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Data Retention Schedule

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Version: 1.0.0 | Effective Date: 2025-01-01 | Governing Law: EU GDPR (Lithuania) | Applies To: All users, globally | Contact: legal@motiw8.com

1. Introduction

This Data Retention Schedule describes:

Retention periods apply to:

When a retention period expires, the data is:


2. Definitions


3. Summary Table — Retention Periods

Data Category Retention Rationale
Media (photos) 180 days after challenge ends Verification integrity, appeals
Media (videos) 90 days after challenge ends Storage limits, liveness only needed short-term
Timestamp screenshots 180 days Date validation for challenges
Face vectors Until account deletion or consent withdrawal Required for future comparisons
Derived verification data 3 years Fraud analytics, dispute resolution
Fraud flags & risk scoring 3 years Anti-cheat compliance
Challenge results Permanent Historical accuracy
Account profile data Until deletion Needed for service delivery
Health data (steps, weight) Until deletion User fitness history
Challenge participation records Permanent Required for historical rankings
Payout records 7 years EU/US tax and accounting laws
Transaction logs 7 years Stripe + EU AML law
KYC documents 7 years AML regulations
Audit logs 7 years Security and compliance
Backups 30–90 days Disaster recovery only
Consent records 7 years Legal proof of consent
Analytics logs 2–5 years (Firebase) Industry standard

4. Detailed Retention by Category

4.1 Media Evidence Retention

4.1.1 Photos (scale, full-body, timestamp)

After 180 days:

4.1.2 Videos

After 90 days:

4.1.3 Timestamp Screenshots

4.2 Derived Data & AI Outputs

Derived data includes:

After 3 years:

4.3 Face Vectors & Biometrics

Face vectors (numerical biometrics) created via AWS Rekognition CompareFaces:

Retention: until:

Upon deletion request:

4.4 Health Data (Weight, Steps, Body Fat)

Stored in:

4.5 Challenge Participation Records

Challenge data (rank, score, final result, history):

Why permanent?

Users may request anonymization, but records remain.

4.6 Financial Data

Includes:

Cannot be deleted early.

If a user requests account deletion:

4.7 KYC/AML Data (Future Stripe Identity)

Includes:

Deletion: Motiw8 can request Stripe to erase earlier than required only if legally allowed.

4.8 Audit Logs

Logs may contain:

4.9 User Consents

Stored in user_consents:

4.10 Backups

Supabase backups (encrypted):

Deletion from production takes effect once backups expire.


5. Interaction with GDPR Rights

When users request:

5.1 Right to Access

We provide:

5.2 Right to Erasure

Not applicable to:

These are anonymized, not deleted.

5.3 Right to Rectification

Users may correct:

5.4 Right to Object

Users may object to:

Cannot object to:

5.5 Right to Portability

We export:

In a machine-readable format.


6. Exceptions & Special Cases

6.1 Fraud Flags

Kept 3 years even after account deletion.

Reason: prevent repeated sign-ups using new accounts.

6.2 Legal Requests

We may retain data beyond schedule when:

6.3 Suspicious or Penalized Accounts

If an account is under investigation:


7. How Data Is Deleted

Deletion is multi-step:

  1. Mark for deletion
  2. Remove from Supabase tables
  3. Delete media from storage buckets
  4. Delete AI-derived information
  5. Scrub identifiers from challenge records
  6. Anonymize financial records
  7. Purge logs after 90 days
  8. Expire from backups after 30–90 days

Users receive a confirmation email when deletion is complete.


8. Internal Retention Governance

The retention schedule is reviewed:

All updates receive a version bump (e.g., 1.0.0 → 1.1.0).