Introduction

Your privacy is important to us. This Privacy Policy explains how AccountaPartner s.r.o. (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal data when you use our website AccountaPartner.com and our accountability and coaching Services (collectively, the “Services”). It also describes your rights and choices regarding your personal data under the EU General Data Protection Regulation (GDPR) and other applicable laws.

AccountaPartner s.r.o. is the data controller of the personal data you provide, meaning we determine how and why your data is processed. In order to deliver our Services, we may share certain personal data with our independent contractors. These contractors act as data processors on our behalf and are contractually obligated to process your personal data only in accordance with our instructions and for the purpose of providing the Services.

This Policy is based on Czech and EU regulations, particularly GDPR, but we aim to make it understandable for users worldwide.

By using our Site or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our handling of your data, you must not use our Services.

Personal Data We Collect

We collect and process several categories of personal data from you when you interact with us. This may include:

• Contact Information: When you sign up or contact us, we collect your name, surname, email address, phone number, and any other contact details you provide. This information is necessary to create your account, schedule sessions, and communicate with you.
• Account and Profile Data: If you create an account, we may collect login credentials (such as username, password), as well as information about your subscription plan, and any preferences or notes you add to your profile.
• Payment Information: If you subscribe to a paid plan, our payment processors will collect your payment card details or payment account information. The Company itself generally does not store full credit card numbers. We may keep a record of your transactions (date, amount, payment method, last four digits of card, transaction ID) for billing history. All payments are securely processed by third-party providers compliant with PCI-DSS standards.
• Service Usage Data: This includes data inherently generated through your interactions with us:
  • Session Information: We keep records of your scheduled sessions, such as dates and times of calls, the coach/partner assigned, and session duration. We may also retain notes or summaries about the sessions (e.g., goals you’re working on, progress, and any follow-up actions), which your accountability partner or our staff records to help personalize your service.
  • Call Recordings: As noted in our Terms, some calls or online meetings may be recorded. If a session is recorded, the recording (audio and/or video) constitutes personal data we collect. These recordings are kept secure and used only for internal purposes like quality control or dispute resolution.
  • Communication Content: If you communicate with us or with your accountability partner via email, messaging app, or through our Site (for example, sending feedback or asking questions), we will collect the content of those communications and any information you choose to provide therein.
• Website Usage Data: When you visit our website, we may automatically collect technical information like your IP address, browser type, device information, and browsing behavior through cookies or similar technologies. For example, we might record what pages you visit on our Site and any actions you take (such as clicking a signup button). This data helps us improve our website and services.
• Consultation Data: If you take advantage of a free consultation call before signing up, we may take notes during that call regarding your needs, questions, and suitability for our Services. This helps us follow up and tailor our offering to you. This information becomes part of your client record if you later subscribe.
• Marketing Preferences and Testimonials: If you opt in to receive marketing emails/newsletters, we will record that consent and your communication preferences. Additionally, if you agree to provide a testimonial or be featured in a case study, we may collect the content of your testimonial and your name/likeness, but only with your explicit consent.

We do not collect any sensitive personal data about you unless you voluntarily provide it during your interactions (for instance, you might mention health conditions or other sensitive details during coaching). We do not require such information for the Services. If you do share it, we will treat it as confidential and use it only for providing the service to you, and you retain the right to request its deletion.

How We Use Your Personal Data

We use the collected data for the following purposes, in accordance with applicable law:

