Data Retention Policy

Why This Document Exists

Step 2 of the FTC's Six-Step COPPA Compliance Plan requires each product's privacy policy to state “the business need to retain personal information, and a timeframe for deletion. You cannot retain personal information collected from a child indefinitely.” Step 6 reinforces: “Hold on to personal information only as long as is reasonably necessary.”

This document is the single source of truth for retention windows across the Matside portfolio. Each product's privacy policy mirrors the window for that product.

Per-Product Retention Windows

WrestleFA

Data class Active retention Deletion trigger Grace
Parent accountWhile account activeUser-initiated OR 24 months of inactivity30 days
Wrestler profile (under-13)Linked to parent accountSame as parent account30 days
Confirmed placementsAnonymized + retained for TD historyAnonymization on parent-account deletionn/a
Consent recordsWhile wrestler profile existsDeleted alongside wrestler profile30 days
Square payment records~7 years per tax lawLegal-hold exceptionn/a
Audit log entries24 months rollingAutomatic at 24 monthsn/a

Rationale for the 24-month inactivity window: WrestleFA is a free-agent marketplace tied to a wrestling season cadence. A parent who hasn't logged in or updated a profile across two full seasons is functionally inactive; the window is conservative enough that families taking a season off don't lose data immediately. A notification email is sent at 22 months of inactivity with a 60-day grace before deletion.

COPPA implication: WrestleFA is the only product in COPPA scope. A 24-month inactive timer plus notification plus grace is materially stronger than “indefinite retention” and satisfies the COPPA Six-Step Steps 2 and 6 explicitly.

MatRecruit

Data class Active retention Deletion trigger
Athlete accountWhile subscription active OR logged in within 18 monthsUser-initiated OR 18 months past stated class year
Profile dataSame as accountDeleted with account
Tracker data (private)Same as account; subscription cancellation does NOT deleteDeleted with account
Profile photosSame as profileImmediate on user action
Audit log entries24 months rollingAutomatic
Sentry error reports90 days (per Sentry)Per provider
Stripe payment records~7 years per tax lawLegal-hold exception

Rationale for the 18-months-past-class-year window: A wrestler who graduates in class year X uses MatRecruit through the recruiting cycle ending ~spring of year X. Eighteen months past graduation covers the late-recruiting JUCO/transfer window. After that, the profile has functionally aged out of the recruiting market. Notification email sent at 16 months past class year with a 60-day grace.

MatPass

Critical FERPA dependency: When the wrestling program using MatPass is school-affiliated (high-school, college, or other educational institution), athlete compliance records are likely education records under FERPA, which has its own retention requirements that supersede MatPass's default. MatPass acts as a data processor; the wrestling program is the data controller. The organization owner is responsible for configuring MatPass to align with the program's institutional retention obligations.

Data class Retention
User account (coach, admin, parent)24 months of inactivity or user-initiated deletion
Organization recordsWhile org is active
Athlete recordsPer the wrestling program's institutional retention policy
Compliance documentsPer institutional + governing-body requirements
Audit log entries24 months rolling (org owners may extend)

Default for non-FERPA programs (club programs, private programs): athlete records retained for 24 months past the end of the season they were created in. Notification to the org admin at 22 months with a 60-day grace.

MatTime

MatTime uses a 7-year anonymization sweep, materially stronger than the cross-product default. This window aligns with typical state-level coaching-credential retention requirements and provides a clean audit trail for any post-booking dispute. The anonymization sweep is already implemented at the scheduled-cron layer.

Data class Retention
Coach account + profile7 years of inactivity or user-initiated
Parent account + bookings7 years of inactivity or user-initiated
Booking confirmation records7 years past booking date (automatic anonymization)
USAW credential submissions7 years past expiration
Audit log entries7 years rolling

SignupSignin

Data class Retention
User account (volunteer or admin)12 months past last login or user-initiated
Event signup recordsAt the organization's discretion; recommend ≤12 months past event
Audit / activity records12 months rolling
Mobile push notification tokensRemoved on logout or account deletion

Rationale for the 12-month inactivity window: SignupSignin is event-driven; volunteers typically sign up around a tournament cadence. 12 months covers a full off-season plus the next year's early-season cadence. Past that, the user is functionally inactive. Notification email sent at 10 months of inactivity with a 60-day grace.

Cross-Product Applicable Items

Audit Log Retention

All products: audit-log entries retained for 24 months rolling (MatTime is 7 years per its stronger policy). Standardized to support security investigations and dispute resolution without indefinite storage.

Service-Provider Logs

Per the respective provider's retention schedule:

Legal-Hold Exception

Any retention window above is superseded when records are subject to:

Legal-hold records are retained until the hold is released.

Notification and Grace Pattern

For every product where inactivity triggers deletion, the following pattern applies:

  1. Inactivity warning email sent at (retention window) minus 2 months, to the user's account email, with: explanation that the account is approaching the deletion timer; link to log in and reset the timer; link to export data before deletion; link to confirm immediate deletion if preferred.
  2. 60-day grace period between the warning email and final deletion.
  3. Final deletion email sent at the deletion moment confirming the deletion occurred.

This pattern satisfies the COPPA spirit (“hold on to personal information only as long as is reasonably necessary”) and provides users with meaningful warning and an opportunity to preserve their data.

Changes to This Policy

The Sept 1, 2026 attorney review will redline retention windows where appropriate; the change happens here first, then per-product privacy policies update to match. After the Oct 1, 2026 launch, this document is reviewed quarterly alongside the per-product COPPA compliance checklists.


Questions about this Data Retention Policy? Contact support@matside.org.