Accingo empowers K-12 teachers through bite-sized professional learning modules and classroom resources. Respecting educator privacy—and by extension the privacy of their students—is foundational to our mission. This notice explains what we collect, why we collect it, and the options you have.

Who We Are

Accingo LLC ("Accingo," "we," "us," or "our") is a U.S. company headquartered in New Port Richey, FL USA. You can reach our privacy team through our contact page.

Scope & Audience

This notice covers visitors and registered users (collectively, "Users") of accingo.co and any associated mobile or web applications (the "Services").

The Services are intended only for adults (18 years or older). Accingo is designed for K-12 educators, school administrators, instructional coaches, and other education professionals. We do not provide services to, and do not knowingly collect Personal Data from, individuals under 18.

Student Data Commitment

Accingo does not collect, process, or store any student education records or student personal information. Our platform is built exclusively for educator professional development. Teachers may discuss instructional strategies or share anonymized classroom scenarios in optional reflection activities, but we prohibit the sharing of any personally identifiable student information.

If we discover that information about a minor has been submitted to our platform, we will delete that information within 72 hours. If you believe we might have any information from or about a person under 18, please contact our Privacy Lead.

User Consent

By creating an account, submitting Personal Data, or otherwise using the Accingo Services, you:

1. Acknowledge that you have read and understood this Privacy Policy
2. Expressly consent to the collection, use, disclosure, and retention of your information as described below
3. Certify that you are at least 18 years old
4. Agree that you will not share your account credentials with minors

We reserve the right to verify user age through documentation if misuse is suspected.

Compliance with Education Privacy Laws

Accingo is committed to compliance with:

• Family Educational Rights and Privacy Act (FERPA)
• Children's Online Privacy Protection Act (COPPA) - Not applicable as we serve only 18+ users
• Protection of Pupil Rights Amendment (PPRA)
• State laws including California AB 1584, New York Education Law § 2-d, Illinois SOPPA, and similar statutes in all 50 states

If we introduce features that process student data, we will:

• Execute written Data Processing Agreements (DPAs) with schools and districts
• Act solely as a School Official or Service Provider under FERPA
• Implement additional technical and organizational safeguards
• Update this policy with at least 90 days advance notice
• Obtain explicit consent from institutional administrators

We have reviewed and aligned our practices with the Student Privacy Pledge coordinated by the Future of Privacy Forum (FPF).

How We Use Information

We process Personal Data solely to:

Core Operations

• Authenticate users and maintain account security
• Deliver the Services including tracking your professional learning progress
• Provide certificates and completion records
• Enable content access and resource downloads
• Facilitate collaboration in discussion forums and peer sharing features
• Process payments and manage subscriptions

Platform Improvement

• Analyze usage patterns to understand which content is most valuable
• Conduct A/B testing on interface improvements (always with anonymized cohorts)
• Fix bugs and optimize performance
• Develop new features based on aggregated user needs

Communications

• Transactional emails regarding your account, security, or service changes
• Educational content including new module announcements (opt-in required)
• Surveys and feedback requests to improve our offerings (optional)
• Customer support responses

Legal & Security

• Detect and prevent fraud or unauthorized access
• Enforce our Terms of Service
• Comply with legal obligations including subpoenas, court orders, or regulatory inquiries
• Protect rights and safety of Accingo, users, and the public

What We Do NOT Do

We commit to the following restrictions:

• No targeted advertising based on your activity on our platform
• No sale or rental of your Personal Data to third parties
• No creation of automated profiles about educators beyond legitimate educational purposes
• No student data processing unless explicitly contracted under separate terms

Future AI & Machine Learning Features

If we introduce recommendation engines, content personalization, or AI features that analyze your learning patterns or content submissions, we will:

1. Update this notice with detailed descriptions at least 90 days in advance
2. Provide a clear, separate opt-in mechanism
3. Enable you to opt-out at any time without loss of core functionality
4. Ensure any AI training uses only aggregated, de-identified data

Legal Bases for Processing

For Users Subject to GDPR (EEA/UK)

We process your Personal Data under the following lawful bases:

