Privacy Policy

Owner and Data Controller

Fragua Labs LLC, 30 N Gould St Ste N, Sheridan, WY 82801, USA

Owner's contact email: [email protected]

Types of Data we collect

Among the types of Personal Data that this Application collects, either directly or through third parties, are:

• Usage Data
• Trackers
• Device information

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when this Application is used.

Unless otherwise indicated, all Data requested by this Application is mandatory, and refusal to provide it may make it impossible for this Application to provide its services.

Methods and place of processing of the collected Data

Processing methods

The Owner will process Users' Data appropriately and will adopt appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of the Data.

Data processing will be carried out using computers and/or IT tools, following procedures and organizational methods strictly related to the purposes indicated.

Location

The Data is processed at the Owner's offices, as well as at any other location where the parties involved in the processing are situated.

Retention period

Unless otherwise stated in this document, Personal Data will be processed and retained for as long as necessary and for the purpose for which it was collected, and may be retained for longer due to a relevant legal obligation or on the basis of Users' consent.

Certificates after an academy closes: if an academy leaves the platform and its data is deleted, the Owner keeps a minimal record of each valid certificate it issued (verification code, student name, subject, academy, issue and closing dates, requirement and the certificate PDF) and a one-way hash of the student's email, which cannot be used to recover the email. It is kept so the certificate can still be verified publicly and so its holder can download it. Students can ask for its deletion by contacting the Owner.

Chat messages between students and academies: each message is stored with the sender's email and IP address. If a student deletes their account or the academy removes them, their profile is anonymized, but their messages (text, email and IP) are kept for 3 years from the deletion, on the basis of legitimate interest, so that possible claims can be handled or defended; after that period they are deleted. During that time the academy only sees "Deleted student", and the email and IP are only accessible to the Owner in response to a legal request or a claim. For all other messages, the IP is erased 3 years after sending.

Purpose of Processing the collected Data

Data relating to the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, and protect its rights and interests, as well as for the following purposes:

• Display content from external platforms
• Platform and hosting services
• Traffic optimization and distribution

Providers that process data on behalf of Acatudy

To provide the service, Acatudy relies on these providers, which process data only on our instructions and with the safeguards required by law:

• Stripe: subscription payments and the payments academies collect from their students.
• Cloudflare: web traffic delivery and protection, and storage of uploaded files.
• SendGrid: sending the service's emails.
• Anthropic: AI assistants: Tudy (help assistant), Kody (website generator) and Quiddy (question generator). It receives the text and material you send to those assistants so they can answer.

Cookie Policy

This Application uses strictly necessary cookies for the service to work (session, security and your cookie choices) and, only if you accept it, a preferences cookie to remember your language. We use no advertising or analytics cookies. If an academy enables its own analytics (e.g. Google Analytics), it only loads with your consent and the academy will tell you in its own policy. Cookie Policy

More information for users in the European Union

Legal basis of Processing

The Owner may process the User's Personal Data if one of the following conditions is met:

• When Users have given their consent for one or more specific purposes.
• When the collection of Data is necessary for the performance of a contract with the User.
• When the processing is necessary for compliance with a legal obligation.
• When the processing is related to a task carried out in the public interest.
• When the processing is necessary for the purposes of a legitimate interest pursued by the Owner or a third party.

Users' rights under the GDPR

Users may exercise certain rights in relation to their Data:

• Withdraw their consent at any time.
• Object to the processing of their Data.
• Access to their Data.
• Verify and request rectification.
• Restrict the processing of their Data.
• Erase or delete the Personal Data.
• Receive their Data and transfer it to another controller.
• Lodge a complaint with the competent authority.

How to exercise these rights

You can exercise your rights of access and erasure directly from your profile, in the "Privacy and data" section (download of your data and account deletion, immediately and free of charge). For any other right, contact the Owner using the contact details in this document; they will respond as soon as possible and always within one month.

Information for users in the United States (CCPA/CPRA)

If you reside in California or another state with its own privacy laws, you have the right to know and access the personal data we process about you, to request its deletion, and to not be discriminated against for exercising these rights.

We do not sell or share your personal data for advertising purposes. You can exercise these rights from your profile ("Privacy and data") or by writing to the contact listed in this document.

Additional information about Data collection and processing

Legal defense

The User's Personal Data may be used for the Owner's legal defense in court or in the judicial stages leading up to possible litigation arising from the improper use of this Application or the related Services.

Changes to this privacy policy

The Owner reserves the right to modify this privacy policy at any time, notifying Users through this page. Users are strongly encouraged to review this page frequently, referring to the date of the last update indicated at the top of the page.

How can we help you?

If you have any questions about this privacy policy or wish to exercise your rights, you can contact us at:

Email: [email protected]