Privacy Policy
Accendo Associates LLC
Version 2.1. Last updated: October 20, 2026
1. Who we are
Accendo Associates LLC (“Accendo,” “we,” “us” or “our”) is a limited liability company formed in Maryland, United States. We decide how and why the personal information described in this policy is used. In some laws this role is called the “controller” or “data fiduciary.”
Registered office and privacy contact:
Accendo Associates LLC
306 W Redwood St, Ste 201, Baltimore, MD 21201, USA
Email: [email protected] (subject line “Privacy request”)
This policy covers our website (accendoassociates.com), our forms, emails and events, the Impact Investors AI Circle, the Impact Lender AI.OS resource for registered users, and our business contacts. It does not cover personal information we handle for a client under a client contract. That contract governs such information.
2. One standard for everyone
People from many countries use our website and services. We give everyone the protections and rights in this policy, wherever they live, whether or not a local law requires them. Where the law of your country gives you more rights, we honor those rights as well. Section 14 adds points that apply in specific places.
3. Information we collect
Information you give us. When you contact us, subscribe to updates, register for an event or complete an assessment, we collect the details you enter. These can include your name, email address, phone number, job title, organization, country and your message.
Impact Lender AI.OS registered users. When you register, we collect your name, work email, institution, institution type, country and department, and your institution’s website. We also collect how you heard about the resource, with the detail you give. You may also give your institution’s size band and the type of AI tool it uses. We record the date of registration, the version of the terms you accepted, and your choice on follow-up contact. If you set up a passkey, we store only its public key. The private key stays on your device.
Your use of Impact Lender AI.OS. We record when you view, copy, save or download a template, and the feedback you give. Each record holds a usage token that links to your user ID in our systems, the template, its version, the type of event and the time. If you answer the 90-day check-in, we collect your answers.
Clients and AI Circle members. If you join the Impact Investors AI Circle or engage us for services, we collect your contact and billing details and the information you share during the work. Our agreement with you governs confidential information.
Sanctions screening. Before we confirm a paid order, we screen the buyer and, where relevant, its owners and the people who will take part, against sanctions lists. We use the name, organization and country you give us. We ask for more detail, such as date of birth or nationality, only if we need it to rule out a possible match. We do not screen registered users of our free resources.
Information collected automatically. When you visit our website, our systems and service providers collect your IP address, browser and device type, the pages you visit, the referring page, the time of your visit and your approximate location based on your IP address. Section 7 covers cookies.
Information from others. We may receive your business contact details from a person who refers you to us, from an event organizer, or from public professional sources such as LinkedIn when you contact us.
What we do not collect. We do not ask for sensitive personal information, such as health, financial account, government ID, religion or biometric data. Our forms do not ask for personal information about your institution’s clients or staff. Do not enter it in any form or feedback field. No AI runs on the Impact Lender AI.OS pages. You copy each prompt and run it in your institution’s own AI tools. We do not see what you enter into those tools or what they return.
4. How we use information
| Purpose | Legal basis, where a law requires one |
|---|---|
| Answer your inquiries and discuss possible work | Legitimate interests, or steps before a contract |
| Create and run your Impact Lender AI.OS account, including sign-in by emailed link or passkey, and show your saved templates | Contract |
| Check sign-ups to keep out automated and false accounts (see section 6) | Legitimate interests (security) |
| Send service emails, such as confirmation, sign-in, access and 90-day check-in emails | Contract |
| Learn which templates are used and what they achieve, and improve the resource | Legitimate interests |
| Report usage counts by institution type, country and institution name to Accendo’s administrator (see section 5) | Legitimate interests |
| Publish aggregate figures that do not identify you or your institution | Legitimate interests |
| Send updates, insights and event invitations | Consent, or legitimate interests for existing business contacts where the law allows |
| Deliver services and AI Circle sessions, and invoice for them | Contract, legal obligation |
| Screen paid orders against sanctions lists | Legal obligation, legitimate interests |
| Keep our website and systems secure and working | Legitimate interests |
| Meet legal, tax, accounting and regulatory duties, and protect our legal rights | Legal obligation, legitimate interests |
We use legitimate interests only where our interest is not outweighed by your rights. You can object at any time (section 11). We contact registered users about Accendo’s services only if they agree at sign-up or later. We do not use personal information for a new purpose that is incompatible with the original one without notice, and without your consent where the law requires it.
