Privacy & Policies

Our Ethical Foundation

Grounded in Professional Standards

SPARC's approach to data privacy is grounded in the professional codes of ethics that govern our practice. As an ICF-credentialed coaching firm and the exclusive U.S. partner of the Academy of Executive Coaching — which holds triple accreditation from the ICF, EMCC Global, and the Association for Coaching — we are bound by two foundational codes of ethics that set the standard for confidentiality, data stewardship, and professional conduct in the coaching profession.

This privacy statement reflects our commitment to the principles set forth in both codes.

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About Us

Who We Are

SPARC Executive Development and Consulting ("SPARC," "we," "us," or "our") operates the website sparcinsights.com. We are committed to protecting your privacy and handling your personal information with care and transparency.

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Data Collection

Information We Collect

We collect personal information in the following ways:

Information You Provide Directly

When you use our contact forms, register for programs such as the Coaching Skills Certificate, or subscribe to our newsletter, we may collect your name, email address, phone number, organizational affiliation, and any additional details you choose to share in a message or inquiry.

Payment Information

When you purchase a program or service through our online store, payment is processed through Squarespace Commerce and its integrated payment providers (such as Stripe). We do not store your full credit card number or payment credentials on our servers. Payment processors receive only the information necessary to complete your transaction.

Assessment and Coaching Engagement Data

In the course of delivering our executive coaching, leader development, and coach training services, we use third-party assessment platforms that collect and process personal information separately from our website. These include Gallup CliftonStrengths, the Leadership Circle Profile, and programs delivered in partnership with the Academy of Executive Coaching (AoEC).

When you participate in an assessment or program, the relevant platform may collect your name, email address, assessment responses, and in some cases demographic information such as age, gender, and race or ethnicity. The Leadership Circle Profile, as a 360-degree assessment, also collects feedback from evaluators you or your organization have selected. Evaluator identities are kept confidential and are not disclosed in your results, with the exception of your direct manager's feedback, which is identified by role.

This assessment data is collected, stored, and processed by the respective platform provider. SPARC receives access to your results in order to support your coaching or development engagement. Each platform maintains its own privacy policy governing how your data is handled (see "Third-Party Services" below).

Information Collected Automatically

When you visit our website, certain information is collected automatically through cookies and similar technologies, including your IP address, browser type, operating system, referring URL, pages visited, and time spent on the site. This information is collected through Squarespace Analytics and Google Analytics.

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Data Use

How We Use Your Information

We use the information we collect for the following purposes:

• Responding to your inquiries and contact form submissions
• Processing program registrations and payments
• Sending our newsletter and occasional updates about SPARC programs and services (only when you have opted in)
• Understanding how visitors use our website so we can improve its content and functionality
• Facilitating assessments and development programs through third-party platforms
• Sharing participant data with accrediting bodies (ICF, EMCC Global, and the Association for Coaching) as required for program accreditation and credentialing
• Fulfilling legal and regulatory obligations

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

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Cookies and Tracking

Cookies

Our use of cookies and similar technologies is described in our Cookie Policy. See it for details on what we set, why, and how to manage them.

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Partners & Platforms

Third-Party Services

We use the following third-party services in connection with our website and professional services:

We encourage you to review the privacy policies of these third-party services, as their practices are governed by their own policies rather than ours.

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Vendor Compliance

Vendor Trademarks

Our use of third-party assessment instruments and frameworks, including CliftonStrengths and the Leadership Circle Profile, is subject to vendor-imposed trademark and copyright obligations. See our Vendor Trademarks & Disclosures policy for the full text of those obligations.

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Our Commitment

Confidentiality

SPARC takes seriously its obligation to protect the privacy and confidentiality of all client information, including assessment results, coaching conversations, and evaluator feedback. Assessment results are shared only with the individual participant and, where applicable, with the sponsoring organization as agreed upon at the outset of the engagement. In multi-rater assessments such as the Leadership Circle Profile, individual evaluator identities are never disclosed to the participant. All SPARC coaches and practitioners are bound by the ethical standards of the International Coaching Federation, which include strict confidentiality requirements.

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Retention

Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes described in this statement, or as required by law. Coaching and assessment engagement records are retained for up to seven years following the conclusion of the engagement, consistent with professional liability and tax record requirements. Contact form submissions and email inquiries are retained for the duration of our business relationship and a reasonable period thereafter. Payment records are retained for up to seven years as required for accounting and tax purposes. Newsletter subscriber information is retained until you unsubscribe. Assessment data held on third-party platforms (Gallup, Leadership Circle, AoEC) is subject to each platform's own retention policies as described in the "Third-Party Services" section.

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Your Privacy

Your Rights

Depending on your location, you may have certain rights regarding your personal information.

For All Visitors

You may request access to the personal information we hold about you, ask us to correct inaccurate information, request deletion of your personal information, and unsubscribe from our newsletter at any time using the link provided in each email.

Additional Rights for Visitors in the EEA and United Kingdom

Under the General Data Protection Regulation (GDPR), you also have the right to request restriction of processing of your personal information, object to processing based on legitimate interests, request a portable copy of your data in a structured, commonly used format, withdraw consent at any time where processing is based on consent, and lodge a complaint with your local data protection supervisory authority (such as the Information Commissioner's Office in the UK or the relevant authority in your EEA member state).

