Privacy Policy
This Privacy Policy was published on March 24, 2025.
This Privacy Policy describes the privacy practices of the website accendica.com (hereinafter "Website", "Site") operated by Outlimit Inc, registered at 3524 Silverside Road Suite 35B, Wilmington, County of New Castle, 19810-4929, Delaware. (hereinafter referred to as "We," "Us," "Our", "Company") and how we collect and use the personal data you provide on the Website to access and use the Services, which are specified in our Terms and Conditions. It also describes your choices regarding our use of your personal information and how you can access, update and delete this information.
The use of the Website is possible without any indication of personal data. However, if you want to access and use the Services, collecting and processing of personal data could become necessary. If the processing of personal data is necessary, we generally obtain consent from you as from a data subject, except in cases when personal data processing is available under other grounds (legitimate interests, contract executing, etc.).
The processing of personal data, such as the name, address, email address or billing information of a data subject shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the Company.
By means of this Privacy Policy, we would like to inform you of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, you are informed, by means of this Privacy Policy, of the rights to which they are entitled.
This Privacy Policy is an integral part of the Terms and Conditions.
As the personal data controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.
CONTENT
- Definitions
- Personal data collection and use
- Scope and categories of personal data, lawful basis for personal data processing and data subject categories
- Encrypted data
- Legal matters
- Where data subject's personal data are stored
- Your rights as a data subject
- Children's privacy
- Data storage and data removal
- Miscellaneous
DEFINITIONS
Personal data
means any information relating to an identified or identifiable natural person (hereinafter — the "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Controller
for the purposes of the General Data Protection Regulation (GDPR) and other data protection laws, is the Company.
Processing
means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data subject
means you, as an identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
User
means you, as a data subject and a user of the Services.
Encryption
means a security protection measures for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables to decode it again.
Consent
means any freely given, specific, informed and unambiguous indication of the data subject's wish by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.
Any other capitalized terms used herein but not defined shall have the meanings assigned to them in the Terms and Conditions.
PERSONAL DATA COLLECTION AND USE
Anyone can access our Website without the necessity to provide personal data.
- Your intention to access and use the Services;
- To provide the user with the ordered and purchased Services;
- For the performance of a contract to which the user is a party, in accordance with Article 6.1.b of the GDPR and the collected data is necessary in order for the Company to identify and bill the user and to charge its bank card number;
- For verifying your identity and providing customer care service and assistance;
- Analyze your use of our Website and Services to better understand how our Website and Services are being used so we can improve our Services and the user experience, as well as engage and retain users.
The purpose of processing your personal data by the Company and collection of information about you are as follows (the "Purpose"):
- Improve your browsing experience by personalizing the Website and to improve the Services;
- Send information to you by email regarding registration status, password verification, and payment confirmation;
- Send you communications relating to your use of the Services;
- Provide our partners with statistical information about our users by secured channels under data processing agreements (DPA);
- Send you marketing and promotional materials and messages.
We may use your personal data to:
As you are willing to access and use the Services, you are required to provide your personal data (to complete the Quiz and purchase the Services), thus becoming a user of the Services.
SCOPE AND CATEGORIES OF PERSONAL DATA, LAWFUL BASIS FOR PERSONAL DATA PROCESSING AND DATA SUBJECT CATEGORIES
We strive to be compliant with GDPR and implement data minimization principles.
| No. | Scope and Categories of Personal Data | Data Subject Categories | Processing Purpose | Lawful Basis for Personal Data Processing |
|---|---|---|---|---|
| 1 | Full name (first and last) | Service users | To provide the Services | Performance of a contract |
| 2 | Email address | Service users | To provide the Services To communicate information about our Services To send marketing communications | Performance of a contract / Consent | 3 | Support-related personal data | Website visitors and Service users | To provide support | Consent |
| 4 | Personal data communicated via electronic communication | Service users | To provide the Services | Performance of a contract |
| 5 | Automatically collected data (cookies and similar technologies, device and connection data) | Website visitors | To provide the features of the Website | Consent |
| 6 | IP address and other location data | Services users and Website visitors | To provide the features of the Website To comply with our legal obligations | Legitimate interest |
The personal data is not transferred to third parties, except events, when it's necessary with the purpose to provide the Services and/or there is a lawful obligation to transfer these data under the request of government authorities and/or the transferring is executed in respect of criminal proceedings.
The personal data is stored separately in our database to avoid data subject identification by using depersonalization features in compliance with the GDPR storage limitation principle.
We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under the "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secure.
You also have to fill in the billing information and payment method, which should contain your personal data, which is partly processed by us and processed by the payment providers.
Payment information
We implemented all necessary measures and standards in the area of payment security for the Services. Our Website is in compliance with PCI DSS and other requirements. We cooperate with different payment service providers and before our cooperation, we check them according to our policies for the availability of licenses and other permits for the acquirer transactions. Within a payment execution, you provide the following information to the payment service provider: (i) credit/debit card number; (ii) the expiration date of your credit/debit card; (iii) your full name; (iv) your email. This information is collected and stored by the payment service provider.
Data that we collect automatically
We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies such as Cookies, Log Files and Pixel tags. As you navigate our Website(s), information that we automatically collect is information in "log files" about your device's connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.
Our Website uses Cookies
Cookies are text files that are stored in a computer system via an Internet browser. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Website, Cookies help us track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you have entered preference information before. Cookies contain a so-called Cookie ID. A Cookie ID is a unique identifier of the Cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the Cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other Cookies. A specific Internet browser can be recognized and identified using the unique Cookie ID.