5. Naming institutions
Accendo’s administrator sees usage counts for each named institution on a private dashboard. Only the administrator account can open it. It holds counts and institution names. It holds no names of people, email addresses or IP addresses. We do not share this report outside Accendo. Where an institution is run by one person, its name identifies that person, so we treat its usage counts as that person’s personal information, and the rights in section 11 apply to them. We name your institution in a case study or on our website only with written consent from your institution.
6. Automated checks and AI
Sign-up checks. To protect the resource, our website checks each sign-up automatically. It uses Google reCAPTCHA, a confirmation email, a limit on sign-ups from one network, a check that the email domain is not a disposable one, and a check that your institution’s website exists. Some sign-ups go to our team for review. If a check stops your sign-up, contact us and a person will review it.
No significant automated decisions. We do not make decisions that have legal or similarly significant effects on you by automated means alone, and we do not profile you for such decisions.
AI tools in our work. We use AI tools to support research, drafting and internal operations. Each template and library we share shows, for each AI tool it names, the type of data the template suits and an indication of its token use. We give this information to the best of our knowledge and do not guarantee it. Check the terms of your own AI tools before you enter data into them. We are not liable for how those tools handle your data.
7. Cookies
We use a small number of cookies and similar technologies:
- Essential cookies keep you signed in, remember your choices in forms, and protect the website. Cloudflare sets security cookies to tell people from automated traffic.
- Google reCAPTCHA runs on our sign-in and registration pages. Google collects device and interaction data to assess whether the visitor is a person. The Google Privacy Policy and Terms of Service apply to this use.
- Analytics cookies. We use Google Analytics to count visits and see which pages people read. Google receives your IP address and information about your device and visit. Google Analytics runs only after you accept analytics cookies.
Our cookie banner lets you accept or reject non-essential cookies, and you can change your choice at any time from the Consent Preferences button at the bottom left of each page. We do not use advertising or retargeting cookies. If we add tools that need consent, we will ask before they run and update this section. You can also block or delete cookies in your browser settings. Some parts of the website, such as sign-in, will not work without essential cookies.
8. Who we share information with
We share personal information only with:
- Service providers that host and run our systems for us, under contracts that limit their use of the information. They are Bluehost (website hosting and firewall), Cloudflare (security and content delivery), Microsoft 365 (email and documents), Google (Analytics and reCAPTCHA), CookieYes (cookie consent), Automattic (Jetpack website backups) and DigitalOcean (the server for our n8n workflow tool, which holds a copy of registration data and usage records).
- Professional advisers, such as lawyers, accountants and auditors.
- Authorities, such as regulators, courts and law enforcement, where the law requires it.
- A successor business, if we restructure or transfer part of our business. The successor must protect the information as this policy describes.
We do not sell personal information. We do not share it for cross-context behavioral or targeted advertising. We do not share information that identifies a registered user or their institution with funders or investors.
9. International transfers
Accendo is based in the United States, and our service providers process information in the United States and other countries. If you are outside the United States, your information is transferred there. Where the law of your country requires a safeguard for such transfers, we rely on one of these: the provider’s certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, standard contractual clauses approved for that purpose (including the UK International Data Transfer Agreement or UK Addendum), or another mechanism that the law allows. Contact us for a copy of the relevant safeguard.
10. How long we keep information
| Information | Period |
|---|---|
| Website inquiries | Up to 3 years after our last contact |
| Marketing contacts | Until you unsubscribe or the contact is no longer active |
| Impact Lender AI.OS account data | While your account is open. If you do not sign in for 24 months, we delete the account or make the data anonymous. We email you 30 days before we do this |
| Usage records linked to your user ID | 24 months, then made anonymous |
| Usage tokens | 30 days, or until you sign out |
| Closed accounts | Deleted within 30 days, unless the law requires us to keep the data |
| Email delivery logs | 7 days |
| Client and AI Circle records | Up to 7 years after the relationship ends, unless the law requires longer |
| Session recordings and transcripts | Deleted when the membership ends, and at the latest 12 months after the session |
| Sanctions screening records | 10 years from the order or the end of the relationship, as US recordkeeping rules require |
| Records of your acceptance of our Terms of Service | 7 years after the account or order ends |
| Legal, tax and accounting records | As the law requires |
Where no fixed period applies, we decide based on the purpose, legal requirements, risk and business need. Anonymous figures that cannot identify you may be kept.