Legal Basis for Processing (GDPR)

Where GDPR applies, we process your personal information on the following legal bases. We rely on your consent when you subscribe to our newsletter or submit a contact form. We rely on contractual necessity when processing payments and delivering programs you have registered for. We rely on legitimate interests when analyzing website usage to improve our services, supporting the effective delivery of contracted coaching and development services, and maintaining professional accreditation records, provided these interests do not override your rights. We rely on legal obligations when retaining records as required by applicable law.

Exercising Rights with Third-Party Assessment Platforms

In addition to the rights you may exercise with SPARC, you may also exercise data rights directly with the third-party platforms used in our services. Gallup allows you to manage your CliftonStrengths sharing settings and request data deletion through your Gallup account. Leadership Circle and the AoEC each support individual rights requests in accordance with GDPR. Contact information for each platform is available through the privacy policy links provided in the "Third-Party Services" section above.

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Protection

Data Security

We take reasonable administrative, technical, and organizational measures to protect your personal information from unauthorized access, loss, misuse, or alteration. Our website is served over HTTPS, and payment processing is handled by PCI-DSS compliant providers. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

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Minors

Children's Privacy

Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete that information.

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International

International Data Transfers

SPARC is based in the United States. If you access our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using our website, you acknowledge this transfer. Where GDPR applies, we will ensure appropriate safeguards are in place for any transfer of personal data outside the EEA.

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Technology

Use of AI Tools

Our use of artificial intelligence tools across business operations, content development, and program delivery is described in our AI Use Policy.

When you visit sparcinsights.com, our site and certain third-party services we use place small data files on your device. These are commonly called cookies, and each one serves a specific purpose described below.

Essential cookies

Squarespace, our website host, sets cookies that are required for the site to function: session management, security features, and remembering items in your store cart while you browse. These cookies do not identify you personally and cannot be disabled without breaking site function.

Analytics cookies

Two services help us understand how visitors use the site:

• Squarespace Analytics. Built into our hosting platform. Tracks aggregate metrics like page views, session duration, and approximate geographic location. Data stays within Squarespace's analytics dashboard.
• Google Analytics. Provides additional traffic analysis. Google may set its own cookies when you visit. See Google's data practices at google.com/policies/privacy/partners.

Analytics cookies do not collect content from forms you submit, your assessment responses, or coaching engagement records.

Third-party embed cookies

Some pages embed services that may set their own cookies when the embedded content loads, for example Calendly when you book a session, or external video players. These cookies are governed by the embedding service's own policy, listed in our Privacy Policy under Third-Party Services.

How to manage cookies

Most web browsers let you control cookies through their privacy settings, typically under Preferences or Settings. You can block or delete cookies for any site, including ours, though doing so may affect parts of the site that rely on essential cookies.

Cookie consent banner

Where required by the ePrivacy Directive, UK PECR, or similar regulations applicable to your location, our website will present a cookie consent banner that allows you to accept or decline non-essential cookies before they are placed on your device. The banner is managed through Squarespace's cookie settings. If you are visiting from a region where consent is required and you do not see a banner, contact us at connect@sparcinsights.com so we can investigate.

This Cookie Policy sits alongside our Privacy Policy and forms part of how SPARC handles your data. For the full set of services that may collect your information, see the Third-Party Services section of the Privacy Policy.

SPARC uses artificial intelligence tools to support our business operations, content development, and the documentation of our programs and coaching engagements. We hold a clear posture: AI assists the work of trained coaches and faculty; it does not replace their judgment.

Where we use AI

We use AI tools across four areas of our work:

• Business operations. Drafting, summarization, research, scheduling, and similar administrative work.
• Content development. First-pass writing and editorial review of materials we then refine.
• Program documentation. Session summaries and draft notes from cohort sessions. A SPARC coach or faculty member reviews and edits the output before it reaches participants.
• Task processing. Files, data, and structured artifacts handled through desktop AI tools that run locally where possible.

What we will not do with AI

We do not use AI to make decisions about whether you receive a credential, whether your work meets a program standard, or any other determination that produces legal or significant personal effects. Those decisions belong to qualified human reviewers and accrediting bodies. We do not enter your coaching content, assessment responses, or confidential client material into publicly accessible AI systems. We do not use AI for content subject to HIPAA, FERPA, or similar regulatory regimes without a separate written agreement appropriate to that material.

Training data and provider settings

Where the AI tools we use offer a setting to disable model training on our content, we disable it. Where a tool routes content through a provider's servers during processing, we select tools whose contractual terms restrict that use to the immediate task. The set of tools we rely on shifts over time as the technology shifts; we adjust accordingly.

Recording and session materials

With your consent, SPARC may record program sessions for cohort supervision, faculty professional development, accreditation requirements, and accurate documentation. Recordings are stored securely and retained for the period required by the relevant accreditation body or by SPARC's records retention policy. You may decline recording of any individual session without penalty, except where a recording is a required component of a program assessment, in which case we will discuss alternatives with you. Recordings used for accreditation submission are subject to the receiving body's confidentiality obligations, which we will summarize on request.

AI-assisted summaries of program work

Where SPARC uses AI tools to draft session summaries or surface themes from a coaching engagement or a program module, a SPARC coach or faculty member reviews the output before it is shared with you. The summary is a working tool for our practice; the relationship and the developmental work remain human.

