Privacy Policy

Legal entity: Keogh Ltd

Trading as: AccessibilityRef

Registered address: Travessa Dom Sancho I 25, 3030-461 Coimbra, Portugal

Website: Accessibilityref.eu

Data protection enquiries: Contact form

We have not appointed a Data Protection Officer as we do not meet the thresholds under GDPR Article 37. For all data protection enquiries, please use our contact page.

Lead supervisory authority: Comissão Nacional de Proteção de Dados (CNPD), Portugal. You also have the right to lodge a complaint with the supervisory authority in your country of residence.

Account data: Email address and password (hashed) when you register. Stored securely via Firebase Authentication (Google LLC).

Payment data: When purchasing Pro tools, payment is processed by Stripe Inc. We receive only a transaction confirmation and your email. We do not store card details.

Usage data: Page views and tool interactions via Google Analytics 4. This data is anonymised and aggregated, and only collected with your consent.

AI tool input data: When using AI-powered tools (ARIA Assistant, Alt Text Prompter), the content you submit is sent to Anthropic's Claude API for processing. We do not store this input data after the response is returned. Under Anthropic's API terms, inputs and outputs are not used to train their models. Anthropic may retain data for up to 30 days for trust and safety purposes per their data retention policy.

Contract (Art. 6(1)(b)): Processing your account and payment data to provide the service you purchased.

Legitimate interests (Art. 6(1)(f)): Security, fraud prevention, crash reporting, and improving the platform and app.

Consent (Art. 6(1)(a)): Advertising and analytics cookies, only after you click "Accept All" in the cookie banner.

Account data: Retained while your account is active. Deleted within 7 days of an approved deletion request, and within 30 days at the latest (GDPR Article 12(3)).

Payment records: Anonymised Stripe billing records (with personally identifying fields removed) are retained for 7 years to comply with EU tax and accounting obligations under GDPR Article 17(3)(b).

Analytics data: Retained for 14 months (Firebase Analytics default), then automatically purged.

Audit logs: Server-side audit logs of administrative actions and security events are retained for 12 months for security and compliance purposes.

Beyond the records described in section 2, we keep a first-party log of how the site is used. This section is fully transparent: we record more than you might expect, but we keep it ourselves, we do not share it with third-party trackers, and you can opt out of the analytics portion through the cookie banner.

What we record

• view: each page render — path, locale, your account tier if signed in, a rotating session id.
• action: primary button clicks — signup, sign in, checkout, running a tool. Each event has a short name and the page it fired on.
• api_call: every server-side API call our app makes on your behalf — route, HTTP method, response status, duration.
• export: each deliverable document you generate (statements, conformity declarations, technical files, VPATs, compliance reports). Recorded server-side, attributable to your account.
• ai_call: each successful invocation of an AI feature (alt-text generator, ARIA generator, document analysers).
• signup_acknowledgement: a record at account creation showing you saw the refund-cap terms — version, caps, a hashed and truncated IP address.

Why we record it

Product improvement (which tools are used, which workflows succeed) and dispute resolution. Our 30-day refund promise ends once you have generated 3 full deliverables or made 2 AI-assisted generations — the export and AI-call records back that policy if a refund is ever disputed.

Legal basis

Essential events (api_call recorded server-side, export, ai_call, signup_acknowledgement, refund_counter, refund_request) run on our legitimate interest in service delivery, fraud prevention, and dispute resolution (GDPR Article 6(1)(f)). Analytics events (view and action beacons) run on your consent through the cookie banner (Article 6(1)(a)); rejecting the analytics bucket disables them. Marketing cookies (Google Ads partnership) are independently consented.

Retention

Raw events expire automatically after 90 days. Daily aggregate rollups (counts of events per tool per day with cardinality counts of unique users) are kept indefinitely but contain no personal identifiers. Refund-counter records and signup acknowledgements are kept for the duration of your account plus any dispute window.

Your rights

Section 5 of this policy lists the GDPR rights that apply to all data we hold. Specifically for analytics: you can opt out of analytics beacons through the cookie banner. You can request export or deletion of every record above through your account settings — deletion removes raw events, refund counters, signup acknowledgements, and refund requests within the SLA in section 5.