Data Retention Policy
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Data Retention Policy
Version: 1.0
Last updated: October 2026
This policy explains which personal information Kluppy keeps about the students, teachers and administrators of the schools that use it, why, and when it is deleted. It is Kluppy's written data retention policy for personal information collected from children, as required by the Children's Online Privacy Protection Rule (16 CFR 312.10), and it applies to every school, wherever it is. It forms part of the Terms of Service for Schools, the Student Data Privacy Addendum and the UK Data Processing Addendum.
1. Who decides
The school decides which of its students and staff use Kluppy and can delete them at any time. Kluppy keeps their information only to provide the service to the school and deletes it on the schedule below. No information about a student is kept indefinitely.
Kluppy does not collect students' dates of birth, precise location, photographs, audio or video. The optional camera exercise runs only on the student's device.
2. What is collected, why, and for how long
| Information | Why it is collected | Why it is kept | When it is deleted |
|---|---|---|---|
| Account: name, username or email address, school and groups | To let the student sign in and the school organise its classes | While the school uses Kluppy, so that the student can practise | See section 3 |
| Learning record: typing activity, levels, progress, achievements, the letters the student finds difficult | To adapt the exercises and show progress to the student and the school | So that progress continues across the school year | See section 3 |
| Games and classroom: alias, avatar, game and league results, classroom races and class sessions, dictation attempts and work on tasks | To run the games and classroom activities | So that the student can see their results and history | See section 3. Game rooms and challenge invitations that are not saved as a result are deleted after 24 hours |
| Assessment module (where the school activates it): period summaries, achievement bands, teacher observations, copies of reports for families | To give the school evidence for its own assessment | The school keeps them as a record of what it was given | When the school asks, within 30 days, and at the end of the service with everything else |
| Texts written by teachers for the school library and dictation | To use them in the school's exercises | While the school uses them | When the school deletes them, and at the end of the service. Texts rejected by the safety check: 90 days |
| Messages inside the app (assigned tasks, announcements, achievements) | To tell the student about their activity | So that the student can read them | 90 days after they are sent |
| Error logs: account identifier, page, device and browser | To find and fix faults | Until the fault can be investigated | 30 days |
| Email delivery and notification records, reports of inappropriate texts, records of password resets made by the school | To deliver messages, review reported texts and help the school with access problems | To answer questions about a message or a reset | 12 months |
| Support tickets | To answer the school's questions | To follow up on a case | 2 years after the last activity of a closed ticket |
| Security and accountability records: administrative actions, access by Kluppy's staff, deletions | To detect and investigate incidents and to show that data was handled and deleted as promised | For the period in which a data protection claim can be brought | 3 years |
| One-time codes and confirmation links sent by email | To confirm a request | Only until they are used | 1 day for codes; 30 days for confirmation links |
3. Deletion of a student's account and learning record
- When the school deletes a student from its administration panel: at once, with the student's games, classroom records, dictation attempts and messages. The records of the assessment module stay with the school as evidence until the school asks for them to be deleted.
- When the school withdraws a student's licence: the account is blocked and deleted 180 days later, unless the school gives the licence back before then.
- When a trial ends or the school stops using Kluppy: access is blocked and the school's data is deleted 180 days later, so that a school that returns for the next school year keeps its students' progress. The school can ask for earlier deletion or for a copy of its data at any time.
- An account the student already had before joining the school (for example, one their family pays for) is not deleted with the school's data: it returns to its holder, and the school stops seeing it.
4. How deletion is done
Deletion runs automatically every day. A record that cannot be deleted in one run is retried the next day. Deleted information can remain in Kluppy's encrypted backups for a short time: up to 7 days in point-in-time recovery and up to 35 days in daily backups, which are used only to recover from an incident. If a backup is restored, anything that had already been deleted is deleted again.
Invoices and billing records are kept for the period required by Spanish tax law. They concern the school and its payers, not students.
5. Requests and review
A school, or a parent through the school, can ask for information to be deleted earlier by writing to dpo@kluppy.com. Kluppy reviews this policy at least once a year and whenever it adds a feature that collects new information.
Data Retention Policy · KLUPPY, S.L. · Version 1.0 · October 2026