Privacy Policy

1. Who we are

Accrue is operated by Vince Kosik, a sole trader based in Malta (“we”, “us”, “our”). We are the data controller responsible for your personal data. For any privacy question or to exercise your rights, contact us at accrue4u@gmail.com.

2. What data we collect

• Account data: your email address and an encrypted password, handled by our authentication provider.
• Study data: the questions you answer, whether your answers were correct, and timestamps, so we can show your progress and statistics.
• Payment data: if you subscribe, your payment is processed by Stripe. We do not see or store your full card details. We store a customer and subscription reference and your subscription status.
• Technical data: essential cookies used to keep you signed in, and basic technical information needed to deliver the service.

3. Why we use it and our legal basis

We process your data to provide the service you have asked for (performance of a contract), to take payment for a subscription you choose, and to keep the service secure and working. Where we rely on legitimate interests, such as preventing abuse, we balance these against your rights.

4. Cookies

We use only essential cookies that are needed to sign you in and keep your session active. We do not use advertising or third-party tracking cookies.

5. Who we share data with

We use a small number of trusted providers (sub-processors) to run Accrue:

• Supabase - authentication and database hosting, hosted in the European Union.
• Stripe - payment processing for subscriptions.
• Vercel - application hosting and delivery.

We do not sell your personal data to anyone.

6. International transfers

Your core account and study data are hosted within the European Union. Some providers, such as Stripe, may process data outside the EU. Where that happens, the transfer is protected by appropriate safeguards such as the European Commission standard contractual clauses.

7. How long we keep it

We keep your account and study data for as long as your account is active. If you delete your account or ask us to erase your data, we remove it within a reasonable period, except where we are required to keep certain records, for example billing records for tax purposes.

8. Your rights

Under the EU General Data Protection Regulation you have the right to:

• access the personal data we hold about you,
• have inaccurate data corrected,
• have your data erased,
• restrict or object to how we use your data,
• receive your data in a portable format,
• withdraw consent where we rely on it.

To exercise any of these, email accrue4u@gmail.com. You also have the right to complain to the Maltese supervisory authority, the Office of the Information and Data Protection Commissioner (idpc.org.mt).

9. Security

We take reasonable technical measures to protect your data, including encrypted connections and access controls. No service can be guaranteed to be completely secure, but we work to keep your data safe.

10. Children

Accrue is intended for users aged 16 and over. We do not knowingly collect data from children under this age.

11. Changes to this policy

We may update this policy from time to time. We will change the date at the top when we do, and significant changes will be made clear within the service.