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BrainSeeds · Data Governance

Data Retention & Deletion Policy

Keeping What Matters. Protecting What Matters More.

BrainSeeds believes personal information should be retained for a meaningful purpose — not simply because technology makes long-term storage possible.

Effective Date
[Insert Date]
Last Updated
[Insert Date]
Purposeful
Data Lifecycle
Retain
with purpose
Protect
with care
Review
with discipline
Delete
responsibly
Assess Understand
Develop Measure
Reassess Grow
Review Retention
Protect Information
Delete When appropriate
01–02 · Retention Foundations

Retain with purpose. Know what is being retained.

BrainSeeds approaches retention through purpose, necessity, security, transparency and responsible deletion — while recognising that different information may require different retention periods.

Our Data Retention Philosophy

Purpose

Information should have a legitimate reason to be retained.

Necessity

We seek to retain information only for as long as reasonably necessary.

Security

Information retained by BrainSeeds should remain subject to appropriate safeguards.

Transparency

Users should understand why information may be retained.

Deletion

When information is no longer required and there is no legitimate reason to retain it, appropriate deletion or anonymisation may be undertaken.

Retain with purpose. Review with discipline. Delete responsibly.

What Is Data Retention?

Data retention refers to the period during which BrainSeeds keeps personal information in its systems, records or authorised service environments.

Account information
Registration information
Contact information
Assessment responses
Assessment scores
Assessment reports
Learning profiles
Development plans
Career interests
Programme participation
Training records
Progress information
Reassessment results
Payment & transaction records
Customer-support communications
Consent records
Security records
Technical logs
Different types of information may require different retention periods.
A simple principle sits underneath the policy.

BrainSeeds seeks to avoid keeping personal information without a meaningful purpose, while recognising that retention requirements can differ according to the type and purpose of the information.

03–04 · Purpose & Development

Retention should support the journey — not become the journey.

BrainSeeds may retain personal information when there is a legitimate purpose, including service delivery, assessment history, reassessment, personalised learning, support, financial requirements, security and applicable legal requirements.

03

Why Do We Retain Information?

BrainSeeds may retain personal information for legitimate purposes connected with delivering and maintaining its services.

Providing Services

Continue providing assessments, learning programmes and personalised development services.

Assessment History

Previous results may, where appropriate, help users understand development over time.

Reassessment

Historical information may support meaningful comparison between baseline and subsequent assessments.

Personalised Learning

Previous assessment and development information may support continuity in a personalised learning pathway.

Customer Support

Information may be retained to respond to enquiries, resolve issues and maintain service records.

Financial & Accounting

Certain transaction and payment records may need to be retained for legal, tax, accounting or audit requirements.

Security

Certain technical and security records may need to be retained for a reasonable period for incident investigation, fraud prevention and system protection.

Legal & Regulatory

Certain information may need to be retained where required or permitted by applicable law.

04

Assessment Information & Long-Term Development

Assessment information can have developmental value beyond the date on which an assessment is completed.

01
Baseline
Assessment
02
Personalised
Development
03
Practice &
Intervention
04
Progress
Measurement
05
Reassessment
Why historical information may matter Historical information may help demonstrate changes over time and support comparison between baseline and later assessments.
Retention still has boundaries Where retention is necessary for this purpose, BrainSeeds may retain relevant assessment information for an appropriate period, subject to applicable law, programme terms and individual rights.
Useful does not mean indefinite The fact that information may be useful does not mean it should be retained indefinitely. Retention should remain purpose-driven.
Assess → Develop → Measure → Reassess → Grow BrainSeeds seeks to balance developmental continuity with responsible retention rather than keeping assessment information indefinitely.
05–06 · Retention Categories

Different information. Different retention logic.

There is no single retention period that necessarily applies to every category of information. The appropriate approach depends on the information, its purpose and the applicable requirements.

