1. Who We Are
Data Controller
Accelerate Partners OÜ
Registration Number: 17207975
VAT: EE102845613
Contact Information
Phone: +372 5479 0346
Address: Sepapaja 6, 15551 Tallinn, Estonia
Website: acceleratepartners.io
Supervisory Authority
Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Tatari 39, 10134 Tallinn, Estonia
Website: www.aki.ee
Email: info@aki.ee
2. What Data We Collect
We collect different types of data depending on how you interact with our services. We prioritize minimal
data collection and use privacy-preserving technologies wherever possible.
Information You Provide Directly
When you contact us, use our products, or subscribe to communications:
- •Contact information: Name, email address, phone number
- •Account information: When using our products like BubbleMom
- •Communication content: Messages, inquiries, and support requests
- •Product usage data: Interactions with our AI products (processed
to improve service)
Information Collected Automatically
Privacy-Focused Analytics (Cookie-Free)
We use Plausible Analytics, a privacy-focused tool that does not use cookies or collect personal data. It
provides only aggregated insights:
- •Page views and visitor counts
- •Traffic sources and referrer information
- •Browser and device types (aggregated)
- •Country-level geographic data (no precise location)
Strictly Necessary Cookies Only
We use minimal cookies required for essential website functionality:
| Cookie | Purpose | Duration |
| Session cookies | Maintain form state | Session (deleted when browser closes) |
| Security cookies (Cloudflare) | Protection against malicious activity | Session |
We do not use:
- •Marketing or advertising cookies
- •Analytics cookies (Plausible is cookie-free)
- •Third-party tracking cookies
- •Social media tracking pixels
3. How We Use Your Data
We process your personal data only when we have a valid legal basis:
| Purpose | Legal Basis | Data Used |
| Providing our products and services | Contract performance | Contact details, account data, usage data |
| Responding to inquiries | Legitimate interests | Contact details, communication content |
| Website analytics and improvement | Legitimate interests | Aggregated usage data (no personal data) |
| Security and fraud prevention | Legitimate interests | Technical logs, IP addresses |
| Legal compliance | Legal obligation | Transaction records, communications |
Our legitimate interests include:
- •Operating and improving our products and services
- •Ensuring website and service security
- •Understanding aggregated usage patterns
- •Communicating product updates and support
We have conducted balancing tests to ensure our legitimate interests do not override your fundamental
rights.
4. Who We Share Your Data With
We share your data only with trusted service providers necessary for our operations. We never sell your personal data.
Our Service Providers
| Provider | Purpose | Location |
| Cloudflare | Website hosting, DNS, security | Global (EU data protection) |
| Plausible Analytics | Privacy-focused web analytics | EU (Germany) |
| Resend | Transactional email delivery | USA (EU-US DPF certified) |
| Buttondown | Newsletter subscription management | USA |
| Stripe | Payment processing | USA (EU-US DPF certified) |
| WhatsApp/Meta | Messaging for BubbleMom | USA (EU-US DPF certified) |
All service providers are bound by data processing agreements ensuring GDPR compliance.
Other Disclosures
We may share your data when:
- •Required by law: To comply with legal obligations or court
orders
- •Protecting rights: To protect our rights, property, or safety
- •Business transfers: In case of merger or acquisition (with
notice)
- •With your consent: When you explicitly agree
5. International Data Transfers
Some service providers operate globally. When your data is transferred outside the European Economic Area,
we ensure protection through:
- •EU-US Data Privacy Framework certification
- •Standard Contractual Clauses approved by the European Commission
- •Adequacy decisions for countries with equivalent protection
You may request copies of our transfer safeguards by contacting .
6. How Long We Keep Your Data
We retain your data only as long as necessary:
| Data Type | Retention Period |
| Contact form inquiries | 3 years from last interaction |
| Product account data | Duration of service + 3 years |
| Communication records | 7 years (legal requirements) |
| Website analytics | Aggregated only (no personal data stored) |
| Security logs | 6 months |
7. Your Rights
Under GDPR, you have comprehensive rights regarding your personal data:
Access and Portability
Request a copy of your personal data in a structured, machine-readable format.
Correction and Erasure
Correct inaccurate data or request deletion when data is no longer necessary.
Restriction and Objection
Restrict processing in certain circumstances or object to processing based on legitimate interests.
Consent Withdrawal
Where processing is based on consent, withdraw at any time without affecting prior processing.
Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects.
To exercise your rights: Contact . We will respond within one month.
Right to Complain
If unsatisfied with our data handling, you may lodge a complaint with the Estonian Data Protection
Inspectorate or your local supervisory authority.
8. Cookies and Tracking Technologies
Our Cookie-Minimal Approach
We believe in privacy by design. Our website uses only strictly necessary cookies required for basic
functionality and security.
What We Use:
- •Session cookies for form functionality (deleted when you close browser)
- •Cloudflare security cookies (protection against attacks)
What We Don't Use:
- •Analytics cookies (Plausible is completely cookie-free)
- •Marketing or advertising cookies
- •Social media tracking pixels
- •Third-party trackers
No Cookie Consent Banner Required
Since we only use strictly necessary cookies for basic functionality and security, we are not required
under GDPR/ePrivacy to show a cookie consent banner. These cookies cannot track you and are essential for
the website to work.
Managing Cookies
You can control cookies through your browser settings:
- •Chrome: Settings → Privacy and security → Cookies
- •Firefox: Settings → Privacy & Security → Cookies
- •Safari: Preferences → Privacy → Cookies
- •Edge: Settings → Privacy → Cookies
Note: Blocking strictly necessary cookies may affect website functionality.
9. Product-Specific Privacy Information
BubbleMom
BubbleMom is delivered via WhatsApp. When you use BubbleMom:
- •Messages are processed to provide AI-powered responses
- •Conversation history may be retained to improve service quality
- •WhatsApp's privacy policy also applies to message delivery
- •Health-related queries are handled with extra care—we provide
information, not medical advice
- •You can request deletion of your conversation history at any
time
10. How We Protect Your Data
We implement appropriate technical and organizational measures:
Technical Measures:
- •Encryption in transit (TLS/SSL) and at rest
- •Regular security updates
- •Access controls and authentication
- •DDoS protection via Cloudflare
Organizational Measures:
- •Limited access on need-to-know basis
- •Confidentiality agreements with staff and processors
- •Data protection impact assessments for high-risk processing
11. Children's Privacy
Our services are designed for adults. We do not knowingly collect data from individuals under 16 years of
age. If we become aware of such collection, we will promptly delete the data.
12. Updates to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material
changes will be communicated through prominent website notices. The "Last Updated" date indicates the most
recent revision.
13. Contact Us
For any privacy-related questions or to exercise your rights:
Accelerate Partners OÜ
Phone: +372 5479 0346
Address: Sepapaja 6, 15551 Tallinn, Estonia
Estonian Language Notice
Vastavalt Eesti seadusandlusele on käesolev privaatsuspoliitika kättesaadav ka eesti keeles. Eestikeelse
versiooni saamiseks võtke ühendust aadressil .
(This privacy policy is available in Estonian upon request.)
This Privacy Policy is effective as of November 25, 2025
