Service Providers, Subprocessors & Data Flow

Last updated: August 8, 2026

This page explains how Learning-Focused uses third-party service providers and subprocessors to deliver learningfocused.com, its online store, and Spark, including the Spark Apps, and how information flows between those services.

For readability, this page may refer to these providers collectively as "subprocessors." A provider's precise legal role may vary depending on the service, the information involved, and applicable law.

This page is intended to support school, district, organizational, and procurement reviews. It should be read together with our company-wide Privacy Policy:
https://learningfocused.com/policies/privacy-policy

For a high-level description of our security practices, see our Security Statement:
https://learningfocused.com/pages/security-statement

1) Services and Data-Flow Overview

Learning-Focused provides products, services, and professional learning resources through:

• learningfocused.com, including its Shopify-hosted online store; and

• Spark, our Thinkific-hosted professional learning platform, including courses, memberships, resources, and the Spark Apps.

At a high level:

1. Website visitors and customers access learningfocused.com and the online store through Shopify.

2. Shopify and its supporting providers process website activity, accounts, carts, checkout, orders, payments, and related commerce information.

3. Spark members access accounts, courses, memberships, resources, and Spark App eligibility through Thinkific.

4. When a user opens a Spark App, the Spark interface communicates with the Spark API hosted on Google Cloud Platform.

5. For AI-assisted features, relevant request content is transmitted from the Spark API to OpenAI through the OpenAI API.

6. The AI-generated response is returned through the Spark API to the user.

7. Spark conversations, bookmarks, Workspace items, or related settings may be preserved when a user chooses or uses a feature that saves them for later access.

Spark and the Spark Apps are designed to function without student names, student identifiers, education records, or other student personal information. Users and organizations must not submit or direct others to submit such information.

2) Current Providers and Subprocessors

Provider	Service and purpose	Information involved	Notes
Shopify	Hosts learningfocused.com and the online store; supports website operation, customer accounts, carts, checkout, orders, commerce, and certain payments	Contact and account information, cart and checkout activity, order and shipping information, payment status, device and usage data, fraud-prevention signals	Payment-card information is processed by Shopify and its payment partners. Learning-Focused does not store full payment-card numbers.
Thinkific	Hosts Spark, including courses, memberships, professional learning resources, account access, and Spark App eligibility; may process Spark purchases	Account and profile information, memberships, enrollments, course activity and progress, purchase and payment status, device and usage data	Used to provide and administer the Spark professional learning platform.
Google Cloud Platform (Google LLC)	Hosts the Spark API and related application services	Spark App requests and responses, user-requested saved content where applicable, and technical, operational, security, and usage metadata needed to provide and protect the service	Application hosting and processing infrastructure for Spark Apps.
OpenAI (API)	Processes relevant AI requests and generates responses for Spark Apps	Relevant Spark App prompts, selections, other request content, generated outputs, and limited technical metadata associated with API processing	Learning-Focused does not opt in to use Spark App data to train or improve OpenAI models.
Google Analytics and applicable Google measurement tools	Website analytics, search-performance measurement, and service-performance analysis	Approximate IP address, device and browser information, referring pages, pages or features used, interaction events, and usage statistics	Used to understand traffic, performance, and general usage. Cookie and opt-out choices may depend on location and website configuration.

Additional provider categories may be used to operate the Services, including Shopify or Thinkific payment partners, shipping and fulfillment providers, email and communications providers, customer-support providers, fraud-prevention providers, tax and accounting providers, and professional advisers. Some of these providers receive information only when the related transaction, communication, or service is used.

Where a provider acts as an independent business or independent controller rather than solely as Learning-Focused's processor, its own privacy notice and terms may also apply.

3) Detailed Data Flow by Service

A. learningfocused.com and the Shopify Online Store

Primary platform: Shopify

Website and store users may browse content, create or use an account, join a mailing list, submit a form, place products in a cart, complete checkout, make a purchase, or contact customer service.

Depending on the activity, Shopify and related commerce providers may process:

• Contact and account information

• Website, device, browser, cookie, and interaction information

• Products viewed, cart contents, checkout activity, and promotional codes

• Billing and shipping information

• Order, payment-status, refund, return, and customer-service information

• Fraud-prevention and transaction-security signals

Shopify and its payment partners process payment-card information. Learning-Focused receives payment status and order information but does not store full payment-card numbers.

When a physical product is ordered, necessary recipient, address, order, and delivery information may be provided to shipping, fulfillment, or delivery providers. Digital products may be delivered through Shopify, Spark, email, download links, or another service identified at purchase.