Information Category
Potential Purpose
Retention Approach
Account information
Maintaining user account
While account/service is active + appropriate period
Assessment responses
Assessment processing
Based on assessment/service requirements
Assessment reports
User access & development continuity
Appropriate programme period
Development records
Personalised learning
While reasonably necessary
Reassessment history
Measuring development
Appropriate developmental period
Payment records
Accounting / tax obligations
Period required by applicable law
Customer communications
Support & records
Appropriate operational period
Security logs
Security & incident management
Appropriate security period
Consent records
Demonstrating lawful processing
Appropriate legal / operational period
Marketing preferences
Managing communications
Until preference changes + appropriate record period
Anonymised data
Research / analytics / improvement
May be retained where no longer reasonably identifiable
Illustrative framework: These categories are illustrative. Actual retention periods may depend on the service, technology, contractual arrangement and applicable law.
06

Children’s & Student Data

BrainSeeds recognises the importance of responsible retention when services involve children and students.

Additional care BrainSeeds seeks to avoid retaining children's personal information longer than reasonably necessary.
Related policy For more information, refer to the BrainSeeds Children & Student Data Protection Policy.
06A

Purposes for Children’s Information

Children's personal information may be retained where reasonably necessary for the following purposes and subject to applicable law.

  • Assessment services
  • Educational programmes
  • Personalised learning
  • Development tracking
  • Reassessment
  • Institutional requirements
  • Legal obligations
Deletion or anonymisation Where children's information is no longer necessary and there is no legitimate reason to retain it, appropriate deletion or anonymisation may be considered, subject to applicable law.
Rights • Deletion • Responsible Retention

When Data No Longer Needs to Stay

BrainSeeds approaches deletion as a responsible process: understand the request, verify the appropriate authority, review legitimate retention requirements, and delete, anonymise, or restrict information where appropriate.

Parent & Guardian Requests

Parents or legal guardians may, where applicable, request information concerning personal data relating to their child.

Access to relevant information
Correction
Deletion
Withdrawal of consent where applicable
Information about processing
Other applicable privacy rights
BrainSeeds may need to verify identity and parental or legal authority before processing such requests.

When Will We Delete Information?

BrainSeeds may delete or anonymise personal information when the original purpose has been fulfilled or continued retention is no longer reasonably required.

The original purpose for collecting the information has been fulfilled.
The service relationship has ended and retention is no longer necessary.
The applicable retention period has expired.
The information is no longer reasonably required.
A valid deletion request is received and no lawful retention exception applies.
Consent has been withdrawn where deletion is appropriate.
Applicable law requires deletion.
Deletion remains subject to legal, contractual, security and operational requirements.

When May We Retain Information Despite a Deletion Request?

There may be circumstances in which BrainSeeds is required or permitted to retain information even when a user requests deletion.

Compliance with legal obligations
Tax or accounting requirements
Regulatory requirements
Legal claims or disputes
Fraud prevention
Security investigations
Protection of legal rights
Enforcement of contractual obligations
Other circumstances permitted by applicable law
Where appropriate, information that must be retained may be restricted from further use except for the purpose requiring retention.

Deletion Does Not Always Mean Immediate Physical Erasure

When a deletion request is accepted, deletion may occur through different technical processes depending on where the information is stored.

Information may exist across different operational, recovery and service environments. Some backup systems may not support immediate individual deletion.

Where this occurs, BrainSeeds may ensure that information is appropriately isolated, restricted or excluded from ordinary operational use and deleted during the applicable backup lifecycle, subject to technical and legal requirements.
Primary databases
Backup systems
Security logs
Disaster-recovery systems
Archived records
Third-party service environments
Responsible deletion means protecting the individual while respecting legitimate legal, contractual, security and operational requirements.
Secure Disposal • Anonymisation • Technology

Remove the Identity. Preserve the Purpose.

When information no longer needs to remain identifiable, BrainSeeds may use appropriate deletion, de-identification or anonymisation processes, depending on the nature and location of the information.

