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 password authentication, handled by our authentication provider. We record your affirmation that you are at least 16 and the policy version. We do not ask for your date of birth.
• Study data: your question grants and answers, whether answers were correct, lesson completion, flashcard reviews and review dates, so we can save progress, show statistics and schedule revision.
• Optional class pilot: class names, assignments, your chosen learner alias, membership dates and your progress-sharing choices. We record when sharing is enabled, withdrawn or a class is left. Statement-workshop completion is saved with your other learning progress.
• 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.
• Usage data: page paths, referral domains, campaign labels and practice interactions help us understand which resources are useful. A random identifier held in page memory connects interactions during a visit. It resets on a full reload and is not stored in a tracking cookie or browser storage. We use Vercel for aggregate traffic and performance measurements and Supabase for funnel events.
• Technical data: essential cookies used to keep you signed in, and basic technical information needed to deliver the service.
• Contract and contact records: recurring-billing acceptance, the terms version and timestamp, plus the name, email, subscription details and receipt time you submit with a withdrawal statement.
• Marketing preferences: when you opt out, we retain a hash of your normalised email address in a restricted suppression list, to help prevent further promotional mail to that address.

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. We also use usage measurements to improve our resources and understand discovery and signup. Where we rely on legitimate interests, such as preventing abuse, we balance these against your rights. We also keep contract and withdrawal records to administer your requests and meet applicable legal obligations. Marketing preferences are used to respect your opt-out.

Optional sharing of assignment completion with a class tutor is based on your consent. You can stop sharing or leave the class from your class page, while continuing to use your personal study materials.

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.

If you choose to share progress in a class, its tutor can see your chosen alias and completion counts for assigned Accrue materials. The pilot does not give the tutor your email address, individual answers, billing information or progress on unassigned materials. Other learners cannot see your completion records. Stopping sharing or leaving removes you from the tutor's current learner view. Information a tutor has already seen or recorded cannot be recalled.

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. We retain contract and request records only as needed to handle the request and meet applicable record-keeping or legal requirements. A minimal marketing suppression record may be retained to continue respecting an opt-out after other data is removed.

Leaving a class preserves its membership and sharing-choice history in Accrue, while ending current progress sharing. These records follow the account-data retention and deletion process above. Closing a class stops progress sharing, preserves its assignments and history, and prevents new joins or assignments.

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. Signup requires an age affirmation. If you believe an underage account exists, contact accrue4u@gmail.com. We will investigate and restrict access or remove the data where required.

Marketing choices

Account creation is not consent to promotional email. You can opt out of promotional messages using Unsubscribe from marketing or by emailing accrue4u@gmail.com. This does not cancel your subscription or stop essential account, security or billing communications.

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.