Accord Privacy Policy
Updated: 1 July 2025
1. Introduction
This Privacy Policy explains how we collect, use, share, and protect personal data when you use Accord software and services (collectively, the "Service"). The Service is provided by Layer Labs Pty Ltd (ABN 22644264166) Layer Licensing Limited (Company Number 15997740) ("Company", "we", "us", or "our").
We are committed to ensuring the fair and appropriate handling of your personal data.
By using the Service, you agree to the collection and use of information in accordance with this policy.
Accord applies applicable data protection laws of the jurisdictions in which we are operating. Data protection laws guide how we collect and manage your personal data. Importantly, we:
● are transparent about our personal data handling practices
● limit our collection of personal data to that which is necessary for our functions
● understand our platform’s purposes, and restrict our use and disclosure of personal data in that regard
● take reasonable steps to keep the personal data we have secure.
We use the term ‘Privacy Notice’ as set out in the UK General Data Protection Regulation (UK GDPR) interchangeably with the term ‘Privacy Policy’ as set out in the Australian Privacy Act 1988.
2. About Accord
Accord is a product that helps teams better understand their Discord communities. Accord utilises the Discord application programming interface ("API") to access, read, collate, and organise messages and data from designated Discord servers.
For the purposes of data protection law, we act as the "data controller" for the information you provide when registering for and using our Service (Platform Data), and as a "data processor" for the Discord server data we process on your instruction (Discord Server Data). Our contact details are provided at the end of this policy.
3. Information We Collect
We collect information in different ways when you use our Service:
a) Information You Provide to Us (Platform Data):
● This is information we receive when you, our Customer, register for, or use, our Accord platform. This may include:
● Name: Your full name or the name of your organisation.
● * Contact Information: Email address, and any other contact details you provide.
● Account Information: Your username, password, and other details related to your Accord account.
● Order and Transaction History: If applicable to paid services, details of subscriptions or purchases you make.
● Communications: Any communications you send to us (e.g., for support or feedback).
● Usage Data and Telemetry: Information about how you use our Service, such as features accessed, and performance metrics. This helps us improve our Service.
b) Information We Process on Your Behalf (Discord Server Data):
● When you, our Customer, instruct Accord to analyze specific Discord servers, Accord uses the Discord API to view and collect messages and other information posted by users in public channels within those designated Discord servers. This data is processed by Accord at your instruction and for the purpose of providing you with insights and analytics about those communities. This "Discord Server Data" constitutes "API Data" under Discord's Developer Terms. This includes: ○ Messages and Content: The textual content of messages users have voluntarily shared in those public Discord channels.
○ Associated Identifiers: The unique 18-digit Discord User ID of the individual who posted the message, and their Discord username at the time the message was collected.
○ Metadata: Other information associated with messages, such as timestamps, server IDs, and channel IDs.
● We only access data that users have made available on Discord in public channels designated by you. Discord's Privacy Policy (https://discord.com/privacy) provides information on how they share data with third-party developers like us.
● We do not require the installation of any Discord bot on a Discord server for this purpose, and our access is typically based on view-only permissions for publicly available information as facilitated by the Discord API and your designation.
● We do not have direct interaction with members of the Discord communities you designate through our platform in their capacity as community members.
4. How We Use Your Information
We use the information we collect for the following purposes:
a) To Provide and Manage the Service to Our Customers:
● To set up and maintain your Accord Customer account.
● To enable you to use the features of our Service, including designating Discord servers for analysis and receiving insights derived from Discord Server Data.
● To process any subscriptions or transactions.
● To provide customer support and respond to your enquiries.
b) To Improve Our Service:
● To understand how our users interact with the Service, to identify areas for improvement, and to develop new features.
● To monitor the performance and stability of our Service.
● As further detailed in Section 7, we may use genuinely anonymised and aggregated data derived from the operation of our service for internal analytics, research, and overall service enhancement.
c) To Communicate With You (Our Customer):
● To send you service-related announcements, updates, security alerts, and administrative messages.
