1.0 – Our core beliefs regarding user privacy and data protection

  • User privacy and data protection are human rights.
  • We have a duty of care to the people within our data.
  • Data is a liability and should only be collected and processed when necessary.
  • We don’t like spam as much as you do.
  • We will never sell, rent, distribute, or publicly distribute your personal information.

2.0 – Relevant legislation

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residence’s specific data protection and user privacy legislation, you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.

3.0 – Personal information that this website collects and why we collect it

This website collects and uses personal information for the following reasons:

3.1 – Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to understand better how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser, and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address, which could be used to identify you personally, but Google does not grant us access to this. We consider Google to be a third-party data processor (see section 5.0 below).

GA uses cookies, details of which can be found on Google’s developer guides.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages on this website.

3.2 Contact forms and email links

Should you choose to contact us using the contact form on our website or an email link like this one, none of the data that you supply will be stored by this website or passed to be processed by any of the third-party data processors defined in section 5.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL), meaning the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information in an email.

3.3 Email newsletter

If you choose to join our email newsletter, your email address will remain in our database until you request removal from the list. You can do this by unsubscribing using the unsubscribe links in any email newsletters we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age, you MUST obtain parental consent before joining our email newsletter.

While your email address remains within our database, you will receive periodic (approximately one per month) newsletter-style emails from us.

4.0 – How we store your personal information

If you submit an order on this website, some personal information will be stored in this website’s database. This is currently the only time personal data will be stored on this website. This data is currently stored in an identifiable fashion, which is a limitation of the content management system that this website is built on (WordPress). In the near future, we aim to change the storage of this data to a pseudonymous fashion, meaning that the data would require additional processing using a separately stored “key” before it could be used to identify an individual. Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to implement fully. We are committed to keeping it a high priority and will implement it on this website as soon as we are able to.

5.0 – Our third-party data processors

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen, and they all comply with the legislation set out in section 2.0. All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

6.0 – Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

7.0 – Data controller

The data controller of this website is Accord Consulting OÜ, an Estonian private limited company whose registered office is Ahtri 12, 15551 Tallinn, Estonia.

8.0 Data protection officer

Andrea Galizia
Accord Consulting OÜ
Telephone: +372 6104249
Email: contact@accordconsulting.io.

9.0 Changes to our privacy policy

This privacy policy may change occasionally in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend checking this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the changelog below.

9.1 Changelog

01/01/2024 – version 1.0 Privacy policy instigated