LEGAL

Privacy policy

Last updated: 2026-11

Draft wording. This is a first draft for a lawyer to review. It must not go live as it stands. The legal entity name and registered address are still to be added once the business is registered.

1. Who we are

CrackACCA is an online ACCA coaching service run by CrackACCA / [Legal Entity Name to be inserted upon registration] ("we", "us"). This policy explains how we handle your personal data when you use crackacca.com and the CrackACCA learning platform (the "LMS"). For questions, contact Siyaf MD at admin@crackacca.com.

2. What we collect

  • Enquiries: Name, email, WhatsApp or phone number, country, the level you ask about, and your message.
  • Account and LMS: Name, email, and basic profile details if you sign in with Google; the papers you are enrolled in; your answers, marks, feedback, progress, doubts, and disputes.
  • Payments: The amount, date, country, the payment reference, the sender name shown on the payment, and any screenshot or receipt you upload as proof. We receive payments by UPI and bank transfer, so we do not collect or store card numbers. Please hide account numbers or other details in your screenshot that we do not need.
  • Technical data: IP address, browser and device type, login times, and a device identifier. We use these for security and to enforce our 2-device limit to prevent account sharing.
  • Messages: What you send us by WhatsApp or email (admin@crackacca.com).

No additional data beyond the list above is collected. We do not collect Aadhaar numbers, passport numbers, or government ID documents. Please do not send them to us. We do not ask for your official ACCA portal login details—never share your ACCA account credentials with us.

3. Why we use it

To answer your enquiry, enrol you, run your classes and the LMS, mark your work, give support, take payment, keep the service secure, meet legal duties, and improve the service using aggregated data that does not identify you. We send marketing communications only if you explicitly opt in. If you are located in the UK or EU, our legal bases are contract, legitimate interests, consent, and legal obligation.

4. AI marking

When you submit a written answer, the text is sent to our third-party AI provider so it can be marked against our teacher-authored marking keys. We do not send your name, email, or identifying account details with the submission. See the AI marking notice for details.

5. Who we share data with

We share data only with service providers that help us run the service:

  • Database & Hosting: Supabase
  • Analytics: Google Analytics
  • AI Provider: Third-party AI model provider (for written answer assessment)
  • Communications & Support: Email/messaging infrastructure tools
  • Payment receipt: Banks and UPI apps that carry your payment. We see only what appears on our bank statements and in the proof you upload. We do not currently use a payment gateway.

We share data with public authorities when the law strictly requires it. We do not sell your personal data.

6. Transfers between countries

Our students live in several countries, and our data hosting provider (Supabase) stores data across secure global data centres. Where applicable law requires, we protect cross-border data transfers with approved standard contractual clauses. Payments from students outside India may be received in a bank account in Saudi Arabia, and payments from students in India in a bank account in India.

7. How long we keep it

Data TypeRetention Period
Enquiries (unconverted)12 months
Account, answers, marks, and progress12 months following account inactivity/closure
Security and access logs12 months
Class recordings12 months
Payment recordsAs long as tax and accounting law requires

After the applicable retention period, data is either securely deleted or fully anonymised.

8. Your rights

You can ask to see your data, correct it, delete it, or withdraw consent. You can object to marketing at any time. Indian students can also name someone to act on their behalf. If you are in the UK or EU, you may ask for a copy in a portable format and complain to your data protection regulator. Email admin@crackacca.com. We acknowledge complaints within 48 hours and aim to resolve them within 1 week.

9. Age

CrackACCA is intended for students aged 18 and above. If we discover that an individual under 18 has created an account without verifiable parental/guardian consent, we will close the account and erase their data.

10. Security

We use measures such as access controls, encrypted connections (HTTPS/SSL), activity logs, and regular backups. Access is limited to 2 devices per account. If a data breach affecting your information occurs, we will notify you and relevant authorities as required by law.

11. Cookies

See our Cookie Policy below.

12. Changes

We will post changes to this policy on our site and notify users by email for significant updates.

13. Complaints

Write to Siyaf MD at admin@crackacca.com. You can also complain to your local data protection regulator.