Data Retention & Deletion Policy
Effective Date: [EFFECTIVE DATE] Last Updated: [LAST UPDATED] Version: 2.0
1. Retention Principles
KidStarter retains Personal Data only as long as necessary for the purposes for which it was collected, including:
- providing and improving the Service;
- preventing fraud and abuse;
- meeting legal, tax, and accounting obligations;
- resolving disputes and enforcing agreements;
- complying with regulatory requirements.
We apply the principle of data minimization — retaining only what is needed, for as long as needed, and no longer.
2. Retention Schedule
| Data Category | Retention Period | Basis |
|---|---|---|
| Account information (name, email, role) | Duration of active account + 3 years after account closure | Contract performance; fraud prevention; legal claims |
| Donation records (amount, date, receipt, campaign) | 7 years from date of transaction | Financial/tax compliance (IRS, HMRC, CRA, EU Member State requirements) |
| Payment processor tokens | Duration of active account; deleted on account closure | Contract performance |
| Verification evidence (authorization letters, consent forms, IDs) | Duration of Campaign + 3 years | Fraud prevention; audit; legal claims |
| Government-issued IDs (submitted for verification) | Deleted within 30 days of verification completion (unless legally required to retain) | Data minimization |
| Campaign content (text, images, updates) | Duration of active Campaign; archived on completion; deleted on verified request where legally permitted | Contract performance; fraud prevention |
| Student data (private) | Deleted or anonymized within 12 months of Campaign completion or disbursement | Data minimization; child protection |
| Images of minors | Duration of active Campaign; deleted within 30 days of Campaign completion or verified guardian request | Data minimization; child protection |
| Server and security logs | Up to 24 months | Security; fraud investigation; regulatory compliance |
| Moderation and audit logs | Up to 36 months | Accountability; regulatory compliance; dispute resolution |
| Analytics data | Aggregated/anonymized within 24 months | Service improvement |
| Marketing consent records | Duration of consent + 3 years | Evidence of consent; compliance |
| Support communications | 3 years after resolution | Quality assurance; dispute resolution |
| Cookie data | Per cookie-specific duration (see Cookie Policy) | As stated in Cookie Policy |
| Fraud investigation records | 7 years from conclusion of investigation | Legal compliance; fraud prevention |
| Legal hold data | Duration of legal hold | Legal obligation |
[Adjust retention periods based on your jurisdiction-specific legal advice before publication.]
3. Deletion and Anonymization
3.1 Deletion
When retention periods expire and no legal hold, dispute, or regulatory obligation requires further retention, Personal Data is permanently deleted from all active systems and backups within a reasonable timeframe (typically within 90 days of the retention period expiring, accounting for backup rotation cycles).
3.2 Anonymization
Where deletion is not feasible or where data has analytical value, KidStarter may irreversibly anonymize data so that it can no longer be linked to any individual. Anonymized data is no longer Personal Data and may be retained indefinitely for statistical and analytical purposes.
3.3 Anonymization Standards
We apply anonymization techniques sufficient to meet the standard under applicable law (including GDPR Recital 26, UK ICO anonymization guidance, and CCPA/CPRA definitions), ensuring that re-identification is not reasonably possible.
4. Deletion Requests
4.1. You may request deletion of your Personal Data by contacting [PRIVACY EMAIL].
4.2. We will process your request in accordance with applicable law (GDPR, UK GDPR, CCPA/CPRA, PIPEDA).
4.3. We may retain certain data where we have a legal obligation, legitimate interest, or contractual right to do so, including:
- donation records required for financial/tax compliance;
- fraud investigation records;
- data subject to a legal hold;
- anonymized or aggregated data;
- data necessary to enforce our Terms or resolve pending disputes.
4.4. We will inform you if we cannot fully comply with a deletion request and explain the reasons.
5. Legal Holds
5.1. A legal hold is a directive to preserve data that may be relevant to pending or reasonably anticipated litigation, regulatory investigation, audit, or other legal proceeding.
5.2. When a legal hold is issued, normal retention schedules are suspended for the affected data. Data under legal hold is preserved in its current state until the hold is lifted.
5.3. Legal holds are managed by KidStarter's legal team and are documented with: the scope of data affected, the reason, the date of issuance, and the date of release.
5.4. Data under legal hold is subject to the same access controls and security measures as other data.
6. Backup and Archival
6.1. KidStarter maintains encrypted backups for disaster recovery purposes.
6.2. Deleted data may persist in backup systems for up to 90 days beyond the deletion date due to backup rotation schedules.
6.3. We do not actively process data from backup systems except for disaster recovery purposes.
7. Third-Party Data
7.1. Where Personal Data has been shared with third-party processors (e.g., payment processors, cloud providers), we will use reasonable efforts to ensure that those processors delete or return data in accordance with their data processing agreements and applicable law.
8. Policy Review
This Policy is reviewed at least annually and updated to reflect changes in law, regulation, and business practices.
9. Contact
Deletion Requests: [PRIVACY EMAIL] Privacy Inquiries: [PRIVACY EMAIL] General Support: [SUPPORT EMAIL]