie service.
CoachVox administrators may also access conversations where necessary to provide the CoachVox service, support configuration or training of Sparkie, maintain platform security, or comply with legal requirements. CoachVox has confirmed that chat content is treated as confidential and that administrator access is not currently individually logged. We limit our own internal access to people who require it for an appropriate operational, quality, safety or service purpose.
Lights On Sparkie operates using the CoachVox platform. Explorium Ltd and CoachVox act as joint controllers in relation to Sparkie conversation data. This means both organisations have responsibilities under data protection law in relation to that information.
CoachVox provides its own privacy policy, AI usage terms and data protection information when you create and use your account, available at coachvox.ai/privacy.
You may contact us about your personal data using the details at the end of this notice. You may also exercise relevant data protection rights directly with CoachVox.
To generate Sparkie's responses, conversation content is sent to the underlying AI model provider used by CoachVox. CoachVox has confirmed that conversation data is not used to train the underlying AI model and is not shared for the purpose of training other organisations' AI systems.
AI-generated responses can nevertheless be inaccurate or incomplete. You should use your own judgement and seek appropriate professional help where the situation requires it.
CoachVox uses trusted infrastructure providers including Google and Amazon Web Services (AWS). Data may be stored or processed in the United States and Europe. Data is encrypted in transit and at rest.
Where personal data is transferred outside the UK, we rely on Standard Contractual Clauses (SCCs) as the appropriate legal safeguard, as agreed between CoachVox and its infrastructure providers. For further information contact us at teamlightson@lightsonuniverse.co.uk.
CoachVox does not currently apply a fixed retention period to Sparkie conversation data while an active CoachVox subscription remains in place. Conversation information may therefore remain stored until deletion is requested.
CoachVox is developing functionality that may enable permanent deletion of individual conversations.
You can request deletion of your Sparkie conversation data at any time by contacting us at teamlightson@lightsonuniverse.co.uk.
You can ask us to show you the Sparkie conversations we hold on your behalf. Please contact teamlightson@lightsonuniverse.co.uk and we will access them via our CoachVox client screen.
You can ask us to delete your Sparkie conversation history at any time. You may also contact CoachVox directly to exercise rights in relation to data for which it acts as a joint controller.
Sparkie is designed for adults aged 18 and over. Children should not use Sparkie directly. Parents and carers may share information about their children as part of conversations — please share only what is relevant and avoid unnecessary identifying details such as your child's full name, school or address.
If you believe a child has used Sparkie without appropriate supervision, please contact us at teamlightson@lightsonuniverse.co.uk.
Sparkie is designed to support thinking and reflection. It is not intended to replace medical, mental health, safeguarding, legal or other professional support.
If a conversation indicates a possible immediate safety, safeguarding, medical or significant mental health concern, Sparkie may encourage you to seek appropriate professional, crisis or emergency support. Sparkie does not diagnose children or adults.
If someone is in immediate danger or requires urgent medical attention, contact the appropriate emergency service rather than relying on Sparkie.
Lights On Sparkie uses artificial intelligence to generate conversational responses. Sparkie does not make legal, medical, diagnostic, educational-placement or other decisions about you or your child that have legal or similarly significant effects. Its purpose is to help you think, notice patterns, ask better questions and consider possible next steps. You remain responsible for decisions made on the basis of your own circumstances.
Depending on the circumstances, you may have rights including the right to:
To exercise any of these rights, contact us at teamlightson@lightsonuniverse.co.uk. We may need to confirm your identity before fulfilling a request. You may also contact CoachVox directly in relation to data for which it acts as joint controller.
If you have concerns about how we use your personal information, please contact us first so that we can try to resolve the issue.
How to raise a data protection complaint with us:
Email: teamlightson@lightsonuniverse.co.uk
Subject line: Data Protection Complaint — Sparkie
We will acknowledge your complaint within 30 days of receipt and investigate without undue delay.
This is your statutory right under section 164A of the Data Protection Act 2018.
You also have the right to complain to the UK Information Commissioner's Office (ICO):
We may update this Privacy Notice as Sparkie develops, as our use of the service changes, or where legal or platform requirements change. The latest version will always show the date it was last updated. We will notify active users of any material changes.
Explorium Ltd trading as Lights On Learning
Data Protection Contact: Julia Black
Email: teamlightson@lightsonuniverse.co.uk
Main Privacy Policy: www.lightsonuniverse.com/privacy-policy
Explorium Ltd trading as Lights On Learning | Lights On Sparkie Privacy Notice v1.0 | 12 September 2026 | England and Wales