• To Provide and Personalize the Services: We process your contact info and session data to schedule calls, match you with an appropriate accountability partner (coach), and conduct the sessions. For example, your phone and email are used to send you reminders or links for your online calls. Session notes or your stated goals are used by your coach to tailor the support to your needs.
• Subscription Management and Billing: We use your data to manage your subscription, process payments, send invoices or receipts, and track payment status. (Our payment processors handle the actual card processing, but we manage the subscription status.) We may send you service emails related to billing (e.g., payment confirmations, failed payment notifications, or upcoming renewal reminders).
• Communication: We use your email, phone, or other provided contact channels to communicate with you:
  • Service and Support: to send onboarding information, confirm bookings, notify you of changes to a scheduled session, respond to your inquiries or support requests, and provide customer support.
  • Important Updates: to inform you of important changes to our Services or policies (like updates to Terms & Conditions or Privacy Policy).
  • Marketing (with consent): Only if you have opted in, we may send newsletters, motivational tips, or offers about our Services or new features. You can opt out at any time.
• Quality Assurance and Dispute Resolution: Call recordings, if made, are used strictly for internal purposes such as reviewing the quality of coaching, training our team to improve (e.g., by reviewing how sessions are conducted), or resolving any disputes that may arise (for instance, if there’s a disagreement between you and your coach about what was said or whether a session took place). Only authorized personnel will access recordings for these purposes, and we do not use these recordings for marketing or any external publication without your consent.
• Service Improvements and Analytics: We may use aggregated and de-identified data (that does not identify you personally) to understand how clients use our Services and to improve our offerings. For example, we might analyze overall client retention rates or common goals to enhance our programs. If we use website analytics tools (like Google Analytics), they process usage data to help us understand website traffic and improve the site experience.
• Legal Compliance and Protection: We may process personal data as required to comply with applicable laws and regulations (e.g., retaining transaction records for tax/audit purposes, or responding to lawful requests by public authorities). Also, if necessary, we will use and disclose personal data to enforce our Terms & Conditions, to protect our rights, privacy, safety, or property, and that of our clients or others, and to allow us to pursue available remedies or limit damages if needed (for example, in resolving any legal disputes or handling misuse of Services).

Legal Bases for Processing (GDPR)

Under the GDPR (for users in the European Economic Area and equivalent jurisdictions), we must have a valid “legal basis” to process your personal data. We rely on the following legal grounds:

• Contractual Necessity: Most of our data processing is to fulfill our contract with you – i.e., to provide the Services you have subscribed to. When you sign up, a contract is formed between you and the Company under our Terms & Conditions, and we must process your data to deliver on that contract (for example, using your email to send you call details, or processing your payment). If you refuse to provide necessary data, we may not be able to offer the Services.
• Legitimate Interests: We process certain data for our legitimate business interests, in a manner that does not override your privacy rights. This includes:
  • Recording calls for quality and dispute resolution: Our legitimate interest is to ensure service quality and have a record in case of misunderstandings. We limit this to what is necessary and secure the recordings, as described.
  • Improving our services and website: Understanding usage patterns helps us develop better features and support.
  • Preventing fraud or misuse of our Services, and ensuring IT security. In assessing this, we consider your privacy rights and ensure adequate safeguards (e.g., allowing you to object in some cases as described further in these Terms).
• Consent: We rely on your consent for specific optional processing:
  • Sending marketing communications via email or similar channels. We will only do this if you have given an explicit opt-in (such as by checking a box to receive newsletters).
  • Using your testimonial or story in our marketing materials. We will ask for your written or recorded consent separately before doing so.
  • Certain cookies or tracking technologies on our Site that are not strictly necessary (where consent is required by law). You can manage these via our cookie banner or Cookie Preference Center settings. If we rely on consent, you have the right to withdraw that consent at any time (for example, you can unsubscribe from marketing emails via the link in each email).
• Legal Obligation: We may process and retain some data to comply with our legal obligations. For instance, as a business, we must keep invoice records for a number of years as required by tax law, or we may have to provide information to authorities if legally compelled (such as for an investigation).
• Vital Interests/Public Task: These bases are unlikely to apply to our typical Services. We do not generally process data under these bases except in extreme circumstances (e.g., if there were an emergency involving someone’s life, which is unlikely in our context).

How We Share Your Personal Data

We treat your personal data with care and do not sell it. However, we do share data in certain circumstances, as necessary to run our business and provide Services:

• With Accountability Partners/Contractors: As noted, we share relevant personal information with the contractor assigned as your accountability partner or coach. This includes your contact details and any intake information so they can conduct sessions with you. All such individuals are contractually bound to handle your data confidentially and securely, and to use it only for providing services on our behalf.
• Service Providers (Processors): We use trusted third-party service providers to perform functions on our behalf, and they may handle or store your data as part of those services. Key examples include:
  • Payment Processors: Handling of billing information and processing transactions. They receive your payment details and process payments securely. We share with them the necessary billing information and receive confirmation of payment.
  • Scheduling/Communication Tools: If we use a scheduling software or calendar integration to book calls, that provider will process your name/email to send invitations. Similarly, if we conduct sessions via a platform like Google Meet, Zoom, WhatsApp, or similar, those platforms will handle the call data (like your video/audio and name during the call) as independent controllers or processors. We ensure any such provider we use is reputable and, where feasible, under agreements to protect your data.
  • Email and Messaging Services: We may use an email service provider to send out bulk communications. Your email address and the content of emails would pass through those systems. If we use WhatsApp or similar for communication, those services have their own encryption and privacy practices (WhatsApp messages are end-to-end encrypted by default, for instance).
  • Data Storage and IT: We may use cloud storage or database hosting (for example, AWS, Google Cloud, or other EU-based cloud services) to store our application data, including your personal data. These service providers act as processors, storing data on our behalf. We take steps to ensure data is encrypted or protected and that these providers comply with GDPR (many have EU data centers or appropriate safeguards like Standard Contractual Clauses for data transfers).
  • Analytics and Cookies: If we use analytics tools or advertising partners, those entities will receive limited data via your browser. For instance, Google Analytics would receive your IP (which we may anonymize) and site usage information.
• Business Transfers: If the Company is involved in a merger, acquisition, sale of assets, or reorganization, your personal data may be transferred to the successor or new owner as part of that deal. If this happens, we will ensure that the new entity is bound to respect the terms of this Privacy Policy or give you notice and an opportunity to opt out of the transfer of your data.
• Legal Requirements and Protection: We may disclose personal data to third parties (such as attorneys, auditors, law enforcement, or government authorities) if required to do so by law or if such action is necessary to:
  • Comply with a legal obligation, court order, or regulatory request (including responding to lawful requests by public authorities, such as to meet national security or law enforcement requirements).
  • Protect and defend the rights or property of AccountaPartner s.r.o., or the safety of our clients, contractors, or the public. For example, if you raise a dispute about charges, we might share relevant information with a payment processor or bank to resolve it. Or if a coach reports that a client is an imminent danger to themselves or others, we might need to notify authorities as required by law.
• With Your Consent: In cases where we want to share information for a purpose not covered above, we will ask for your consent. For instance, if we’d like to feature your success story or a testimonial on our website or marketing materials, we would only include personal details like your name, image, or results with your explicit permission. You are not obligated to grant such consent.

We aim to limit the personal data shared to only what is strictly necessary for each purpose and to ensure that any third parties we involve are obligated to protect your data. We do not share your contact details with third parties for their own marketing purposes unless you have given consent.

International Data Transfers: Given that the Company is based in the EU (Czech Republic), your data is primarily stored and processed within the European Union. However, some of our service providers or contractors might be located outside of the EU/EEA. When we transfer personal data internationally, we will do so in compliance with GDPR requirements. This means:

• If we transfer data to a country without an EU adequacy decision (for example, to the United States), we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) with the receiving party, and additional security measures if needed.
• Some providers (like U.S.-based cloud services) may be certified under frameworks that allow lawful transfer, or we will obtain your consent for specific transfers if required.

You can contact us for more information about any specific transfer of your personal data and the safeguards applied.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• Encryption: We use encryption protocols (e.g., HTTPS/TLS) to protect data in transit on our website and, where applicable, encryption at rest for stored data (for example, encrypting our databases or call recordings).
• Access Controls: Personal data (including call recordings and session notes) is accessible only to those staff or contractors who need it to perform their duties. All staff and contractors are bound by confidentiality obligations. We maintain authentication procedures for our internal systems to prevent unauthorized access. For example, coaches may only access information for their assigned clients, not all clients.
• Secure Storage: Call recordings and other sensitive data are stored in secure systems. If using third-party storage, we choose providers with strong security track records. We regularly update our software and use firewalls/anti-malware tools to prevent security breaches.
• Payment Security: We rely on PCI-compliant payment processors, meaning we do not directly handle or store sensitive payment card details. Our site does not see your full card number when you enter it into Stripe’s forms, for instance.
• Incident Response: In the event of a data breach that affects your personal data, we have a procedure to identify, contain, and fix the issue. If a breach is likely to result in a high risk to your rights (e.g., significant harm or fraud), we will notify you and any relevant authorities as required by law.

While we strive to protect your information, no system can guarantee absolute security. You also play a role in keeping your data safe: please use a strong password for any account and do not share it. If you suspect any unauthorized access to your account or any security vulnerabilities, contact us immediately.

Your Choices: Marketing and Cookies

Marketing Communications: We will only send you promotional or marketing communications if you have actively opted in to receive them. This might occur, for example, if you tick a box to subscribe to a newsletter or if you explicitly consent to receive motivational tips and updates from us. If you opt in, we may occasionally send emails about new services, special offers, or company news that we think may interest you.