Right to opt out

You may ask SPARC not to use AI-assisted summarization or task-processing tools in connection with your materials. We will honor the request on written notice to connect@sparcinsights.com. Opt-out does not affect the underlying delivery of your program or coaching engagement.

This policy supplements our Privacy Policy and our Program Terms of Service. For general information about how we handle personal data, see the Privacy Policy. For program-specific recording and assessment provisions, see Program Terms of Service §10.

Several assessment instruments and frameworks SPARC uses in its coaching and development work carry vendor-imposed trademark, copyright, and licensing obligations. The disclosures below are the canonical home for those obligations and apply wherever SPARC discusses or delivers the underlying instruments: on this website, in printed materials, in engagement letters, and in client deliverables.

Gallup CliftonStrengths

The non-Gallup information you are receiving has not been approved and is not sanctioned or endorsed by Gallup in any way. Opinions, views and interpretations of CliftonStrengths, Clifton Youth StrengthsExplorer or BP10 results are solely the beliefs of SPARC LLC.

Dr. Mathew Johnson and Dr. Shannon O'Neill are Gallup-Certified CliftonStrengths Coaches. CliftonStrengths®, StrengthsFinder®, and Gallup® are registered trademarks of Gallup, Inc.

The Leadership Circle Profile

The Leadership Circle Profile® and related models, frameworks, and content are the intellectual property of Conscious Leadership, LLC. They are used by SPARC under license as a Leadership Circle Certified Practitioner. All copyright and ownership rights remain with Conscious Leadership, LLC. SPARC's interpretation, framing, and coaching practice surrounding the LCP are SPARC's own and do not represent the views of Conscious Leadership, LLC.

Academy of Executive Coaching (AoEC)

SPARC delivers AoEC-credentialed programs in the United States under license from the Academy of Executive Coaching Ltd. The Academy of Executive Coaching is accredited by the International Coaching Federation (ICF), EMCC Global, and the Association for Coaching (AC). AoEC curriculum, frameworks, assessment instruments, and related materials remain the intellectual property of AoEC or its licensors. SPARC's interpretations, voice, and delivery practices are SPARC's own and do not represent the views of AoEC.

Where this language applies

These disclosures form part of the assurances SPARC provides to assessment vendors and accrediting bodies. They are reproduced in our coaching engagement, sponsor, and mediation agreements where applicable, and in any proposal or deliverable that describes the underlying instruments.

Version 1.0 · Effective May 17, 2026

Preamble

This participant Enrollment Agreement and Terms of Service (the "Agreement") is between SPARC Associates LLC, a Vermont limited liability company doing business as AoEC USA (referred to in this Agreement as "SPARC," "we," or "us"), and the individual who has submitted an application to enroll in a SPARC program (the "participant," "you," or "your").

This Agreement governs your enrollment in any program, course, workshop, certificate, diploma, accreditation, or other educational offering delivered by SPARC, whether in person, virtually, or in a hybrid format ("Programs"). This Agreement takes effect when SPARC issues written acceptance of your application or when you make a payment toward a Program, whichever happens first (the "Effective Date").

1. What This Agreement Covers

1.1 Scope. This Agreement applies to every Program SPARC delivers, including the Practitioner Diploma in Executive Coaching, Professional Practitioner Diploma, Coaching Skills Certificate, Coaching Tools Certificate, and any other Program SPARC offers under license from the Academy of Executive Coaching ("AoEC") or independently.

1.2 Order of precedence. If SPARC issues a Program-specific addendum, schedule, or order form that conflicts with this Agreement, the Program-specific document controls for that Program only.

1.3 Updates. SPARC may update this Agreement from time to time. Changes do not affect a Program for which you have already enrolled and paid, unless the change is required by law or you and SPARC agree in writing. The current version of this Agreement will be posted on SPARC's website with the version date.

2. Definitions

The following terms have the meanings given below:

• "Assessment Day" means the day or days on which a Program's formal assessments are scheduled.
• "Business Day" means Monday through Friday, excluding US federal holidays.
• "Cohort" means the group of participants enrolled in a specific scheduled instance of a Program.
• "Module" means one or more consecutive training days that form part of a multi-Module Program.
• "Program" has the meaning given in the Preamble.
• "Sponsor" means an employer, foundation, scholarship fund, or other organization that pays Tuition on behalf of a participant.
• "Start Date" means the first scheduled day of a Program or the date SPARC provides you access to Program materials.
• "Tuition" means the fees and any related charges associated with a Program, as published by SPARC or stated on an invoice.

3. AoEC Accreditation, Licensing, and Use of Materials

3.1 AoEC accreditation. SPARC delivers several Programs under a credentialed-organization relationship with the Academy of Executive Coaching (AoEC). For those Programs, SPARC follows AoEC's curriculum, assessment, and quality standards.

3.2 Third-party accreditation bodies. Many AoEC Programs are recognized by the International Coaching Federation (ICF), the European Mentoring and Coaching Council (EMCC), and the Association for Coaching (AC). The list of accreditation bodies applicable to your Program will be identified in your Program materials.

