Privacy Policy

Last updated: 27 October 2026

1. Who we are

Accordo is a trading name of LUX APPS LTD (Accordo, we, us or our). We are committed to protecting your personal data and to complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection law.

Accordo is a survey and workplace insights platform used by:

Customers and Users: organisations, workplace teams and consultants who hold an Accordo account, and the colleagues they invite to their workspace.
Participants: people who answer a survey sent to them by a Customer, usually as an employee of that Customer or of a consultant's client.
Website visitors: people who visit our website.

2. Please read this first: two different roles

If you have an Accordo account (Customers and Users): Accordo is the data controller for your account data. Sections 3 to 9 explain how we use it.

If you are answering a survey (Participants): the organisation that sent you the survey, usually your employer, is the data controller for your responses. Where a consultant runs the survey for your employer, the consultant and your employer are responsible for how your responses are used. Accordo processes your responses as a data processor, on their instructions, to deliver the survey and its results. This means:

questions about why your responses are collected, who will see them and how long they are kept should go to the organisation that sent you the survey; the survey's introduction or privacy text is the best place to start;
section 10 explains how Accordo handles Participant data as a processor.

3. Contact us

We have not appointed a Data Protection Officer. For any questions or requests about your data, contact [email protected] or write to us at the address in section 17.

You have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk. We would appreciate the chance to resolve your concern first, so please contact us before going to the ICO if you can.

4. Data we collect

4.1 Account data (Customers and Users). Your name, email address, a hashed password, your organisation, your role and permissions, and your account preferences such as language.

4.2 Billing data. For paid plans, billing contact details, plan and invoice history. Card payments are handled by our payment provider; we do not store full card details.

4.3 Survey content. Questions, answer options, templates, branding, introduction and consent text, and any historical survey data a Customer chooses to import.

4.4 Participant data (processed for Customers). Depending on how a Customer sets up a survey, this may include:

invitation details, such as name, email address, or Slack or Microsoft Teams identifier, and group details such as team, location or role, from data lists the Customer provides;
survey responses, including free-text answers and the language they were given in;
response metadata, such as start and completion times.

4.5 Anonymous surveys. When a Customer chooses anonymous responses, the survey does not record Participants' identities with their answers. Participants may still be identifiable from what they write in free-text answers, or where results are reported for very small groups, so please avoid including identifying details in free text if you want to stay anonymous.

4.6 Special category data. We do not deliberately collect special category data, such as information about health, ethnicity, religion or sexual orientation, from account holders. Some surveys, such as wellbeing surveys, may ask Participants about these topics. The Customer, as data controller, is responsible for having an appropriate lawful basis and safeguards in place.

4.7 Website and technical data. IP address, browser and device type, pages visited and similar technical data, used to run, secure and improve our website and Services.

4.8 Communications. Messages you send us, for example through support or live chat, and your marketing preferences.

5. Our legal bases

We rely on:

Contract: to create and manage your account and provide the Services.
Legitimate interests: to operate, secure and improve the Services, prevent misuse, and communicate with you about your account, where this does not override your rights.
Consent: for optional cookies and marketing emails, which you can withdraw at any time.
Legal obligation: where we must keep or disclose data by law, for example for tax records.

For Participant data, the Customer is responsible for establishing the lawful basis.

6. How we use account data

We use account data to provide and manage your account and workspace, operate the survey builder, distribution and analytics, provide support, send service and security messages, process payments, and, with your consent, send product news. We use aggregated usage information to understand how the Services are used and to improve them.

7. AI features

Accordo uses AI tools, some provided by third parties, to translate survey content and responses and to generate summaries of open-text feedback. We do not use survey content or Participant responses to train AI models. AI providers process this content only to provide these features to the Customer, under contractual protections.

8. Cookies

We use:

Essential cookies: to keep you signed in, secure the Services and let Participants resume an incomplete survey on the same device.
Analytics and support cookies: on our website, to understand how it is used and to provide live chat support, only where you have given consent.

You can change your cookie choices at any time. We do not use advertising cookies.

9. Your rights

Subject to certain exceptions, you have the right to:

be informed about how we use your data (this policy);
access a copy of the personal data we hold about you;
rectify inaccurate or incomplete data;
erasure of your data in certain circumstances;
object to processing based on legitimate interests, and to direct marketing at any time;
restrict processing in certain circumstances;
data portability, where processing is based on consent or contract and carried out by automated means.

To exercise these rights, contact [email protected]. We will not usually charge a fee, and we may need to verify your identity. If you are a Participant, we will pass your request to the relevant Customer, as they control your survey data.

10. Participant data: how Accordo acts as a processor

When a Customer runs a survey, Accordo:

stores invitation lists and responses in the Customer's workspace, separately from other Customers and, for consultants, separately for each client organisation;
sends invitations by email, Slack or Microsoft Teams where the Customer has set this up;
translates survey content and responses, and generates AI summaries of open-text feedback, for the Customer;
makes results available only to the Customer's authorised Users, according to the access permissions the Customer sets;
keeps original responses alongside any translation.

Accordo does not sell Participant data, use it for advertising or use it to train AI models. Where we provide benchmark comparisons, we may use aggregated and anonymised data that does not identify any Customer, client organisation or individual.

We share personal data with service providers who help us run the Services, including:

hosting and infrastructure providers;
AI translation and summarisation providers;
email delivery providers;
payment providers, for paid plans;
analytics and customer support tools, where you have consented to the related cookies.

Where a Customer connects Slack or Microsoft Teams, survey invitations are sent through those platforms under the Customer's own agreement with them.

We require our providers to process data only on our instructions and to keep it secure. We may also disclose data where required by law, or to a buyer or successor if our business is sold or reorganised, in which case your data will remain protected by equivalent terms.

12. How long we keep data

We keep account data while your account is active, and for a reasonable period afterwards to deal with queries and meet legal obligations. Survey content and Participant data are kept while the Customer's account is active, until the Customer deletes the survey or responses, or until the account is closed, after which they are deleted in line with our retention practices. Billing records are kept for as long as tax law requires.

13. International transfers

Some of our providers, including AI and infrastructure providers, may process data outside the UK. Where they do, we make sure appropriate safeguards are in place, such as UK adequacy regulations or the UK International Data Transfer Agreement or Addendum.

14. Children

Accordo accounts are for people aged 18 and over. The Services are designed for workplace surveys, and we do not knowingly collect personal data from children. If a Customer surveys anyone under 18, the Customer is responsible for appropriate consent and safeguards.

15. Security

We protect personal data with measures appropriate to the risk, including access controls, role-based permissions and encryption in transit. Access is limited to staff and providers who need it to operate the Services. No system is completely secure, so if you believe your account or data has been compromised, contact us immediately.

16. Changes to this policy

We review this policy regularly and will post updates on this page. If changes are significant, we will tell account holders by email or in the workspace.

17. Company details

Accordo (trading name of LUX APPS LTD)
Company Number: 13566067
27 Old Gloucester St
Holborn, London
WC1N 3AX
United Kingdom

Email: [email protected]