• Opt-Out: You have the right to opt out of marketing emails at any time. You can do this by clicking the “unsubscribe” link in any marketing email we send, or by contacting us at info@accountapartner.com and requesting to be removed from marketing lists. Once you opt out, we will stop sending you non-essential communications. (Note: even if you opt out of marketing messages, we will still send you transactional or service-related messages as necessary, e.g., billing notices or scheduling confirmations, which are not promotional.)
• Consent for Testimonials/Case Studies: If you agree to share a testimonial or participate in a case study, we will clearly explain how your information will be used (e.g., using your first name, or an alias, plus a quote about your experience, etc.) and ask for your written consent. This is entirely voluntary. If you give consent and later change your mind, you can withdraw consent, and we will cease future use (though we may not be able to retract materials already published, but we will stop further distribution).

Cookies and Tracking Technologies: Our website uses cookies and similar technologies to provide and improve our services, as well as to understand how users engage with our Site.

• Essential Cookies: Some cookies are necessary for the Site to function (e.g., to keep you logged in, or to remember your preferences). These do not require your consent and are used based on our legitimate interest or your request (for providing the service).
• Analytics and Preference Cookies: We may use analytics cookies to count visits and understand which pages are most popular, or preference cookies to save your settings. Where required by law, we will request your consent for any non-essential cookies via a cookie banner when you first visit the Site.
• Third-Party Cookies: If we embed content from third parties or use advertising/analytics services, those third parties may set their own cookies. For example, if we use Google Analytics or a Facebook Pixel, these services will set cookies to collect website usage data.
• Your Choices: You can manage these via our cookie banner or Cookie Preference Center settings, and you can also adjust your browser settings to refuse or delete cookies. However, please note that blocking cookies may impact your experience (for instance, you might have to log in again, or certain features might not work).

For more details, please see our Cookie Policy. By continuing to use our Site with cookies not disabled, you are consenting to our use of cookies as described.

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Active Account: If you are an active client (subscriber), we keep your personal data throughout your subscription to provide the Services.
• Dormant or Cancelled Accounts: If you cancel your subscription or otherwise stop using our Services, we may retain your account and related personal data for an extended period—even indefinitely—to facilitate possible reactivation. This retention is based on our legitimate business interest in maintaining historical records and providing convenience if you decide to return. However, you always have the right to request deletion of your personal data at any time, and we will process such requests in accordance with applicable law.
• Financial and Transaction Records: We will retain invoicing, payment records, and related personal data for the period required by Czech accounting and tax laws, typically 5-10 years (depending on the specific regulation), as these may be subject to audit or legal requirements.
• Call Recordings and Session Data: Recorded sessions and detailed session notes are retained for as long as necessary to provide quality assurance, resolve disputes, and maintain historical records of the Services we provide. If you are an active client, these recordings and notes are retained for the duration of your subscription. If you cancel your subscription or otherwise stop using our Services, we may retain call recordings and session data for an extended period—even indefinitely—to support potential future dispute resolution or to facilitate reactivation. However, you always have the right to request deletion of your call recordings and session data at any time, and we will process such requests in accordance with applicable law. In situations where an ongoing issue requires longer retention, we will hold the relevant recordings until that matter is resolved. Once the retention period expires or the data is no longer required, the recordings and session data will be securely deleted or anonymized.
• Newsletter/Marketing Data: If you have subscribed to newsletters, we will retain your contact details for that purpose until you unsubscribe or ask us to delete them. If you unsubscribe, we may keep your email on a suppression list to ensure we honor your no-contact request.
• Legal Hold: In some cases, we may need to retain data for longer if it is subject to a legal hold or required for a legal claim. For example, if there is an ongoing dispute or a potential legal claim involving your use of our Services, we will retain the relevant information until the issue is resolved.

Once the retention period expires or the purpose is fulfilled, we will securely erase or anonymize your personal data. If complete deletion is not immediately possible (for example, due to data residing in secure backups), we will ensure it is not readily accessible and is kept securely until deletion is feasible.

Upon your request, we will also delete your personal data earlier if feasible, provided it’s not required to be retained by law or vital for our legitimate business interests (e.g., we cannot delete your billing records immediately if still within the legally required retention period).