3.3 Use of AoEC materials. All curriculum, frameworks, assessment instruments, written materials, recordings, and other intellectual property used in AoEC-licensed Programs are owned by AoEC or its licensors. SPARC delivers them to you under a written license from AoEC.

3.4 Limited participant license. Subject to your payment of Tuition and compliance with this Agreement, SPARC grants you a personal, non-exclusive, non-transferable, non-sublicensable license to use SPARC and AoEC Program materials solely for your own learning and continuing professional development. You may not copy, distribute, modify, sell, or commercially exploit any Program materials without SPARC's prior written consent.

3.5 Vendor trademark disclosures. Where a Program uses third-party assessment instruments, including CliftonStrengths® and the Leadership Circle Profile®, those instruments carry vendor-imposed trademark, copyright, and licensing obligations. The full text of those obligations is set out in SPARC's Vendor Trademarks & Disclosures policy, which is incorporated into this Agreement by reference.

4. Tuition and Payment

4.1 Tuition rates. Tuition for each Program is published on SPARC's website and confirmed on your enrollment invoice. All amounts are in US Dollars.

4.2 Sales and use tax. SPARC's professional education services are generally exempt from Vermont sales and use tax. If a Program includes taxable goods or in-person services that become subject to tax, SPARC will state the applicable tax on the invoice and you agree to pay it.

4.3 Payment due dates. Your place in a Cohort is confirmed only when SPARC receives full Tuition in cleared funds or, if you have selected an installment plan under Section 4.6, the first installment has been received. If your Program begins within 30 days of the invoice date, Tuition is due on receipt of the invoice. If your Program begins more than 30 days from the invoice date, Tuition is due within seven (7) calendar days of the invoice date.

4.4 Payment methods. SPARC accepts ACH bank transfer, credit card (subject to a processor fee passed through to you), and check made payable to "SPARC Associates LLC." Wire transfers are accepted by prior arrangement; bank charges associated with any wire are your responsibility.

4.5 Advanced Booking Rate. Where SPARC publishes an Advanced Booking Rate for a Program, you qualify only if full Tuition (or the first installment under an installment plan) is received by the date stated on the invoice. Late payment forfeits the discount and the standard rate becomes payable.

4.6 Installment plans. Where SPARC offers an installment plan for a Program, the plan terms are set out on the invoice or in a separate installment-plan addendum. If you withdraw from a Program before completion, all remaining installments remain due except as provided in Section 6 (Cancellation by participant). Where a third-party financing provider services the plan, you enter into a separate credit agreement with that provider; SPARC is not party to that agreement.

4.7 Reminders and withdrawal for non-payment. SPARC will issue up to two payment reminders. If Tuition remains unpaid after the second reminder, SPARC may withdraw you from the Program and reassign your place. Withdrawal for non-payment does not relieve you of any unpaid Tuition obligation that has accrued.

4.8 Late charges. Past-due amounts accrue interest at the lesser of one and one-half percent (1.5%) per month or the maximum rate permitted by Vermont law under 9 V.S.A. § 41a, together with SPARC's reasonable costs of collection (including reasonable attorneys' fees and court costs).

4.9 Deposits. Where SPARC accepts a deposit to hold your place in a Program, the deposit is non-refundable except as required by Vermont consumer-protection law (see Section 17) or where SPARC cancels under Section 7.

5. Sponsor-Funded Enrollments

5.1 Sponsor agreements. If a Sponsor is paying your Tuition, your enrollment is also subject to the written agreement between SPARC and the Sponsor. Where the Sponsor agreement and this Agreement conflict as to financial terms, the Sponsor agreement controls those terms.

5.2 What we share with the Sponsor. SPARC will share with the Sponsor only what is necessary for Program administration: confirmation of enrollment, attendance, and Program completion status. SPARC will not share your assessment results, coaching content, recordings, or learning reflections with the Sponsor unless you provide separate written authorization in advance.

5.3 Your obligations remain. You remain responsible to SPARC for your compliance with this Agreement, including conduct and attendance requirements, regardless of who pays your Tuition.

6. Cancellation by participant

6.1 How to cancel. You may cancel your enrollment at any time. To cancel, send written notice by email to connect@sparcinsights.com during SPARC's regular business hours (9:00 a.m. – 5:00 p.m. Eastern Time, Monday through Friday). Notice is effective when SPARC's email server receives it during business hours; otherwise on the next Business Day at 9:00 a.m. Eastern.

6.2 Refund schedule. SPARC will refund Tuition you have paid (less any non-refundable deposit) according to the following schedule, based on the number of calendar days between SPARC's receipt of your cancellation notice and the Program Start Date:

• 30 or more calendar days before Start Date: Full refund of Tuition paid, less any non-refundable deposit.
• 15–29 calendar days before Start Date: 50% refund of Tuition paid.
• 0–14 calendar days before Start Date, or after Start Date: No refund.

6.3 Single-day workshops and events. Tuition for single-day workshops, events, or sessions priced under $500 is non-refundable once the event begins; cancellations made at least 48 hours before the start time are refundable in full.

6.4 Mentor coaching and individual sessions. Individual or group mentor coaching sessions cancelled or rescheduled with less than 24 hours' notice are forfeited (or, where the session is part of a Program package, count as a used session). Three forfeited sessions in a single Program may be treated as an incomplete Program component under Section 8.

