Privacy Policy

1. Introduction

Apte (“Apte,” “we,” “us,” or “our”) operates the SPARC Benchmarking platform (the “Service”), a web-based application that allows member schools of the Summer Programs and Auxiliary Revenue Collaborative (“SPARC”) to enter, view, and benchmark aggregate financial and participation data related to their summer and auxiliary programs. This Privacy Policy explains what information we collect, how we use and share it, and the choices available to you.

This Policy applies to visitors, registered users, and administrators who access the Service (collectively, “Users,” “you”). By accessing or using the Service, you agree to the collection and use of information as described here. If you do not agree, please do not use the Service.

2. Who We Are

The Service is operated by Apte [exact legal entity name and state/jurisdiction of formation to be confirmed]. For questions about this Policy or our data practices, contact us at diego@apte.com.

3. Information We Collect

3.1 Account and Contact Information. When a school or staff member is provisioned access to the Service, we collect the individual's name and email address, their school/institution name, their role (school user or SPARC/Apte administrator), and authentication credentials or session tokens issued through our sign-in process (currently a development sign-in flow; in production this will be handled through single sign-on with Novi AMS, SPARC's membership platform).

3.2 Institutional and Financial Data. Schools voluntarily enter aggregate, institution-level data about their auxiliary and summer programs, including revenue and expense figures by category, personnel expense totals, number of program sessions, total unique camper/participant counts, the name of the preparer, and an optional school logo image.

This data is aggregate and institutional. It is not intended to, and should not, include personally identifiable information about individual students, campers, or minors. See Section 8.

3.3 Usage and Technical Data. We automatically collect limited technical information, including IP address, browser/device information, pages visited, and session cookies used strictly to keep you signed in.

3.4 Uploaded Files. If a school uploads a logo image, it is stored and displayed on that school's own reports and is not used for any other purpose.

4. What We Do Not Collect

• Personal data about individual students, campers, or other minors
• Payment card numbers, bank details, or other financial account credentials (the Service does not process payments — see Section 11)
• Sensitive categories of personal information (e.g., health information, government ID numbers, precise geolocation)

5. How We Use Information

• To provide, operate, and maintain the Service, including dashboards and benchmarking reports
• To authenticate Users and maintain account security
• To generate the Service's “Smart Summary” narrative feature (see Section 12)
• To communicate with you about your account or changes to our policies
• To monitor, troubleshoot, and improve the Service's performance and security
• To comply with legal obligations and enforce our Terms of Service

We do not use school data to build individual student profiles, and we do not sell User or school data to third parties for their own marketing purposes.

6. How We Share Information

We do not sell personal information. We share information only as follows:

6.1 Service Providers. We use third-party providers to host and operate the Service (currently anticipated to be Google Cloud Platform infrastructure, database hosting, and secret management), who process data solely on our behalf under confidentiality and security obligations.

6.2 Cross-School Benchmarking. Aggregate, collaborative-wide figures are visible to authorized SPARC/Apte administrators for cross-school benchmarking. Individual school-level detail is visible only to that school's own authorized users and to SPARC/Apte administrators — never to other member schools.

6.3 Future Novi AMS Integration. We intend to integrate sign-in with Novi AMS. When implemented, limited identity information will be exchanged with Novi AMS solely to authenticate your access.

6.4 Legal Requirements. We may disclose information if required by law or legal process, or to protect our rights, safety, or investigate fraud.

6.5 Business Transfers. If Apte is involved in a merger, acquisition, or sale of assets, User information may be transferred as part of that transaction, subject to standard confidentiality protections.

7. Data Retention

We retain account and institutional data for as long as a school's account remains active, and for a reasonable period thereafter to comply with legal obligations and enforce our agreements. A school may request deletion of its data as described in Section 9.

8. Children's Privacy

The Service is intended for school administrators, staff, and SPARC/Apte personnel who are at least 18 years old. It is not directed at children, and we do not knowingly collect personal information from children under 13 (or the applicable age of consent in your state).

Schools and their staff are solely responsible for ensuring that no personally identifiable information about individual students, campers, or other minors is ever entered into the Service. Any such data submitted in violation of this Policy may be removed upon discovery, and the submitting school may be held responsible under our Terms of Service.

9. Your Rights and Choices

Depending on your state of residence, you may have rights to request access to, correction of, or deletion of your personal information, and to opt out of the sale or “sharing” of personal information (we do not sell or share personal information as defined under applicable state privacy laws, including the California Consumer Privacy Act as amended by the CPRA, and similar laws in Virginia, Colorado, Connecticut, Utah, and other states). To exercise these rights, contact diego@apte.com. We will verify and respond within the timeframe required by applicable law.

10. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect information, including encrypted credential storage, role-based access controls, and secured cloud infrastructure. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials.

11. Payments

The Service does not currently collect or process payment card, bank account, or other financial account information from Users. If this changes, this Policy will be updated to describe the payment processor used and applicable safeguards.

12. Smart Summary and Automated Content

The Service includes a “Smart Summary” feature that generates narrative text based solely on numbers already submitted to the Service. This feature is not a substitute for professional financial, accounting, tax, or legal advice. Apte does not guarantee the accuracy, completeness, or suitability of any automatically generated summary, and Users should independently verify any figures or conclusions before relying on them.

13. Third-Party Links

The Service may reference or link to third-party platforms (such as Novi AMS). We are not responsible for the privacy practices of any third-party service, and we encourage you to review their policies separately.

14. International Users

The Service is intended for use within the United States by SPARC member schools. We do not currently direct the Service to, or knowingly process data from, individuals located outside the United States.

15. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify registered Users by email or through a notice on the Service prior to the change taking effect. The “Effective Date” above indicates when it was last revised.

16. Contact Us

Questions about this Privacy Policy or our data practices can be sent to diego@apte.com.