• Contract Performance (Article 6(1)(b)): To provide the Services you've requested
• Legitimate Interests (Article 6(1)(f)): To improve our platform, ensure security, and conduct analytics (balanced against your rights)
• Consent (Article 6(1)(a)): For optional cookies, marketing communications, and certain analytics
• Legal Obligation (Article 6(1)(c)): To comply with laws, regulations, or court orders

You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

For Users Subject to State Privacy Laws

Under laws such as CCPA, VCDPA, CPA, CTDPA, and UCPA, we process data for:

• Business purposes as defined under each statute
• Service or operational purposes that do not constitute "sale" or "sharing"
• We do not "sell" or "share" Personal Information for cross-context behavioral advertising

How We Share Information

We disclose Personal Data only in the following limited circumstances:

Service Providers & Subprocessors

We engage third-party vendors who access data solely to perform services on our behalf under written agreements that require:

• Confidentiality and security obligations
• Data use restrictions (only for providing services to Accingo)
• Compliance with applicable privacy laws
• Return or deletion of data upon contract termination

Current service providers include:

Legal & Safety Disclosures

We may disclose information when we believe in good faith that disclosure is necessary to:

• Comply with law, regulation, legal process, or governmental request
• Enforce our Terms of Service or investigate potential violations
• Detect, prevent, or address fraud, security, or technical issues
• Protect the rights, property, or safety of Accingo, our users, or the public as required or permitted by law

Law Enforcement Transparency: We will notify affected users of law enforcement requests for their data unless legally prohibited.

Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, Personal Data may be transferred to the successor entity. The successor must either:

• Honor this Privacy Policy, or
• Provide you with notice and choice before using your data differently

We will notify you via email and prominent platform notice at least 30 days before such a transfer.

Aggregated & De-Identified Data

We may share aggregated, de-identified statistics that cannot reasonably identify you (e.g., "75% of users complete a module in under 15 minutes" or "The average teacher in our network teaches 4th grade").

De-identification follows NIST standards and we commit not to re-identify this data.

Data Security

Technical Safeguards

• Encryption in transit: TLS 1.3 for all data transmission
• Encryption at rest: AES-256 encryption for databases and file storage
• Infrastructure: SOC 2 Type II audited cloud providers
• Access controls: Role-based access (RBAC) with principle of least privilege
• Authentication: Multi-factor authentication (MFA) required for all staff
• Network security: Firewall protection, intrusion detection systems, DDoS mitigation

Organizational Safeguards

• Security training: Mandatory annual training for all employees and contractors
• Vendor audits: Regular security assessments of third-party providers
• Penetration testing: Annual third-party security audits
• Incident response plan: Documented procedures for breach detection and response
• Data minimization: We collect only what's necessary and delete data when no longer needed

Your Role in Security

• Use a strong, unique password (minimum 12 characters)
• Enable two-factor authentication if available
• Keep your email account secure
• Log out when using shared devices
• Report suspicious activity immediately to the Accingo team

Despite these safeguards, no system is 100% secure. We cannot guarantee absolute security but commit to using industry-standard practices to protect your data.

Data Breach Notification

In the event of a data breach involving your Personal Data, we will:

1. Notify affected users within 72 hours of discovery via email
2. Describe the breach including what data was involved
3. Explain the risks and potential consequences
4. Detail our response including steps taken to secure systems
5. Provide guidance on how you can protect yourself
6. Notify authorities as required by applicable law (e.g., state attorneys general, EU supervisory authorities)

Data Retention

Active Accounts

We retain your account information and associated data for as long as your account remains active and for legitimate business purposes.

Account Deletion

When you delete your account:

1. Within 24 hours: Your account is deactivated and no longer accessible
2. Within 30 days: Personal Data is anonymized or permanently deleted from production systems
3. Within 90 days: Data is purged from backup systems (except where noted below)

Legal Retention Requirements

We may retain certain data longer when required by:

1. School or district contracts
2. Tax and financial reporting laws
3. Litigation holds or ongoing investigations
4. Legal compliance obligations

In these cases, data is isolated, access-restricted, and deleted once the retention period expires.