11. Your rights
Wherever you live, you can ask us to:
- Tell you whether we hold personal information about you, and give you a copy.
- Correct information that is wrong or incomplete.
- Delete your information.
- Give you your information in a portable format.
- Stop or limit some uses, including any use based on legitimate interests.
- Withdraw consent you gave, at any time and as easily as you gave it.
- Stop marketing emails. Every marketing email has an unsubscribe link.
- Opt out of sale, targeted advertising and profiling. We do none of these, and we treat a Global Privacy Control signal from your browser as a valid opt-out.
- Accept a request from a person you authorize, or a person you nominate to act for you if you die or cannot act.
How to ask. Email [email protected] with the subject line “Privacy request.” Registered users can also update their details and close their account from their account page. We may need to confirm your identity first. We respond within 30 days. If a request is complex, we may extend this where the law allows, and we will tell you why. Requests are free unless they are clearly unfounded or excessive.
Appeals. If we decline a request, we explain why. You can appeal by replying to our answer. We decide the appeal within 60 days and tell you the result.
You will not be treated differently for using these rights.
12. Complaints
If you have a concern about how we handle your information, contact us first. We acknowledge your complaint within 7 days and give you our answer within 30 days. You also have the right to complain to the data protection authority in your country, such as the Maryland Attorney General in Maryland, the Information Commissioner’s Office in the United Kingdom, the supervisory authority in your EU member state, or the Data Protection Board of India.
13. Security
We use technical and organizational measures that fit the information we hold. These include encrypted connections, passwordless sign-in, two-factor sign-in for administrators, limited administrator access and regular backups. No system is completely secure. If a breach affects your personal information, we notify you and the authorities where the law requires it.
14. Additional points for specific places
European Economic Area, United Kingdom and Switzerland. The legal bases in section 4, the transfer safeguards in section 9 and the right to complain in section 12 apply. Where we rely on consent, you can withdraw it at any time without affecting earlier use.
United States. Some state laws, such as the Maryland Online Data Privacy Act and the California Consumer Privacy Act, give residents specific privacy rights. We give the rights in section 11 to everyone, whether or not these laws apply to us. We do not sell personal information, we do not process sensitive data for advertising, and we do not knowingly sell or use for targeted advertising the information of anyone under 18. In the past 12 months we have collected the categories in section 3: identifiers and contact details, professional and institutional information, and internet activity on our website. We used them for the purposes in section 4 and disclosed them only as section 8 describes.
India. We process registration data for Impact Lender AI.OS with your consent, which you give at sign-up and can withdraw at any time. You can nominate another person to exercise your rights. For grievances, contact us as section 12 describes. If you are not satisfied with our answer, you can complain to the Data Protection Board of India.
Other countries. Data protection laws in countries such as Brazil, Kenya, Mexico, Nigeria and South Africa give rights similar to those in section 11. You can use them through the same contact, and you can complain to your national data protection authority.
15. Children
Our website and services are for business and professional audiences. They are not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has given us personal information, contact us and we will delete it.
16. Links to other websites
Our website links to other websites and platforms. Their own privacy policies apply. We are not responsible for their practices.
17. Governing law
This policy is governed by the laws of the State of Maryland, United States, without regard to its conflict of laws rules. Disputes about this policy are resolved as the governing law and disputes section of our Terms of Service sets out. This section does not remove any right that the mandatory data protection law of your country gives you, including the right to complain to your national data protection authority, or to bring a claim in your local courts where that law allows it.
18. Changes to this policy
We may update this policy. We post the new version on this page with a new “Last updated” date. If a change is material, we also email registered users and AI Circle members before it takes effect.
19. Contact us
Accendo Associates LLC
306 W Redwood St, Ste 201, Baltimore, MD 21201, USA
Email: [email protected]