● To send you marketing communications if you have consented to them or where otherwise permitted by law (you can opt-out at any time).
d) For Legal and Security Reasons:
● To comply with our legal obligations.
● To enforce our Terms of Service and protect our rights and the rights of others.
● To detect and prevent fraud, security breaches, and other harmful activities.
5. Legal Basis for Processing Personal Data
We process your personal data based on the following legal grounds under GDPR and UK GDPR:
● Performance of a Contract:
○ When you, as our Customer, register for and use Accord, we process your Platform Data (as described in 3.a) as necessary to fulfill our contractual obligations to provide the Service to you, as set out in our Terms of Service.
● Legitimate Interests:
○ We process Customer Platform Data (such as usage data and communications) to pursue our legitimate interests in understanding market trends, our customers' needs, how the Service is used, and to improve the Service.
○ We also process data to monitor compliance with our Terms of Service and to protect our business.
○ When processing Discord Server Data (as described in 3.b) on behalf of our Customer, you, as the Customer designating the server for analysis, are responsible for ensuring you have a lawful basis for instructing us to process that data. Our legal basis for processing this Discord Server Data as a service provider is to fulfill our contract with you and based on your instructions.
● Consent:
○ For certain types of processing, such as sending direct marketing emails to our Customers, or for the use of certain non-essential cookies on our website, we will rely on your consent. You can withdraw your consent at any time.
● Legal Obligation:
○ We may process your personal data if necessary to comply with a legal or regulatory obligation.
6. Sharing and Disclosure of Information
We are committed to transparency in how we share and disclose information.
● To Our Customers: When you, our Customer, use the Service to analyze designated Discord servers, Accord processes Discord Server Data (which includes public messages and associated identifiers of Discord end-users who posted those messages) and provides insights and analytics derived from this data back to you. In this context: ○ You, the Customer, are the data controller for the purposes of your community analysis and for the Discord Server Data you instruct us to process.
○ Accord acts as a data processor on your behalf for this Discord Server Data.
○ Accord does not control how you, our Customer, may subsequently use or disclose the insights or data provided through the Service. Discord end-users whose public messages are processed should be aware that the administrators of the Discord servers they participate in may use tools like Accord for community insights. Discord’s Privacy Policy (https://discord.com/privacy) makes this clear and we encourage Discord end-users to review Discord’s privacy policies and practices.
● Sharing Between Layer Labs Entities (If Applicable): ○ We share your personal data (both Platform Data and, where necessary for service provision, Discord Server Data) between Layer Labs group entities, for example, between Layer Labs Pty Ltd (Australia) and Layer Licensing Limited (UK) to provide global support and service continuity. We have implemented intra-group data sharing agreements that ensure your data is treated according to strict privacy and data protection standards (including GDPR and UK GDPR standards) regardless of which entity is processing it.
● Our Service Providers (Sub-processors): Accord uses third-party service providers (Sub-processors) to provide essential services and functions on our behalf, such as cloud hosting, payment processing, customer support tools, and analytics for our own Service. For our Sub-processors to provide these services, we may need to share personal data (which can include Platform Data and, in some instances, Discord Server Data) that is relevant to the services being provided, or they may collect certain information on our behalf. ○ We have contractual arrangements in place with all our Sub-processors that include strict obligations regarding data privacy, security, confidentiality, and data breach reporting.
○ We take steps to ensure that Sub-processors only process personal data for the specific purposes for which it was provided to them, in accordance with our instructions, and not for any other purpose.
○ A list of our key Sub-processors can be made available upon reasonable request, subject to confidentiality considerations.
● Other Sharing and Disclosures: Accord will not sell your personal data. We will not otherwise share your personal data (Platform Data or Discord Server Data) with other third parties, such as advertisers or unrelated data brokers, unless: ○ We have your explicit consent to do so (for example, if you, as a Customer, request an integration with another service); or
○ There is a lawful ability or legal requirement for us to do so (e.g., to comply with a court order, subpoena, or other lawful request from public authorities, or to protect our legal rights or the safety of others).