Anonymized Data

After deletion, we may retain anonymized, aggregated data that cannot identify you for research and platform improvement purposes indefinitely.

Your Choices & Rights

All Users

Access Your Data: View and download your data via My Account → Export Data (available in JSON and CSV formats)

Correct Your Data: Update your profile information at any time through account settings

Delete Your Account: Permanently delete your account via My Account → Delete Account (irreversible)

Opt In and Out of Marketing: Unsubscribe from promotional emails via the link in any message (you'll still receive essential service communications)

Control Cookies: Manage preferences through your browser settings (see Cookies section)

EEA/UK Residents (GDPR)

Under GDPR, you have the right to:

• Access: Obtain confirmation and a copy of your Personal Data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion ("right to be forgotten")
• Restriction: Limit how we process your data in certain circumstances
• Data Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: For processing based on consent (without affecting prior lawful processing)
• Lodge a Complaint: With your local supervisory authority (UK: ICO; list at edpb.europa.eu)

California Residents

In addition to the above, you have the right to:

• Know what Personal Information we collect, use, and share
• Request deletion of your Personal Information
• Opt-out of "sale" or "sharing" (note: we do not sell or share data)
• Correct inaccurate Personal Information
• Limit use of Sensitive Personal Information (if applicable)
• Non-discrimination for exercising your rights

To exercise these rights, please contact the Accingo team.

Verification: We will verify your identity using the email associated with your account. For sensitive requests, we may require additional verification.

Response Time: We respond within 45 days (extendable by 45 days with notice).

Authorized Agents: You may designate an authorized agent to make requests on your behalf with proper documentation.

Colorado, Connecticut, Utah, Virginia Residents

You have similar rights as California residents under your state's privacy law, including the right to:

• Confirm whether we process your Personal Data and access that data
• Correct inaccuracies
• Delete your Personal Data
• Obtain a portable copy in a readily usable format
• Opt out of targeted advertising, sale, or profiling (note: we do not engage in these practices)
• Appeal our decision if we deny your request

We will not discriminate against you for exercising any privacy right.

Cookies & Similar Technologies

Types of Cookies We Use: Essential Cookies (Required)

These cookies are necessary for the website to function and cannot be disabled:

• Session cookies: Keep you logged in during your session
• Security cookies: Detect authentication abuse, prevent unauthorized access
• Load balancing: Distribute traffic across servers

Impact of Blocking: Core functionality will not work.

Do Not Track (DNT)

Our website does not currently respond to DNT signals because no industry standard exists. We do not track you across third-party websites.

International Data Transfers

Accingo is headquartered in the United States. By using the Services, you understand that your Personal Data may be transferred to, processed, and stored in the United States or other jurisdictions.

Third-Party Links & Integrations

Our Services may contain links to third-party websites, resources, or integrations (e.g., YouTube videos, external articles, SSO providers). This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices of third parties.

We encourage you to review their privacy policies before sharing information with them.

Children's Privacy

Accingo does not provide services to children under 18. Our Terms of Service prohibit use by anyone under 18 years old.

We do not knowingly collect Personal Data from minors. If we learn that we have collected data from someone under 18:

1. We will delete the data immediately
2. We will suspend or terminate the associated account
3. We will investigate how the minor gained access

If you are a parent or guardian and believe a minor has created an account or submitted information, contact the Accingo team immediately.

COPPA Compliance: While COPPA applies to children under 13, and our service is restricted to 18+, we apply COPPA's data minimization principles to our overall approach.

Accessibility

Accingo is committed to making our Services accessible to all users, including those with disabilities. We strive to comply with WCAG 2.1 Level AA standards.

If you encounter accessibility issues, please contact the Accingo team so we can work to address them as quickly as possible.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

Material changes will be communicated at least 30 days before they take effect. May require re-acceptance for significant changes.

Non-material changes will be posted on this page and will take effect immediately.

Your Continued Use

Continued use of the Services after the effective date of changes constitutes your acceptance of the updated policy. If you do not agree to the changes, you must stop using the Services and may delete your account.