1. Key Principles
- Purpose limitation – We keep personal data only for as long as necessary for the specific purpose it was collected.
- Legal obligations – Some data must be retained for statutory reasons (e.g., tax, accounting, or child protection laws).
- Customer instructions – For organization-provisioned accounts, we follow the controller’s instructions for retention and deletion under our DPA.
- Secure deletion – When data is no longer needed, it is securely deleted or anonymized.
2. Standard Retention Periods
| Data Category | Examples | Standard Retention | Deletion / Anonymization Method |
|---|---|---|---|
| Account Data (Public Users) | Name, email, profile info | Kept until account deletion request or 24 months of inactivity | Secure database deletion; backups overwritten within 35 days |
| Account Data (Org-Provisioned) | Name, username, org affiliation | Retained until controller instructs deletion or contract ends | Deleted per controller request; backups overwritten within 35 days |
| Course & Activity Data | Assignments, grades, attendance | Retained while account is active; deleted within 12 months after deletion | Secure deletion from LMS & storage systems |
| Tournament Data | Player IDs, match stats, leaderboards | Kept for active season + 12 months | Purged from tournament platform; anonymized for analytics |
| Payment & Billing Data | Billing name, address, transaction history | 7 years (tax & accounting compliance) | Secure deletion from billing system |
| Support & Communication Records | Emails, chat transcripts, support tickets | 24 months after case closure | Secure deletion from ticketing platform |
| Security Logs | Login history, IP addresses, device info | 12 months (security & fraud prevention) | Automatic purge from log management system |
| Marketing Data | Newsletter sign-ups, marketing preferences | Until withdrawal of consent or inactivity for 24 months | Removed from CRM/email platform |
3. Backup Data
- Backups are retained for 35 days unless otherwise required by law or contract.
- Deleted data may remain in backups until the backup cycle expires. Backups are encrypted and access is restricted.
4. Deletion Process
- Trigger – Retention period expires or a valid deletion request is received.
- Verification – Confirm identity of requester (public users) or confirm request with controller (org-provisioned).
- Deletion – Remove data from active systems.
- Backup purge – Data naturally removed as backup cycles expire.
- Confirmation – For DSR requests, confirmation sent to requester or controller.
5. Exceptions
Some data may be retained beyond standard periods:- To comply with legal obligations.
- To resolve disputes or enforce agreements.
- For ongoing investigations into misuse or violations.