● Website Analytics and Marketing (Relating to Accord's Own Marketing): We may use analytics tools on our own website (where you learn about and sign up for Accord) to understand website traffic and improve our marketing efforts for the Accord service. If we use tools for advertising or retargeting related to promoting Accord itself (for example, to show ads for Accord to potential customers who have visited our website), this will be based on your interaction with our website and any consents you provide for cookies or similar technologies, as detailed in our separate Cookie Policy (if applicable) or website cookie banner. This processing relates to data about visitors to our marketing website, not the Discord Server Data processed through the Accord service.
● International Data Transfers: As Accord operates and provides services that may involve Customers and data from various global locations, personal data we collect may be transferred to, and processed in, countries outside of the jurisdiction from which it was originally collected. This is further detailed in Section 10 (International Data Transfers).
7. Data Retention and Deletion
We retain personal data for as long as necessary to fulfill the purposes for which we collected it, or as required by applicable law or contractual obligations.
● Platform Data (Our Customers): We generally keep Platform Data related to your Accord Customer account for up to 6 years from when our relationship with you ends (e.g., account closure), to comply with legal and tax obligations. If you, as an Accord Customer, request deletion of your account data, we will delete such personal data associated directly with your Accord account within 30 days, subject to any overriding legal or regulatory retention requirements.
● Discord Server Data (Processed on behalf of Customers):
○ Active Processing: We retain and process Discord Server Data from the servers you designate for as long as your Accord account is active and you instruct us to analyze those servers, or as necessary to provide the Service to you.
○ Data Subject Deletion Requests (Discord End-Users): If a Discord end-user requests the deletion of their specific Discord Server Data processed by Accord, we will process such requests as detailed in Section 8. Validated deletion requests will typically be actioned within 30 days from verification, unless a different timeframe is required by applicable law or the nature of the request necessitates a longer period, in which case we will inform the requestor.
○ Upon Accord Customer Account Termination: When an Accord
Customer account is terminated, or if a Customer requests the deletion of all data processed on their behalf, we will delete the specific datasets of Discord Server Data that were processed for that Customer. This data will be removed from our active systems within 30 days.
○ Anonymised and Aggregated Data for Service Improvement: Separately from the Customer-specific datasets mentioned above, we may derive data from the general operation of our Service, which includes elements originally sourced from public Discord channels. This data is transformed into a strictly anonymised and aggregated form, such that it can no longer be used to identify any individual Discord user or specific Accord Customer. This anonymised and aggregated dataset may be retained and used by us indefinitely for internal analytics, research, product development, and to improve the overall Accord Service. Such anonymised and aggregated data is not considered personal data and is outside the scope of data subject rights under GDPR and UK GDPR.
8. Your Data Protection Rights
We respect your data protection rights under GDPR and UK GDPR.
● Rights of Accord Customers (Regarding Platform Data):
○ As an Accord Customer, you have the right to access, rectify, erase, restrict processing of, and request portability of your Platform Data that we hold. You can also object to certain processing. Please email us at privacy(at)accord.gg to exercise these rights.
● Rights of Discord End-Users (Regarding their Discord Server Data Processed by Accord):
○ If you are a Discord user and believe Accord has processed your public messages from a Discord server (as part of the Discord Server Data processed on behalf of one of our Customers), you have rights concerning that data.
○ Access and Deletion Requests: You may request access to or deletion of your specific Discord Server Data held by Accord by contacting us at privacy(at)accord.gg.
○ Information Required for Requests: To help us locate your data and process your request efficiently, please include the following verifiable information in your request:
■ Your unique 18-digit Discord User ID.
■ The specific Discord Server ID(s) where your messages were posted.
■ The approximate date range(s) of the messages you are concerned about.
○ Without sufficient verifiable information, we may be unable to locate your specific data or may need to request further clarification. We will typically action validated requests within 30 days from verification, subject to applicable legal requirements or complexities of the request.
