Privacy Policy
Last updated: 6 November 2026
This explains what KRAMO collects, why, and how to make us delete it. It is written to be read, not to be survived. If anything here is unclear, email support@promo.kramo.org and ask.
Who we are
KRAMO is a study tool for candidates preparing for ACCA examinations. It is independent: not affiliated with, endorsed by or connected to the ACCA. KRAMO is operated by Translate.com LLC (trading as Kramo), 571 Washington Street, Afton, WY 83110, United States, which is the data controller for the information described below.
What we collect
| What | Why |
|---|---|
| Your email address, and your name if you give it | To create your account, give you access, and reply to you |
| The exam paper and sitting you tell us you are preparing for | To show you the right questions and scope your feedback |
| The answers you write and the marks and feedback they receive | This is the product — your history is what makes the diagnosis possible |
| Usage events: pages seen, buttons pressed, the page you came from, ad campaign tags, your browser and device, and a random visitor ID | To see which parts of the product and which ads work |
| Your country, worked out from your IP address | To show the right prices and currency |
| Your IP address | Stored with each free demo request, to limit abuse of the demo. Stored with your payment record at checkout, together with your browser details, so a purchase can be matched to the ad that led to it. For college and tuition enquiries we keep only a hashed version |
| Meta's click and browser identifiers, if you have them from a Meta ad or the Meta Pixel | To match a purchase to the ad that led to it |
| Billing details: your plan and whether it is active, the amount and currency, any promo code, and the email and country given at checkout | To give you access to what you paid for and to keep sales and tax records |
| If you message us on WhatsApp: your phone number, your WhatsApp name and your messages | To reply to you. WhatsApp, which is part of Meta, also processes them under its own terms |
| If you enquire for a college or tuition provider: your name, organisation, work email, phone if given, country and number of students | To reply to your enquiry and prepare a quote |
We never see your card. Payments are handled entirely by a PCI-compliant payment processor. Card numbers, UPI credentials and bank details are entered on their systems and are never transmitted to or stored by us. We receive the result of the payment and the billing details listed above.
What we do not do
- We do not sell your data. Not to anyone, at any price.
- We do not share your answers or your marks with advertisers.
- We do not publish your answers, your marks or your results. They are yours.
- We do not use your individual answers as public examples without asking you first.
Who processes it on our behalf
We use a small number of specialist service providers to run the service. We do not name their brands here, but the categories are complete:
- a cloud hosting and database provider, which stores your account and your answers;
- a payment processor, which takes payments and holds the card details we never see;
- an email delivery provider, for account and service emails, progress updates, and reminders about a checkout you did not finish;
- an analytics provider, for aggregate usage statistics;
- an advertising platform, which receives information about visits and purchases so we can measure how our ads perform;
- an AI model provider, which processes the text of your answers to mark them, and your questions to the AI tutor to reply to them;
- a location lookup service, which can turn an IP address into a country.
Each is bound to use the data only to provide that service to us. Some are located outside your country, so your data may be transferred internationally; where that happens we rely on the provider's standard contractual protections. If you want the specific companies named, email us and we will tell you.
How long we keep it
- Your account and your answers — while your account exists, and for 12 months after you last use it, so you can come back to an unfinished session.
- Billing records — as long as tax and accounting law requires us to keep them.
- Usage events — indefinitely. They are linked to a random visitor ID, or to your account if you are signed in, and contain no email address.
- Enquiries from colleges and tuition providers — while we are discussing working together, and no longer than 24 months after our last contact.
Your rights
You can ask us to show you what we hold about you, correct it, export it, or delete it. One email to support@promo.kramo.org is enough — you do not need to give a reason and we will not try to talk you out of it. We will respond within 30 days. Deleting your account removes your answers and your marking history; we cannot recover them afterwards.
You can switch off progress and product emails in Settings, or email us and we will stop them.
Depending on where you live you may also have the right to complain to a data protection authority. Doing so does not affect any of the above.
Cookies
We use what is needed to keep you signed in. We also use Google Analytics to count visits and see which pages work, and the Meta Pixel to measure how our ads perform. Both set their own cookies, and Google and Meta receive information about your visit, such as the pages you view and any purchase. In the UK and Ireland they stay off unless you accept them in the cookie banner, and you can change your answer at any time under Cookie settings at the bottom of the page. Until you accept, the random visitor ID lasts only for that visit. You can also block cookies in your browser; sign-in will stop working if you block the essential ones.
Children
KRAMO is for people preparing for a professional accountancy qualification and is not intended for anyone under 16. We do not knowingly collect data from children.
Changes
If we change this policy we will update the date at the top, and if the change is significant we will email account holders rather than hoping they re-read this page.