B. Spark Professional Learning Platform

Primary platform: Thinkific

Thinkific hosts Spark, including:

• Account access and user profiles

• Spark memberships and subscriptions

• Course and professional learning delivery

• Resource access

• Course enrollments, progress, and completion information

• Purchase and payment processing for applicable Spark offerings

• Eligibility and access pathways for Spark Apps

Thinkific may process account information, memberships, enrollments, activity and progress, purchase records, payment status, communications, and device or usage information needed to provide and secure Spark.

C. Spark Apps Within Spark

Application hosting: Google Cloud Platform
AI processing: OpenAI API

The typical Spark App request flow is:

1. An authorized adult user opens a Spark App through Spark.

2. The user submits planning selections, form entries, or a written request.

3. The request is sent to the Spark API hosted on Google Cloud Platform.

4. For an AI-assisted feature, relevant request content is transmitted to OpenAI through the OpenAI API.

5. OpenAI generates a response and returns it to the Spark API.

6. The Spark API returns the response to the user.

7. A conversation, bookmark, Workspace item, or related setting may be retained when the user chooses or uses a feature that preserves it for later access.

Learning-Focused does not use Spark App inputs or outputs to train a generalized artificial intelligence model and does not opt in to use Spark App data to train or improve OpenAI models.

Spark Apps must not be used to submit student names, student identifiers, education records, or other student personal information.

D. Analytics and Measurement

Learning-Focused uses analytics and measurement tools to understand website traffic, referring pages, general product and content interest, device and browser characteristics, website and feature performance, and general usage patterns.

Analytics providers may receive cookie or device identifiers, approximate IP-derived location, pages or features used, referring information, interaction events, and similar technical data. Analytics and advertising-related technologies, if enabled, are subject to the choices and disclosures described in our Privacy Policy.

4) Student Data and K-12 Considerations

• The primary Spark users are adult educators and school- or district-authorized adult users.

• Spark Apps do not provide student accounts and are not directed to children under 13.

• Spark and the Spark Apps are designed to function without student names, student identifiers, education records, or other student personal information.

• Users and organizations must not enter or direct others to enter student personal information into Spark Apps.

• Learning-Focused does not use Spark App inputs or outputs as the sole basis for grading, discipline, eligibility, placement, special education, employment, teacher evaluation, or other consequential decisions concerning a person.

• If student personal information is submitted inadvertently, contact support@learningfocused.com so that Learning-Focused can investigate and take appropriate deletion or other remedial steps.

Unless Learning-Focused expressly agrees otherwise in a written agreement signed by an authorized representative, the Services are not intended to receive or maintain education records or other student personal information on behalf of a school or district.

5) Provider Management and Shared Responsibility

Learning-Focused configures and manages its accounts, access, and application settings within the provider platforms it uses. Each provider maintains its own infrastructure and security controls and is responsible for its services under its agreement with Learning-Focused and applicable law.

Security is a shared responsibility among Learning-Focused, its providers, organizations that purchase or manage access, and individual users. Users and organizations are responsible for protecting credentials, authorizing appropriate users, and avoiding prohibited information.

Where appropriate to the service and provider relationship, Learning-Focused seeks contractual terms addressing confidentiality, security, permitted processing, and applicable data-protection obligations.

6) Retention and Deletion

Retention varies by provider, data type, feature, transaction, and legal requirement. Learning-Focused's general retention practices are described in the Privacy Policy.

• Commerce and transaction information is retained as needed to fulfill orders and comply with tax, accounting, warranty, fraud-prevention, dispute-resolution, and other obligations.

• Spark account, membership, enrollment, and saved-content information is retained while needed to provide the applicable account or feature and for limited administrative, legal, security, or dispute-resolution periods.

• Operational, diagnostic, and security records are retained for limited periods appropriate to service reliability, troubleshooting, abuse prevention, and security.

• Deletion from active systems may take additional time to propagate through encrypted backups maintained on limited backup lifecycles.

Users and authorized organizations may request access, export, correction, or deletion as described in the Privacy Policy, subject to identity and authority verification and applicable legal or technical limitations.

7) School, District, and Procurement Reviews

Schools, districts, and other organizations may contact Learning-Focused to request information reasonably needed for privacy, security, legal, or procurement review.

Where Learning-Focused and an organization enter into a written organizational agreement or data privacy addendum, that agreement may establish additional requirements concerning permitted processing, confidentiality, security incidents, providers and subprocessors, access, export, retention, deletion, and order of precedence over generally applicable online terms.

8) Changes to Providers and Subprocessors

We may update this page as the Services and providers evolve. If we add, replace, or materially change a provider in a way that materially affects how personal information is processed, we will update this page and provide additional notice where required by applicable law or an applicable written organizational agreement.

The date at the top of this page indicates when it was last revised.

9) Contact

Questions about providers, subprocessors, data flow, or organizational review may be directed to:

Learning-Focused
1070 Tunnel Road 10-292
Asheville, NC 28805, USA
Email: support@learningfocused.com