Privacy Policy
Last Updated: September 2, 2026 | Effective Date: September 2, 2026
Introduction & Scope
Welcome to ACCA AI Coach ("the Platform", "we", "our", or "us"), operated by trueattendly. This Privacy Policy governs the collection, processing, storage, and protection of personal data and usage information from registered students, visitors, and platform administrators.
Purpose of the Platform: ACCA AI Coach is an intelligent EdTech web application engineered to deliver AI-driven exam training, Socratic reasoning coaching, and step-ladder micro-learning tailored specifically for ACCA (Association of Chartered Certified Accountants) professional qualifications, including Applied Skills (FR, AA, PM, etc.) and Strategic Professional (SBR, AAA, AFM, etc.) papers.
Data Controller: For the purposes of the General Data Protection Regulation (EU GDPR / UK GDPR) and the California Consumer Privacy Act (CCPA / CPRA), trueattendly acts as the Data Controller responsible for deciding the purposes and means of processing your personal data.
Information We Collect
We collect information to provide, maintain, and optimize your learning experience. This information is categorized into:
A. Account & Authentication Data
When you register or sign in, we collect your full name, email address, one-time verification codes (OTP), and cryptographically salted and hashed passwords (via bcrypt). We issue JSON Web Tokens (JWT) stored in secure HTTP-only cookies to verify authenticated student sessions.
B. Learning, Chat & Progress Data
To deliver contextual coaching, our database records student interaction transcripts (Socratic dialogue, user replies, step-ladder responses), syllabus topic completion records, self-evaluation notes, selected exam option distractors, and mastery summaries across ACCA accounting and auditing standards.
C. Technical, Device & Telemetry Metadata
When accessing our Next.js and Vercel edge infrastructure, we automatically receive telemetry including browser type, operating system, IP address (anonymized for analytics), device screen dimensions, session timestamps, page views via Vercel Analytics, and error diagnostics logs for platform reliability.
How We Use Your Information
We process personal and educational data based on legitimate educational interests and contractual necessity to fulfill the following services:
- Personalized Socratic Coaching: Delivering dynamic pedagogical questioning, counterfactual nudges, step-by-step calculations, and personalized feedback aligned with IFRS, IAS, and ISA standards.
- Curriculum & Progress Tracking: Maintaining your Study Tracker progress records, completed topics, mastery status, and recommended next study topics.
- Authentication & Session Continuity: Securing login credentials, verifying one-time password (OTP) email authorizations, and preserving active workspace state across devices.
- Platform Infrastructure & Security: Monitoring serverless API pipelines, load balancing, mitigating brute-force or abuse attempts, and diagnosing infrastructure errors.
AI Processing & Third-Party LLM Providers
To provide real-time Socratic feedback, student prompts and conversation context are transmitted to enterprise-grade AI inference providers over secure, encrypted TLS connections.
Our Privacy Commitments for AI Workloads:
- No Sale of Data: We never sell, rent, or monetize student personal data, prompt queries, or chat logs.
- No Model Training on Student Data: Inference queries dispatched to our API providers (including Google AI Gemini, Mistral AI, Microsoft Azure / GitHub Models, and OpenRouter enterprise endpoints) are processed under strict zero-data-retention or commercial API terms that prohibit using student inputs to train public foundation models without explicit consent.
- End-to-End Encryption in Transit: All communication between the student client, our serverless Next.js edge router, and AI inference endpoints is secured using modern TLS 1.3 encryption.
Data Storage, Security & Retention
Database Infrastructure: All persistent student data—including user accounts, study topics, chat histories, and progress tracking records—is securely hosted on MongoDB Atlas with enterprise-grade encryption at rest (AES-256) and encryption in transit (SSL/TLS).
Data Retention Schedules:
- Active Account Data: Maintained for the active lifespan of the student's account to allow continuous syllabus tracking across exam sessions.
- One-Time Passwords (OTPs): Ephemeral verification codes automatically expire and are purged from database records within 10 minutes of issuance.
- Session Clearance & Deletion: Students may clear individual chat sessions directly within the interface or request full account and data deletion at any time.
User Rights (GDPR & CCPA / CPRA Compliance)
Regardless of your geographical location, we extend comprehensive privacy rights consistent with European (GDPR), United Kingdom, and California (CCPA/CPRA) statutory benchmarks:
✓ Right to Access & Portability
You may request a machine-readable export of all your personal data, chat history, and study progress records.
✓ Right to Rectification
You have the right to correct or update inaccurate account information or credentials at any time.
✓ Right to Erasure ("Be Forgotten")
You can demand complete and irreversible deletion of your user profile, study metrics, and stored transcripts.
✓ Non-Discrimination
We will never discriminate against, degrade service quality for, or deny access to any student exercising their privacy rights.
To exercise any of these statutory rights, please send an email request to our Data Privacy Officer at privacy@trueattendly.online or contact our support team. We fulfill verified requests within thirty (30) calendar days free of charge.
Contact & Policy Updates
We may update this Privacy Policy periodically to reflect pedagogical enhancements, new AI capabilities, or evolving legal frameworks. When material changes are made, we will notify registered users via email or by displaying an in-app advisory banner prior to the changes taking effect.
Data Protection & Privacy Contact:
Organization: trueattendly / ACCA AI Coach
Location: Ayikkarapadi, Malappuram, Kerala, India
Email: privacy@trueattendly.online / support@trueattendly.online
WhatsApp Support: +91 6282560928
Instagram: @trueattendly