Secure Deletion

When information is scheduled for deletion, BrainSeeds seeks to use appropriate methods designed to prevent unauthorised recovery or continued use.

Secure deletion
Database deletion
Account removal
De-identification
Anonymisation
Secure destruction
Access revocation
Removal from active systems
The method used will depend on the nature and location of the information.

Anonymisation

In some circumstances, BrainSeeds may convert personal information into information that is no longer reasonably capable of identifying an individual.

Removing identifying information
Aggregating information
De-identifying records
Applying statistical techniques
Separating identifying information from analytical information
Once information has been effectively anonymised, it may potentially be retained for legitimate purposes such as service improvement, statistical analysis, research, product development, quality analysis and educational insights. Anonymised information is not intended to identify an individual.

Retention of Aggregated Information

BrainSeeds may retain aggregated or anonymised information for longer periods where it no longer reasonably identifies individual users.

General assessment trends
Learning patterns
Programme effectiveness
Development outcomes
Platform performance
Service quality
Where information is genuinely anonymised, it is not used to recreate an identifiable individual profile.

Data Retention & AI Systems

Where personal information is processed through AI-enabled systems, retention should be governed by the purpose for which the information is processed and the applicable contractual and legal requirements.

BrainSeeds seeks to avoid retaining personal information in AI or analytics environments indefinitely without a legitimate purpose.
Data retention
Data deletion
Data processing
Security
Access
Data isolation

Data Retention & Third-Party Providers

BrainSeeds may use third-party service providers to support different aspects of its services and technology environment.

Cloud hosting
Data storage
Assessment technology
Analytics
Communications
Payment processing
Security
Customer support
AI and technology services
Where such providers process information on behalf of BrainSeeds, we seek to establish appropriate requirements concerning data protection and, where relevant, retention, deletion, security, access, confidentiality and data return. Third-party providers may have their own technical deletion cycles.
BrainSeeds' approach recognises that responsible data disposal depends on purpose, technology, storage location and applicable requirements.
Accounts • Inactivity • Programmes

What Happens After the Service Changes?

Account closure, inactivity and paid programme completion can each trigger a review of associated information. The outcome depends on the purpose of the data and the applicable retention requirements.

Account Closure

If you close your BrainSeeds account, we may begin the process of reviewing the information associated with that account.

01 Some information may be deleted
02 Some information may be anonymised
03 Some information may be retained for legitimate purposes
04 Certain legal or financial records may need to be retained
05 Backup copies may remain temporarily subject to backup retention cycles
Closing an account does not necessarily mean that every record can be immediately removed from every system.

Inactive Accounts

BrainSeeds may periodically review inactive accounts. Where an account remains inactive for an extended period, different actions may be considered.

Contact the user
Provide an opportunity to reactivate the account
Restrict access
Delete certain information
Anonymise information
Close the account
Treatment of inactive accounts may depend on the service and applicable retention requirements. Where a specific service has a defined inactivity period, that period will be communicated in the relevant service terms where appropriate.

Data Retention for Paid Programmes

Paid assessment, training and personalised learning programmes may require certain information to be retained during the programme and for an appropriate period afterward.

Registration information
Payment records
Assessment results
Participation records
Progress information
Completion records
Certificates
Support communications
The exact retention period may depend on the nature of the programme and applicable legal or contractual requirements.
Retention is reviewed in context rather than treated as a single universal period for every type of information.
Requests • Verification • Review

A Structured Path From Request to Resolution

Deletion requests are handled through a defined process that considers identity, authority, the information involved, legitimate retention requirements and the appropriate outcome.

What Happens After a Deletion Request?

Once a valid deletion request is received, BrainSeeds may work through the following sequence.

01
Verify
Verify the identity and authority of the requester where necessary.
02
Identify
Determine what information is covered by the request.
03
Review
Determine whether a legal, contractual or operational reason requires continued retention.
04
Delete or Restrict
Delete, anonymise or restrict the relevant information where appropriate.
05
Confirm
Provide appropriate confirmation or explanation in accordance with applicable requirements.