Your Rights and How to Exercise Them

As a user of our Services, especially if you are in the EU/EEA or in jurisdictions with similar data protection laws, you have certain rights regarding your personal data. We are committed to upholding these rights. Subject to some conditions and exceptions, these rights include:

• Right of Access: You have the right to request a copy of the personal data we hold about you and to obtain information about how we process it. This is often called a Subject Access Request. We will provide you with a copy of the data in a common format, typically within one month of verifying your identity.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can also update some of your own information by logging into your account, if applicable (e.g., changing your contact details).
• Right to Erasure (Right to be Forgotten): You may request that we delete your personal data. We will do so if there is no lawful reason for us to continue processing it. This right is not absolute – for example, we cannot delete data that we are required to keep by law, or which is necessary for the establishment, exercise, or defense of legal claims. But we will honor this right to the fullest extent possible. If you request deletion, note that this typically means we will delete your account and you will lose access to the Services.
• Right to Restrict Processing: You can ask us to suspend the processing of certain personal data about you, for example, if you want us to establish its accuracy or the reason for processing it, or if you have objected to processing (see below) and we are considering that request.
• Right to Data Portability: For personal data that you provided to us and that we process by automated means on the basis of your consent or in performance of a contract, you have the right to request that we provide it to you or directly transfer it to another service provider, where technically feasible, in a commonly used machine-readable format.
• Right to Object: In certain situations, you have the right to object to our processing of your personal data:
  • Legitimate Interests: Where we are processing data based on our legitimate interests, you can object to that processing if you feel it impacts your rights. If you object, we will consider whether our interests in processing your information are outweighed by the impact on your rights and either stop or justify why we need to continue processing your data.
  • Direct Marketing: You have an absolute right to object to any processing of your data for direct marketing purposes. This includes profiling related to direct marketing. (As noted, we only send marketing if you opted in, but you can opt out at any time, and we will cease).
• Right not to be subject to Automated Decisions: Our decisions about you are not made by algorithms or fully automated processes. We do not use automated decision-making or profiling that has legal or similarly significant effects on you without human involvement. Therefore, this right is generally not applicable in our context.
• Withdrawal of Consent: If we are processing any of your personal data based on your consent, you have the right to withdraw that consent at any time. For example, you can withdraw consent for marketing emails by unsubscribing, or for call recording (if ever consent was sought) by informing us that you do not want certain calls recorded. Withdrawal of consent will not affect the lawfulness of processing that was done before withdrawal.

To exercise any of these rights, please contact us at info@accountapartner.com. We may need to verify your identity to process certain requests (to ensure we don’t disclose data to the wrong person or delete the wrong account). We will respond to your request within one month of receipt, or inform you if we need more time (up to an additional two months for complex requests, as permitted by GDPR).

If you have an account with us, we may also provide self-service tools for some requests (for instance, a way to download your data or delete your account). We will inform you if such tools are available.

Complaints: If you believe your privacy rights have been violated or you are dissatisfied with our handling of your personal data, we ask that you contact us first so we can address your concerns. However, you also have the right to lodge a complaint with a data protection supervisory authority. We will cooperate fully with any official inquiries and will adhere to the decisions of regulatory authorities.

Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If you are under 18, please do not use the Site or sign up for our Services, and do not provide any personal information to us.

If we learn that we have inadvertently collected personal data from a minor under 18, we will take steps to delete that information promptly. Parents or guardians who discover that their minor child has provided personal data to us should contact us immediately at info@accountapartner.com, and we will remove the data and terminate the child’s account if one exists.

Updates to this Privacy Policy

We may modify or update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update the Policy, we will post the new Privacy Policy on this page and update the “Last updated” date at the bottom. In the case of significant changes, we will also notify active subscribers via email.

Continued use of the Services after changes become effective constitutes your acceptance of the revised Policy.

If you do not agree with the changes, you must cancel your subscription before the start of the new billing cycle. In that case, your subscription will continue under the previous Policy until the end of the current billing period, and you will not be charged for any subsequent periods. No refunds will be issued for the current period.

We encourage you to periodically review this Policy to stay informed about how we are protecting your information. If you have any questions about the Terms, please contact us for clarification.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at info@accountapartner.com.

AccountaPartner s.r.o. is committed to protecting your privacy and will address any issues to the best of our abilities. We appreciate you trusting us with your personal data and will continually work to keep that trust.

Last updated: June 7th, 2025