7. Cancellation or Changes by SPARC

7.1 SPARC may cancel or reschedule. SPARC may cancel, reschedule, or change the delivery format of any Program, including changes to dates, faculty, modality (in-person, virtual, or hybrid), venue, or content. If SPARC cancels a Program outright and you have not received the Program services for which you paid, SPARC will refund the Tuition you have paid for the cancelled Program.

7.2 Schedule and faculty changes. Reasonable adjustments to schedule, faculty, or modality do not entitle you to a refund. SPARC will use commercially reasonable efforts to maintain the published Program quality and structure.

7.3 Venue changes. Where SPARC changes the venue for an in-person Program, you remain responsible for your own travel and accommodation costs. SPARC is not liable for non-refundable travel expenses arising from a venue change.

8. Transfers, Deferrals, and Completion

8.1 Attendance is required. SPARC's Programs are cohort-based. To complete a Program and qualify for any associated certification, you must attend all Modules and Assessment Days with your enrolled Cohort.

8.2 Transfers and deferrals. Before a Program's Start Date you may request, in writing, to transfer to another scheduled instance of the same Program. SPARC may grant the request subject to capacity and Program scheduling. You may transfer or defer no more than twice for the same Program. Each transfer or deferral request is subject to a $300 administrative fee, payable on invoice and non-refundable.

8.3 Make-up windows. If you miss a Module after starting a Program, you have up to six (6) months from the missed Module to complete the missed content with another Cohort, and up to twelve (12) months to complete any in-person element. If you do not complete the missed components within these windows, SPARC may require you to re-enroll in the full Program at your cost.

8.4 Missed mentor or assessment sessions. Missed individual mentor coaching sessions, failure to provide a coaching demonstration recording on time, or missed re-submissions of assessed work may incur a make-up fee of $200 per occurrence. Three or more occurrences in a single Program may be treated as an incomplete Program at SPARC's discretion.

8.5 Substitutions for Sponsor-funded enrollments. Where a Sponsor wishes to substitute one individual for another from the same organization on a SPARC Program, SPARC may, in its discretion, permit the substitution subject to a charge equal to ten percent (10%) of the Tuition.

9. Code of Conduct and Program Rules

9.1 Expected conduct. You agree to participate in good faith, treat faculty and fellow participants with respect, and comply with SPARC's Code of Conduct, which is published at SPARC's Code of Conduct. SPARC may dismiss you from a Program for material breach of the Code.

9.2 Code of Conduct. Your participation in any SPARC Program is also subject to SPARC's Code of Conduct, which is incorporated into this Agreement by reference. The Code covers attendance, punctuality, preparation, participation, mutual respect, cohort confidentiality, recording, virtual session etiquette, in-person decorum, language, and the consequences of material breach.

9.3 Dismissal and refund. Dismissal from a Program for material breach of this Agreement or the Code of Conduct does not entitle you to a refund of Tuition paid. The refund schedule in §6.2 applies as if you had cancelled on the dismissal date.

10. Recordings and AI Tools

SPARC's use of AI tools and its posture on session recording is set out in SPARC's AI Use Policy, which is incorporated into this Agreement by reference. That policy covers where SPARC uses AI, what it will not do with AI, training-data and provider settings, recording purposes and confidentiality, AI-assisted summaries, and your right to opt out.

11. Privacy and Data Protection

11.1 General privacy posture. SPARC handles your personal information in accordance with our Privacy Policy, which is incorporated into this Agreement by reference. The Privacy Policy describes the categories of information we collect, how we use it, and how it is stored.

11.2 Sharing with accreditation bodies. For Programs accredited by the ICF, EMCC, AC, or AoEC, SPARC may share Cohort data (names, contact information, written feedback, assessment material, and, where required, audio or video recordings) with the relevant accreditation body for the purpose of accreditation review and quality assurance. Those bodies treat such material under their own confidentiality obligations.

11.3 FERPA. SPARC is a Vermont limited liability company and is not an educational institution subject to the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g. Nothing in this Agreement creates a FERPA-protected record. If you are enrolling through a Sponsor that is FERPA-regulated, your separate relationship with that Sponsor may be FERPA-governed; SPARC's relationship with you under this Agreement is not.

11.4 State privacy rights. SPARC complies with the Vermont Data Privacy Act and any other state privacy law applicable to its operations. Where you are a resident of a US state with a comprehensive consumer privacy law (such as California, Colorado, Connecticut, Virginia, or Utah), you have the rights granted by that state's law, including the right to access, correct, or delete personal information, subject to legitimate exceptions. To exercise these rights, contact connect@sparcinsights.com.

11.5 Marketing consent. During enrollment you will be asked whether you wish to receive marketing communications from SPARC. You may withdraw consent at any time through the unsubscribe link in our emails or by contacting connect@sparcinsights.com.

12. Reasonable Accommodations and Inclusive Learning

12.1 Inclusion and accommodations. SPARC's inclusion commitment and the process for requesting reasonable accommodations are set out in SPARC's Inclusion & Accommodations Policy, which is incorporated into this Agreement by reference. That policy describes SPARC's approach to inclusion across cohort programs, how to request an accommodation in advance or during a Program, and how to give feedback.

12.2 ADA compliance. SPARC complies with applicable federal disability law, including Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.

