headrep
Draft under legal review. Highlighted [brackets] are still being decided. Questions: privacy@headrep.com
Data Retention Policy (DRAFT)
HeadRep by [Company Legal Name] · Effective [date] · Draft for counsel review, not legal advice.
We keep personal information only as long as we need it for the purpose we collected it for, then delete it. For children 10 to 12, the FTC's amended COPPA Rule (16 CFR 312.10) requires this written policy, including why we collect each kind of information, why we keep it, and when we delete it. We never keep children's information indefinitely.
On our servers
| Data | Why we collect it | Why we keep it | When we delete it |
|---|---|---|---|
| Parent consent request (parent name and email, child's first name), before the signed form arrives | To give the parent notice and get consent | Only until the form arrives | 14 days after the request if no signed form is verified (automatic, daily) |
| Parent consent record (choices, notice version, how and when verified) | To honor the parent's choices and show consent was given | While the child's account is open | With the child's account (automatic) |
| Account and profile (account ID, first name, age range, sport, level, focus areas, cue word, settings) | To run the account and personalize training | While the account is open | When the account is deleted, or consent is withdrawn (immediately, automatic) |
| Training data (finished exercises with time, duration and effort; check-in days; goals and check-offs; weekly points) | Points, streaks, progress, sync to a new phone, team board | While the account is open | With the account |
| Team membership | Team license and team board | While the athlete is on the team | When they leave the team or the account is deleted |
| Consent history (points & streaks on/off) | To show consent for engagement features (Colorado minors' rules) | While the account is open | With the account |
| Server logs (IP address, device information) kept by our hosting providers | Security and keeping the service working | [Per provider defaults: confirm Supabase log retention for our plan] | Automatically by the provider |
| Backups | Recovery from failures | [Per Supabase plan: confirm] | Deleted data drops out of backups within [30] days |
Inactive accounts
- Ages 10 to 12: after [12] months with no activity, we email the parent; if they don't reply within 30 days, we delete the account and everything in it.
- Under 10: we don't collect anything; if we learn we hold data from a child under 10, we delete it within 30 days.
- 13 and older: after [24] months with no activity, we notify the user in the app or by email (if they gave one) and then delete it.
Outside our servers
| Data | Where | When it's deleted |
|---|---|---|
| Signed parent consent forms | privacy@headrep.com, then a restricted folder | [Counsel to set] after the child's account closes (to show consent was obtained), then destroyed |
| Support emails | Support inbox | [24] months after the conversation ends, or sooner on request |
| Journals, debriefs, check-in answers, recordings, Apple Health data, calendar, playlist, trusted adult | The user's phone only | When the user deletes them, signs out, deletes the account or removes the app. We never have a copy |
How deletion happens
- Automatically: unfinished consent requests are deleted daily once they pass 14 days, and deleting an account in the app (Profile → Delete my account, or Parent controls → Withdraw consent) deletes its server data immediately.
- By request: email privacy@headrep.com (or tell your coach) and we delete within [10 business days], after confirming you're the account holder or the child's parent.
- Inactive accounts: checked monthly, with notice before deletion as described above.
Review
Reviewed with the Information Security Program each year, and whenever we start collecting a new kind of data.