○ Requests via Accord Customers: If you are a member of a Discord community whose owner/administrator is an Accord Customer, you may also direct your data rights requests to them. Our Accord Customers can forward such verified requests from their community members to us at privacy(at) accord.gg, and we will action them in accordance with this policy.
○ Please note that Accord processes data from public channels as designated by our Customers. You also have tools and privacy settings directly within Discord to manage your data and its visibility on their platform.
● Exercising Your Rights: We will respond to all legitimate requests from both Accord Customers and Discord end-users in accordance with applicable data protection laws. We may need to verify your identity before processing your request. There is generally no fee for exercising these rights, though we reserve the right to charge a reasonable fee or refuse a request if it is manifestly unfounded or excessive, in accordance with applicable law.
9. Data Security
We implement appropriate technical and organisational measures to protect the security of your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures are designed to provide a level of security appropriate to the risk of processing your personal data. However, no internet-based site or electronic storage can be 100% secure, so we cannot guarantee absolute security.
10. International Data Transfers
Your personal data, including Platform Data and Discord Server Data, is primarily stored and processed on secure servers located within the United Kingdom (UK) and the European Economic Area (EEA).
However, in order to provide and support our Service effectively, it may be necessary for your personal data to be accessed by authorised Layer Labs Pty Ltd personnel (including employees and individual contractors) or our Sub-processors who are located in countries outside of the UK or EEA.
When we transfer personal data out of the UK or EEA, or allow access to it from such locations, we are committed to ensuring it is protected to the standards
required by applicable data protection laws, including the UK GDPR and the EU GDPR. We do this by implementing appropriate safeguards, which include:
● Adequacy Decisions: Transferring data to countries that have been deemed to provide an adequate level of data protection by the UK Government or the European Commission.
● Standard Contractual Clauses (SCCs) / International Data Transfer Agreements (IDTAs): For transfers to countries without an adequacy decision, we typically rely on: ○ The European Commission's Standard Contractual Clauses (EU SCCs), in conjunction with the UK Information Commissioner's Office (ICO) International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (UK Addendum) for transfers subject to UK GDPR; or
○ The UK ICO’s International Data Transfer Agreement (IDTA) for transfers subject to UK GDPR; or
○ Other contractual clauses recognised by relevant authorities as providing adequate safeguards.
● Transfer Risk Assessments (TRAs) / Transfer Impact Assessments (TIAs): Alongside these contractual measures, we conduct risk assessments for such transfers to evaluate the level of data protection in the recipient country. Based on these assessments, we implement supplementary technical, organisational, and contractual measures where necessary to ensure that your personal data receives a level of protection that is essentially equivalent to that provided within the UK and EEA.
By using our Service, you acknowledge that your personal data may be processed in and transferred to countries outside your country of residence, including those outside the UK/EEA, subject to these safeguards. Details of the specific Sub-processors we use and the locations from which data may be accessed can be provided upon request where appropriate and subject to confidentiality obligations.
11. Third-Party Links and Services (Discord)
Our Service interacts with Discord via its API. This Privacy Policy does not cover the privacy practices of Discord or any other third-party websites or services. We encourage you to review Discord's Privacy Policy (https://discord.com/privacy) and the privacy policies of any other third-party services you interact with.
12. Children's Privacy
Our Service is not intended for individuals under the age of 16 (or a higher age if stipulated by local law for consent to process personal data). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child without verifiable parental consent, we will take steps to delete such information from our systems.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website and indicate the "Effective Date" of the revision. If we make material changes, we will provide you with appropriate notice, such as by email or through a notification within the Service, before the changes take effect. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
14. Contact Us
If you have any questions about this Privacy Policy, your data protection rights, or our privacy practices, please contact us at: privacy(at)accord.gg
You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been infringed. For UK residents, this is the Information Commissioner's Office (ICO). For residents of EEA countries, this is the data protection authority in your country of residence.