Identity Verification

Because BrainSeeds may hold confidential assessment information, we may need to verify the identity of a person requesting deletion.

A child's information
Assessment reports
Personal development information
Another person's account
Verification is intended to protect users from unauthorised deletion or disclosure of information.

Deletion of a Child's Information

Requests concerning a child's information may require additional verification.

Identity of the requester
Relationship to the child
Parental or legal authority
Applicable consent arrangements
Requests will be handled according to applicable law and the relevant service arrangement.

Legal & Regulatory Retention

Certain information may need to be retained because of legal, financial, regulatory or security-related requirements.

Tax laws
Accounting requirements
Regulatory obligations
Court proceedings
Legal claims
Fraud investigations
Security incidents
Other statutory requirements
Where such information is retained, BrainSeeds seeks to limit its use to the purpose for which retention is necessary.

Data Retention Reviews

BrainSeeds aims to periodically review its retention practices so that information does not remain longer than necessary without a continuing purpose.

Whether information is still required
Whether the original purpose remains valid
Whether retention periods remain appropriate
Changes in law
Changes in technology
Changes in services
Security considerations
User rights
Business requirements
Review principle
Where information is no longer required, appropriate action may be taken.
Retention decisions are reviewed in context, taking account of purpose, applicable requirements, security, technology and user rights.
Minimise • Protect • Review • Govern

Keep Less. Protect Better. Review Continuously.

Retention is connected to data minimisation, security and privacy governance. BrainSeeds' approach is to avoid keeping information simply because it is technically possible to store it.

Data Minimisation

Data retention is closely connected to data minimisation. BrainSeeds seeks to avoid retaining unnecessary information merely because it is technically possible to store it.

Core Principle
“If We Don't Need It, We Shouldn't Keep It.”
Children
Students
Assessment results
Behavioural information
Personality information
Developmental information

Security During the Retention Period

Information remains subject to appropriate security measures while it is retained.

Access controls
Authentication
Role-based permissions
Secure infrastructure
Monitoring
Confidentiality controls
Backup and recovery
Security incident management
Related Policy
Data Security & Compliance Policy

Data Retention & Privacy Rights

Data retention forms part of BrainSeeds' broader privacy framework. The related policies work together to describe how BrainSeeds seeks to manage personal information responsibly.

Privacy Policy
Data Security & Compliance Policy
Children & Student Data Protection Policy
Responsible AI & Ethical Assessment Policy
Cookie Policy
Terms & Conditions

International Data Retention

BrainSeeds is intended for international users. Information may be stored or processed in different jurisdictions depending on the infrastructure and service providers involved.

Cross-Border Context
Retention requirements may differ between jurisdictions.
BrainSeeds seeks to comply with relevant legal and contractual requirements concerning retention and processing where applicable.

Our Data Retention Lifecycle

BrainSeeds' retention model follows a continuous lifecycle rather than treating retention as a one-time decision.

01
COLLECT
02
USE
03
PROTECT
04
REVIEW
05
RETAIN
06
ANONYMISE / DELETE
Collect information for a defined purpose → use it to provide the relevant service → apply appropriate security and confidentiality safeguards → periodically review whether retention remains necessary → retain where there is a legitimate reason → anonymise or securely delete when appropriate.
A responsible retention model combines minimisation, security, privacy governance, review and appropriate deletion.
People • Development • Institutions

Retention Should Serve the Journey, Not Define It

BrainSeeds' commitments are designed around the people whose information may be retained: parents, students and educational institutions.

Our Commitment to Parents

“What happens to my child's information after the assessment?”

It should not simply remain in a system without purpose.

Providing the agreed service
Supporting development
Conducting reassessments
Fulfilling legal obligations
Maintaining appropriate records
Where information is no longer required and there is no lawful reason to retain it, appropriate deletion or anonymisation may be considered.

Our Commitment to Students

Your assessment is a part of your development journey. It is not a permanent digital identity.