Through the use of Cookies, we can provide users of this Website with more user-friendly Services that would not be possible without Cookies. By means of Cookies, the information and offers on our Website can be optimized with the user in mind.
The data subject may, at any time, prevent the setting of Cookies through our Website by means of a corresponding setting of the Internet browser used and may thus permanently deny the setting of Cookies. Furthermore, already set Cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our Website may be entirely usable.
If you do not wish to receive Cookies, you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, the Services or support. If you have previously visited our Website, you may also have to delete any existing Cookies from your browser.
Also, we may use Pixel tags (single-pixel image files, also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted email messages.
ENCRYPTED DATA
We have put in place security hardware, software and software updates, and network scanning procedures designed to safeguard and secure the information (including personal data) under our control and follow generally accepted industry standards. We work with third-party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal data. If stored, we house personal information on systems behind firewalls that are only accessible to limited personnel who are under DPA.
We store the personal data of all our users in an encrypted way. We use asymmetric public-private key cryptosystem RSA with a key size of 4096 bit (further RSA) and symmetric-key algorithm AES with a key size of 256 bit (further AES).
Asymmetric public-private key cryptosystem RSA (key size is 4096 bit) use a public encryption key and private decryption key. The public encryption key is stored in a database (DB) in an open way. The private decryption key is stored in DB encrypted using AES 256, consisting of the user's password and secret key. It cannot be decrypted without the user's password and secret key.
The user's credentials are user's login is stored in DB. The user's password is not stored. We store only the hash of the password. We generate a public-private key pair for cryptosystem RSA during the user's sign-up. This public-private key pair is unique for each user. The key pair is stored in DB encrypted format using AES 256.
LEGAL MATTERS
- Comply with the law or legal process served on us;
- Enforce and investigate potential violations of this Privacy Policy, Terms and Conditions, including the use of the Services to participate in or facilitate activities that violate the law;
- Investigate potential fraudulent activities; or
- Protect the rights, property, or safety of the Company, its employees, its customers or the public.
We consider your use of the Services to be private. However, we may disclose your personal information in order to:
In case there might be a risk of unauthorized disclosure of personal data, the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.
However, the encryption is useless if the access password or other credentials are weakly protected and stored by the data subject. In this case, the controller is not responsible for personal data breaches.
In the case of a personal data breach, we, as a controller, shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
WHERE DATA SUBJECT'S PERSONAL DATA ARE STORED
Usually, personal data is stored on servers in Germany and the Netherlands. Personal data also may be stored outside the EU. In some cases, personal data and information may be stored in Canada. We have adopted all necessary security measures for the protection of your personal data according to the best practices of security, protection, and confidentiality. If we transfer your personal data to third-party service providers, we will compel each third-party service provider to adopt necessary security measures for the protection of your Personal Data according to our data protection agreement.
YOUR RIGHTS AS A DATA SUBJECT
You may have the following rights as a data subject, depending on your jurisdiction:
| Access. You have the right to request an explanation of the personal data we process about you. Also, you can request a copy of your personal data undergoing processing. | Rectification.You have the right to request to rectify/correct any inaccurate data about you. |
| Data portability.You have a right to receive the personal data concerning you, which you provided to us. You can make a request to transmit this data directly to another data controller in a structured, commonly used and machine-readable format. We will transmit your data directly to another controller in cases where it is technically feasible. | Erasure.You have a right to be forgotten which means that we will delete all personal data that you have provided to us. We may retain certain information as required by law and for legitimate business purposes permitted by law. |
| Restrict processing.You have the right to request us to temporarily or permanently stop processing all or some of your personal data. | Object processing.You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. You have the right to object to your personal data being processed for direct marketing purposes. |
| Right to lodge complaints.You have the right to lodge complaints in relation to the data processing activities carried out by us to the competent data protection authorities. | Not to be subject to automated decision-making.You have a right not to be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. |
| Right of confirmation.Each data subject shall have the right granted by the European legislator to obtain confirmation from the controller as to whether or not personal data concerning him or her are being processed. | Right to withdraw data protection consent.Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time. |
If one of the aforementioned grounds applies, the data subject may contact us at any time, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.
CHILDREN'S PRIVACY
Provision of the Services is generally not aimed at children. This Website is not intended for use by children under the age of 18.
The Company is acting in compliance with COPPA. We do not knowingly collect information from children under the age of 13. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Website without their permission. If we obtain actual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it unless we are legally obligated to retain such data.
DATA STORAGE AND DATA REMOVAL
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the purposes. As the data controller, we shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the Services or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
However, in case of conflict situations in progress, we may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defense of legal claims and for compliance with a legal obligation which requires processing by law to which the controller is subject in case the data subject requested to delete personal data.
If you wish to remove your personal data, send an email to [email protected]. Your personal data will be permanently removed within 30 days or earlier from our active systems, servers and back-ups, excluding the billing information for compliance with a legal obligation which requires processing by law to which the controller is subject.
To opt out of further email communications from us, just click on the opt-out button in the email or contact us by sending an email to [email protected]. We may need up to 30 (thirty) calendar days to ensure compliance with your request.
MISCELLANEOUS
We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently. We indicate the date of the current version of this Privacy Policy so you know when it was last updated.
Changes to this Privacy Policy may not affect the personal data we have previously collected from you or after such changes.
If you have any questions or suggestions, please get in touch with us via email at [email protected]