Privacy Policy
Last Updated: January 15, 2025
At Luminous Sparkflow, we believe transparency builds trust. This privacy policy explains what information we collect when you use our financial analysis education platform, why we need it, and how we protect it. We're based in Vietnam but serve students globally, so we've structured our practices to meet both Vietnamese regulations and international standards.
Information We Collect
We collect different types of information depending on how you interact with our platform. Most of this happens when you create an account or enroll in our programs.
Account Information
When you sign up, we ask for basics like your name, email address, and phone number. If you're enrolling in paid courses, we'll need billing details too. We store this in encrypted databases located in Singapore, with backup servers in Tokyo for redundancy.
Learning Activity Data
We track your progress through courses, quiz scores, and which materials you access. This helps us personalize your learning experience and figure out which content actually works. For instance, if everyone struggles with a particular module on ratio analysis, that tells us we need to rework it.
- Course completion rates and time spent on each module
 - Assessment results and practice exercise submissions
 - Discussion forum posts and peer interaction records
 - Resource downloads and video playback statistics
 
Technical Data
Like most websites, we automatically collect technical stuff. Your IP address, browser type, device information, and how you navigate our site. This helps us fix bugs and improve performance. We noticed our video player was crashing on older Android devices last year, which we only caught because of this data.
How We Use Your Information
Everything we collect serves a purpose. We're not in the business of hoarding data for the sake of it.
Educational Service Delivery: Your learning data helps us provide personalized course recommendations and adaptive content. If you're excelling at financial statement analysis but struggling with budgeting concepts, our system adjusts accordingly.
- Processing course enrollments and managing your account access
 - Sending important updates about your courses or platform changes
 - Providing technical support when something goes wrong
 - Analyzing aggregate patterns to improve our curriculum
 - Preventing fraud and maintaining platform security
 
We occasionally send educational newsletters, but you can opt out anytime. Just hit the unsubscribe link at the bottom of any email. We're not offended.
Information Sharing and Disclosure
We don't sell your personal information. Period. But we do share data with certain partners who help us run the platform.
Service Providers
We work with third-party companies for specific functions. Our payment processor handles transactions, our email service sends course notifications, and our hosting provider keeps the servers running. These companies can only use your data for the specific services they provide us.
Legal Requirements
If Vietnamese authorities request information under applicable law, or if we need to protect our legal rights, we may disclose data. This has happened exactly twice since we started in 2022, both times related to suspected payment fraud.
Business Transfers
If Luminous Sparkflow merges with another company or gets acquired, your information would transfer to the new entity. You'd be notified beforehand, and you could delete your account if you're uncomfortable with the change.
Data Storage and Security
We use industry-standard encryption both for data in transit and at rest. That means when information travels between your device and our servers, and when it sits in our databases, it's encrypted using AES-256 protocols.
Our servers are in professionally managed data centers with physical security controls. Access to production systems is restricted to essential personnel who've signed confidentiality agreements. We also run regular security audits and penetration testing to find vulnerabilities before anyone else does.
Important Note: No system is completely secure. While we implement strong protections, we can't guarantee absolute security. If you notice anything suspicious with your account, contact us immediately at the details provided at the end of this policy.
Your Rights and Choices
Under Vietnamese law and our commitment to data protection, you have several rights regarding your personal information.
- Access: You can request a copy of all personal data we hold about you. We'll provide this in a readable format within 30 days.
 - Correction: If any of your information is incorrect or outdated, you can update it directly in your account settings or ask us to fix it.
 - Deletion: You can request complete account deletion. We'll remove your personal data within 60 days, though we may retain certain records for legal compliance.
 - Portability: You can download your learning progress, course completion records, and other data to take elsewhere.
 - Objection: You can object to certain data processing activities, particularly marketing communications.
 
To exercise any of these rights, send an email to our privacy team using the contact information below. We'll verify your identity and process your request as quickly as possible.
Cookies and Tracking Technologies
We use cookies to keep you logged in, remember your preferences, and understand how people use our platform. Some are essential for the site to function, while others help us improve the experience.
Types of Cookies We Use
- Essential Cookies: Keep you logged in and remember your language preference. These can't be disabled without breaking basic functionality.
 - Analytics Cookies: Help us understand which features get used and where people get stuck. We use this to prioritize improvements.
 - Performance Cookies: Monitor page load times and technical issues so we can fix problems quickly.
 
You can manage cookie preferences in your browser settings, though disabling certain cookies might affect your experience on the platform.
Children's Privacy
Our platform is designed for adults and students aged 16 and older. We don't knowingly collect information from anyone under 16. If you're a parent and believe your child has created an account, contact us and we'll delete it immediately.
Data Retention
We keep your active account data for as long as you're enrolled in courses or using our services. After you delete your account, we retain some information for specific periods based on legal requirements.
- Financial records: 7 years as required by Vietnamese accounting regulations
 - Course completion certificates: Permanently, since students may need verification years later
 - Support correspondence: 3 years for quality assurance purposes
 - Marketing preferences: Until you unsubscribe or delete your account
 
We review our retention practices annually and delete data that's no longer necessary. Some anonymized, aggregated data may be kept indefinitely for research purposes since it can't be traced back to individuals.
International Data Transfers
While we're based in Vietnam, we use service providers located in other countries. This means your data might be processed in Singapore, Japan, or the United States where our infrastructure partners operate.
We ensure these transfers comply with Vietnamese data protection regulations and use standard contractual clauses approved by relevant authorities. All our international partners must maintain security standards equivalent to what we provide directly.
Changes to This Policy
We update this privacy policy occasionally to reflect new practices or legal requirements. When we make significant changes, we'll notify you via email and post a prominent notice on the platform. The date at the top of this page shows when it was last updated.
If you continue using our services after changes take effect, that means you accept the updated policy. If you disagree with changes, you can delete your account before they go into effect.
Contact Us
Questions about this privacy policy or how we handle your data? We're here to help.
Email: contact@luminous-sparkflow.com
Phone: +84 26 3375 6301
Address: 242 Đ. Nguyễn Văn Luông, Phường 11, Quận 6, Thành phố Hồ Chí Minh, Vietnam
We typically respond to privacy inquiries within 48 hours on business days.