13. Medical Information and On-Site Health and Safety

13.1 Pre-existing conditions. If you have a pre-existing medical condition or accessibility requirement relevant to your Program, please inform SPARC in writing at least 10 calendar days before your Program's Start Date.

13.2 On-site safety. For in-person Programs, responsibility for on-site health and safety (including first aid and emergency procedures) rests with the venue operator. SPARC will exercise reasonable care in selecting venues but is not liable for the venue's failures.

13.3 Emergency assistance. SPARC will take reasonable steps to support your safety during a Program, including assisting with access to emergency medical services where needed.

13.4 Liability. SPARC accepts no liability for illness, injury, or medical incident during a Program unless caused by SPARC's negligence. Nothing in this Agreement limits liability for personal injury or death caused by SPARC's negligence to the extent such limitation is not permitted by Vermont law.

14. Intellectual Property

14.1 Ownership. All intellectual property in SPARC's and AoEC's Program materials, documentation, frameworks, recordings, and assessment instruments remains the property of SPARC, AoEC, or their respective licensors.

14.2 Your license. Section 3.4 grants you a limited license to use Program materials for personal learning and continuing professional development.

14.3 Your work product. You retain ownership of original work you create in response to Program assignments (for example, reflective writing or coaching practice plans). You grant SPARC and AoEC a non-exclusive, royalty-free license to use anonymized excerpts of your work product for assessment, calibration, accreditation, and faculty training purposes.

14.4 Use of SPARC and AoEC marks. After successful completion of a Program, you may describe yourself accurately as a graduate of that Program (for example, "Practitioner Diploma in Executive Coaching, SPARC / AoEC"). You may not use the SPARC, AoEC USA, or AoEC names, logos, or marks in a way that suggests SPARC endorses your independent services without SPARC's prior written consent.

15. Disclaimers and Limitation of Liability

15.1 No guarantee of outcome. SPARC delivers Programs and supports your learning. SPARC does not guarantee that you will pass any assessment, receive any certification, or achieve any specific professional or business outcome. Whether you obtain a coaching credential from ICF, EMCC, AC, or AoEC depends on those bodies' independent decisions.

15.2 No professional advice. Programs are educational. Nothing in a Program is legal, medical, financial, tax, or psychological advice. You are responsible for consulting qualified professionals as appropriate.

15.3 Limitation of liability. To the fullest extent permitted by Vermont law, SPARC's total aggregate liability under or in connection with this Agreement, whether in contract, tort (including negligence), warranty, or otherwise, will not exceed the total Tuition you have paid to SPARC under this Agreement.

15.4 Excluded damages. To the fullest extent permitted by Vermont law, SPARC is not liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, lost business, lost earnings, lost data, or loss of goodwill, arising out of or in connection with this Agreement.

15.5 What this does not limit. Nothing in Section 15 excludes or limits liability for (a) death or personal injury caused by SPARC's negligence; (b) fraud or fraudulent misrepresentation; (c) any other liability that cannot be excluded or limited under Vermont or US federal law.

16. Force Majeure

16.1 Defined. "Force Majeure Event" means a circumstance beyond SPARC's reasonable control, including acts of God, fire, flood, severe weather, earthquake, pandemic, epidemic, public health emergency, governmental action or order, terrorism, war, civil unrest, labor action, internet or telecommunications failure, and utility failure.

16.2 Effect. SPARC is not liable for any delay or failure to perform under this Agreement that is caused by a Force Majeure Event. Where possible, SPARC will offer an alternative date, an alternative delivery format (for example, switching an in-person session to virtual), or a credit toward a future Program. If reasonable alternatives are not available, SPARC will refund Tuition for undelivered Program services. Such refund is SPARC's sole liability, and your sole remedy, for non-performance caused by a Force Majeure Event.

16.3 Your costs. SPARC is not responsible for your travel, accommodation, or related expenses arising from a Force Majeure Event.

17. Vermont Consumer Protection

17.1 Statutory rights preserved. Nothing in this Agreement waives any right or remedy granted to you by the Vermont Consumer Protection Act, 9 V.S.A. § 2451 et seq., or by any other federal or state consumer-protection law that applies to your enrollment and cannot be waived by contract.

17.2 Misleading statements. If you believe SPARC has made a material misrepresentation about a Program's content, delivery, or accreditation status, contact SPARC at connect@sparcinsights.com so SPARC can investigate and address the issue.

18. Complaints and Refunds

18.1 Step 1 — Speak to faculty or Program Manager. If you have a concern about how a Program is being delivered, raise it with the faculty member or Program Manager identified in your Program materials. SPARC asks that you raise concerns by the end of the first Module so that they can be addressed promptly.

18.2 Step 2 — Formal complaint. If a concern is not resolved informally, you may submit a written complaint to SPARC's Head of Programs at connect@sparcinsights.com within seven (7) calendar days of the issue. SPARC will acknowledge and respond within seven (7) Business Days.

18.3 Step 3 — Escalation. If you are unsatisfied with SPARC's response, you may escalate in writing to SPARC's principal at mathew@sparcinsights.com, including the original complaint and the reasons for escalation. SPARC will issue a final written decision within seven (7) Business Days. SPARC's internal complaint process does not affect your rights under Section 17 or under Section 19 (dispute resolution).

