Data Retention Policy and Schedule | Flowbase and SportsFlow

1. Purpose and Scope

This policy sets how long CurioCore keeps personal information in Flowbase and SportsFlow, what starts each period, and how information is disposed of. It covers production systems, backups, logs and service providers acting for us. It applies data minimization and storage limitation under the laws described in our Privacy Policy.

2. Definitions

Account Closure: the date an account is deleted by the user or guardian, closed by us, or closed for inactivity under Section 5.4. Flowbase and SportsFlow accounts close separately. Closing one does not close a linked account unless the user chooses.
Deletion: irreversible removal from production systems, followed by expiry from backups under Section 5.3.
De-identification: processing so data cannot reasonably be linked to a person, with a public commitment and contractual controls against re-identification.
Legal Hold: a suspension of deletion under Section 6.

3. Principles

3.1 We keep personal information only as long as needed for the purpose it was collected for, or as the law requires.

3.2 Unless the schedule says otherwise, personal information is deleted within 90 days after Account Closure.

3.3 Users can delete individual items, such as a message, a result they submitted, a FlowCoach conversation or a device connection, at any time. Deleted items leave production within 30 days.

3.4 Where a longer period is required by law or for legal claims, it applies only to the minimum data needed.

4. Schedule

Ref	Record	Retention	Trigger	Disposition	Reason
A‑01	Account and profile	Life of account + 90 days	Account Closure	Deletion	Service delivery
A‑02	Guardian approval record	3 years	Minor's Account Closure	Deletion	Proof of consent
T‑01	Training logs and personal erg results	Life of account + 90 days	Account Closure	Deletion	Service delivery
T‑02	Ranking and league entries	Life of account + 90 days	Account Closure	Deletion or de-identification	Ranking integrity
T‑03	Race results published by organizers or clubs	Indefinite, as the historical record	Publication	Retained. Display name adjustable; removed on valid legal request	Public sporting record
T‑04	Race schedules	2 years	Event date	Deletion	Service delivery
W‑01	Wellbeing raw answers, adult	Life of account + 90 days	Account Closure	Deletion	Service delivery
W‑02	Wellbeing raw answers, under 18	Until age 18, or 30 days after Account Closure, whichever first	18th birthday or Account Closure	Deletion	Minimization for minors
W‑03	Scores, trends, readiness, load tolerance	Life of account + 90 days	Account Closure	Deletion	Service delivery
W‑04	Wearable data	Life of connection or account + 90 days	Disconnection or Account Closure	Deletion	Service delivery
W‑05	Sharing settings and pod membership	Life of account + 90 days	Account Closure	Deletion	Service delivery
W‑06	De-identified questionnaire data	While needed for reliability work	De-identification	Deletion when no longer needed	Questionnaire validation
C‑01	Messages and attachments	Life of sender's account + 90 days	Sender's Account Closure	Deletion	Service delivery
C‑02	FlowCoach conversations	Life of account + 90 days, or until deleted	Account Closure	Deletion	Service delivery
C‑03	AI provider request data	Not kept by us. Provider: as limited by contract	Request	Provider deletion	Contract
C‑04	Reels and uploaded media	Life of account + 90 days, or until deleted	Account Closure	Deletion	Service delivery
C‑05	Course progress and certificates	Life of account + 90 days	Account Closure	Deletion; public page removed at closure	Service delivery
K‑01	Boat reservations and event sign-ups	2 years	Reservation or event date	Deletion	Club operations
K‑02	Boat damage and safety reports	3 years	Report date	Deletion	Club safety, claims
P‑01	Subscription and purchase records	7 years	Transaction	Deletion	Tax and accounting law
P‑02	Donation and fundraising records	7 years	Transaction	Deletion	Tax, charitable solicitation law
S‑01	Safeguarding records (threshold events)	Club policy. Default: until athlete is 25 or 7 years, whichever is later	Event	Deletion by club; our copy deleted 90 days after export to club	Duty of care
S‑02	Abuse and misconduct reports	Until the subject is 25 or 7 years, whichever is later	Report	Deletion	Safeguarding, legal claims
S‑03	Content moderation decisions and appeals	2 years	Decision	Deletion	Legal compliance
L‑01	Privacy request records	24 months	Request closure	Deletion	Regulatory record-keeping
L‑02	Security and access logs	12 months	Log creation	Deletion	Security investigations
L‑03	Product analytics	24 months	Event	Deletion	Service improvement
B‑01	Backups	35 days rolling	Backup creation	Overwrite	Disaster recovery

5. Disposition

5.1 Method. Automated jobs remove records from databases and storage. Hosting providers dispose of media under NIST SP 800-88 or equivalent.

5.2 Service providers. Providers delete our data on instruction or at contract end. When a user deletes consumer health data, we instruct providers to delete it too.

5.3 Backups. Deleted data expires from backups within 35 days. If a backup is restored, deletion jobs run again before the system returns to service.

5.4 Inactive accounts. Accounts with no sign-in for 24 months and no active subscription are closed after two email notices at least 30 days apart.

5.5 Verification. Deletion jobs are logged without personal data and reviewed quarterly.

6. Legal Holds

When we reasonably expect litigation, an investigation or a regulatory inquiry, the privacy officer may suspend deletion of relevant records. Holds are documented, limited to what is relevant, and lifted when no longer needed.

7. Roles

Role	Responsibility
Privacy officer	Owns this policy; approves exceptions and legal holds
Engineering	Builds and monitors deletion jobs; confirms each release matches this schedule
Clubs	Keep and dispose of safeguarding, reservation and damage records they export, under their own policies

8. Review

Reviewed at least annually and whenever a new data type, feature or legal requirement is introduced.