18.4 Refunds tied to complaints. Refunds are considered only where there has been a clear and demonstrable failure to deliver the core advertised Program content. Personal preference about faculty style, pedagogical method, or pace is not, by itself, a ground for refund.

19. Dispute Resolution — Binding Arbitration; Class Action Waiver; Jury Waiver

Please read this Section carefully. It limits the ways you can resolve disputes with SPARC.

19.1 Mandatory informal resolution. Before either of us initiates an arbitration, the party with the complaint must give the other party written notice describing the dispute and a proposed resolution. The parties will then attempt in good faith to resolve the dispute through direct discussion for at least 30 days from the date the notice is received.

19.2 Binding arbitration. Any dispute, claim, or controversy arising out of or relating to this Agreement, the Programs, or SPARC's services (a "Dispute") that is not resolved under Section 19.1 will be resolved by binding arbitration administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules then in effect, except as modified by this Section. The Federal Arbitration Act, 9 U.S.C. §§ 1–16, governs the interpretation and enforcement of this arbitration agreement.

19.3 Seat and venue. The arbitration will be seated in Washington County, Vermont. Arbitration may be conducted by video conference at the arbitrator's discretion. If you reside outside Vermont, the arbitrator may move any in-person hearing to a location convenient to both parties.

19.4 Arbitrator authority. The arbitrator will have authority to award any remedy that would be available in court under Vermont law, subject to the limitations in this Agreement. The arbitrator's award is final and may be entered in any court of competent jurisdiction.

19.5 Class action waiver. YOU AND SPARC EACH AGREE THAT ANY DISPUTE WILL BE BROUGHT IN AN INDIVIDUAL CAPACITY ONLY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING. The arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding. If this Section 19.5 is found to be unenforceable, then the entirety of this Section 19 is null and void, but the rest of this Agreement remains in effect.

19.6 Jury trial waiver. TO THE FULLEST EXTENT PERMITTED BY LAW, YOU AND SPARC EACH KNOWINGLY AND VOLUNTARILY WAIVE ANY RIGHT TO A TRIAL BY JURY OF ANY DISPUTE THAT IS NOT REQUIRED TO BE ARBITRATED UNDER THIS SECTION 19.

19.7 Small-claims carveout. Either party may bring an individual claim in small-claims court for any Dispute within the small-claims court's jurisdictional limits, in lieu of arbitration.

19.8 Injunctive relief. Either party may seek injunctive or other equitable relief in a court of competent jurisdiction in Vermont to prevent or stop an actual or threatened breach of confidentiality, intellectual property, or the class action waiver. Seeking such relief does not waive that party's right to arbitrate the underlying Dispute.

19.9 Arbitration costs. SPARC will pay AAA filing and arbitrator fees for which SPARC is responsible under the AAA Consumer Arbitration Rules. Each party otherwise bears its own attorneys' fees and costs, except that the arbitrator may award attorneys' fees and costs to the prevailing party where authorized by applicable law.

19.10 Severability of arbitration provisions. If any provision of this Section 19 (other than Section 19.5) is found to be unenforceable, that provision will be severed and the remainder will continue in effect.

20. Governing Law; Venue for Non-Arbitrable Matters

20.1 Governing law. This Agreement is governed by, and construed in accordance with, the laws of the State of Vermont, without regard to its conflict-of-laws principles, and applicable US federal law.

20.2 Venue. For any Dispute that is not subject to arbitration under Section 19, including a claim for injunctive relief under Section 19.8, the parties consent to the exclusive jurisdiction of the state courts of Washington County, Vermont, and the United States District Court for the District of Vermont.

21. General Provisions

21.1 Entire Agreement. This Agreement (together with any Program-specific addenda, SPARC's Privacy Policy, AI Use Policy, Code of Conduct, Inclusion & Accommodations Policy, Vendor Trademarks & Disclosures policy, and any signed enrollment instrument) is the entire agreement between you and SPARC regarding your enrollment, and supersedes all prior discussions, correspondence, and agreements on the subject.

21.2 Severability. If any provision of this Agreement is found unenforceable, the remaining provisions remain in full effect, and the unenforceable provision will be reformed only to the extent necessary to make it enforceable.

21.3 No waiver. SPARC's failure to enforce any provision is not a waiver of that or any other provision.

21.4 Assignment. SPARC may assign this Agreement to an affiliate or successor in connection with a reorganization, merger, or sale of all or substantially all of SPARC's assets, provided that the assignee assumes SPARC's obligations. You may not assign this Agreement without SPARC's prior written consent.

21.5 No third-party beneficiaries. This Agreement is for the benefit of you and SPARC only. No other person or entity has rights under this Agreement.

21.6 Notices. Notices under this Agreement may be given by email. Notices to SPARC should be sent to connect@sparcinsights.com and notices to you will be sent to the email address you provided during enrollment. Either party may change its notice address by written notice to the other.

21.7 Independent contractors. Nothing in this Agreement creates an employment, partnership, agency, or joint-venture relationship between you and SPARC.

21.8 Counterparts; electronic signature. This Agreement may be signed in counterparts and by electronic signature, each of which is an original and all of which together constitute one instrument.

21.9 Headings. Section headings are for convenience only and do not affect interpretation.

Legal entity: SPARC Associates LLC, registered in Vermont, d/b/a AoEC USA.

SPARC was founded to bring rigorous adult-development theory and practice into rooms that don't always make space for it. Inclusion is not a side project for us; it is the precondition for the developmental work we do. People learn from the inside out, which requires being met as they are.

Our programs are designed using the experiential learning model that the Academy of Executive Coaching has refined over more than two decades. Faculty model coaching practice during delivery rather than instructing from the front of the room. Cohorts are small enough that every participant is known by name. Peer triads and supervision groups create more than one channel for participation, so quieter voices get heard and dominant voices stay in proportion.

What this looks like in practice:

• We welcome neurodivergent participants. Faculty are trained to recognize that processing pace and engagement style vary across the room, and to adjust delivery accordingly. Materials are available in advance for participants who prefer to prepare ahead.
• We support physical, sensory, and cognitive accessibility needs. Closed captioning is available on virtual sessions. In-person venues are selected with accessibility in mind. Where a venue falls short, we work with you to identify alternatives.
• We honor confidentiality across the cohort. Participants share at the level they choose; what is said in the room stays in the room.
• We coach in plain language. Jargon, when it appears, is explained on first use. Faculty check for understanding rather than assuming it.

How to request accommodations

If you need an accommodation due to a disability or health condition, write to us at connect@sparcinsights.com when you apply, or at least ten calendar days before your program starts. We will work with you in good faith to identify what supports meaningful participation while preserving program integrity. We do not generally require documentation, and any documentation we ask for will be limited to what is necessary to identify a reasonable accommodation.

You can also share what you need at any point during your program: in writing, in conversation with faculty, or in your small peer group. Asking is not a failure; it is the same posture we ask leaders to take with their own teams.

How to give feedback

If something is not working, tell us. Your first contact is the faculty member or program manager named in your materials. If that conversation does not resolve the issue, write to Mathew Johnson at mathew@sparcinsights.com. We will respond within seven business days.

Inclusion is a practice. We keep learning from the participants who notice what we miss.

Compliance

SPARC complies with Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq., and applicable Vermont and federal accessibility law. This policy supplements the legal accommodations process described in our Program Terms of Service §12.

SPARC programs run on the trust and contribution of the cohort. You will get more from a SPARC program than from many other forms of professional development because we ask more of you, and we ask the same of every participant. The rules below describe what we ask. They are simple, they apply equally, and they make the room a place where serious work can happen.

Attendance

Cohort programs are designed as continuous arcs. Material in one module presupposes the conversations and practice that happened in earlier modules. You are expected to attend every module of your program live, with your cohort, from start to finish. If a circumstance requires you to miss part of a module, contact your program manager before the absence so we can plan for the missed content. Missed components must be made up within the windows described in Program Terms of Service §8.

Punctuality

Arrive at each module ready to begin at the scheduled start time. Late arrivals interrupt the cohort. If a session begins at 9:00 a.m., we begin together at 9:00 a.m.

Preparation

Where pre-work is provided, complete it before the session. Where reading is assigned, read it. Faculty will not recap pre-work content during live sessions; the work in the room builds on what you brought to it.

Participation

Participate fully and in good faith. Speak when you have something to contribute. Listen without rehearsing your reply. Stay with discomfort when something challenges you, rather than retreating from it. The peer triads and supervision groups exist so that everyone has multiple channels to engage; use them.

Respect for one another

SPARC does not tolerate harassment, discrimination, or retaliation based on race, color, religion, sex, gender identity, sexual orientation, national origin, age, disability, veteran status, or any other characteristic protected by law. Reports of harassment may be made confidentially to mathew@sparcinsights.com or shannon@sparcinsights.com and will be investigated promptly.

Confidentiality of the cohort

What is shared in the room stays in the room. You may share your own learning, reflections, and questions with anyone you choose. You may share your own learning de-identified, in ways that do not identify other participants or their material. You may not share other participants' content, stories, recordings, or coaching practice without their explicit written consent.

Recording

You may not record any session, in any format, without SPARC's prior written consent. SPARC may record sessions for accreditation, supervision, and quality purposes, and will inform you where recording is happening. Our full posture on recording and AI-assisted documentation is set out in our AI Use Policy.

Virtual session etiquette

Join sessions from a quiet space with a stable connection. Keep your camera on unless a specific accommodation has been agreed in advance. Coaching practice requires presence, which requires being seen. Mute when you are not speaking. Avoid multitasking; the session has your attention or it does not.

In-person decorum

Treat the venue, the faculty, and your fellow participants with respect. Follow venue rules. Manage your own breaks and refreshments per the program schedule.

Language

Programs delivered in the United States are conducted in English. You must be able to coach in English and to be coached in English. If this is a concern, contact us before enrolling.

If something goes wrong

Material breach of these rules may result in dismissal from the program without refund, as set out in Program Terms of Service §6 and §9. Material breach includes bad-faith participation, harassment of another participant, repeated unexcused absence, breach of cohort confidentiality, and unauthorized recording. For broader complaints about a program or how these rules were applied, the formal complaint and escalation process is set out in Program Terms of Service §18.

These rules sit alongside our Program Terms of Service and our Inclusion & Accommodations Policy. They set the floor that lets serious work happen on top.