Your interests may change.
Your abilities may develop.
Your goals may evolve.
Your learning journey may take new directions.
Your past assessment should help your future development—not permanently define your future.

Our Commitment to Educational Institutions

BrainSeeds encourages schools and educational institutions to establish appropriate data retention practices when using assessment services.

Who needs access
Why information is being retained
How long it is needed
When reports should be archived
When information should be deleted
How student confidentiality is maintained
BrainSeeds can work with institutional partners to establish appropriate data-handling arrangements according to the relevant service and contractual requirements.
Exceptions & Special Circumstances

Some Information May Need to Remain Temporarily

There may be circumstances in which information cannot be immediately deleted. In such circumstances, BrainSeeds may restrict access and use while retaining the information for the required purpose.

Retention in these circumstances is connected to the specific requirement that prevents immediate deletion.
Legal disputes
Regulatory investigations
Security investigations
Fraud prevention
Legal preservation requirements
Technical backup cycles
Contractual obligations
Responsible retention means keeping information for a legitimate purpose while respecting the developmental journey and confidentiality of the people involved.
Updates • Contact • Commitment

Responsible Retention Is an Ongoing Promise

BrainSeeds recognises that responsible data management evolves with services, technology, data practices and applicable requirements.

Changes to This Policy

BrainSeeds may update this Data Retention & Deletion Policy from time to time.

New services
Technology developments
Changes in data practices
Changes in legal requirements
Regulatory developments
Improvements in the privacy framework
The “Last Updated” date indicates the latest revision.

Contact Us

Questions or requests concerning data retention or deletion can be directed to BrainSeeds through the contact channels below.

Organisation BrainSeeds
Website brainseeds.in
Privacy Email privacy@brainseeds.in
General Email info@brainseeds.in
Data Protection / Privacy Contact [Insert Name / Designation, where applicable]
Registered Office [Insert Complete Registered Office Address]

Our Data Retention Promise

Responsible data management is not about keeping everything forever. It is about knowing what to collect, why to collect it, how to protect it, how long it is needed, when it should be deleted, and—most importantly— who the data belongs to.

A BrainSeeds assessment may represent one moment in a person's development. A person's journey continues.
What to collect
Why to collect it
How to protect it
How long it is needed
When it should be deleted
Who the data belongs to
Retain With Purpose. Protect With Care. Delete With Responsibility.
Every Mind Matters. Every Talent Counts. Every Privacy Right Matters.
BrainSeeds — Discovering Potential. Nurturing Excellence. Empowering Futures.
BrainSeeds seeks to ensure that information is retained when it genuinely contributes to the developmental journey, protected while it is retained, and responsibly removed when its legitimate purpose has ended.
Implementation • Governance • Retention Schedule

Make the Policy Match the Real Operating Model

BrainSeeds' policy avoids arbitrary fixed retention periods until the actual operating model is finalised. An internal Data Retention Schedule can define the appropriate periods for different information categories.

Why an Internal Schedule Matters

The public policy can accurately refer to retention periods or categories once the underlying BrainSeeds operating model has been established.

Avoid arbitrary promises
Do not publish a fixed period such as “we retain assessment data for 7 years” until the actual operating model is finalised.
Retention should reflect the real purpose, lifecycle and developmental value of the information.

BrainSeeds Data Retention Schedule

The internal schedule should establish specific periods for the information categories relevant to BrainSeeds services.

Student master data
Parent/guardian data
Assessment responses
Assessment reports
Psychometric profiles
Multiple Intelligence profiles
Personalised learning records
Reassessment history
Certificates
Payment records
Marketing data
Customer-support records
Security logs
Backups
Deleted-account data
The public Data Retention & Deletion Policy can then accurately refer to the periods or categories established by the internal schedule.
This approach helps balance the genuine developmental value of assessment history with the need to avoid indefinite retention of children's assessment profiles.
Purpose • Development • Privacy

Protecting the Journey, Not Just the Data

A BrainSeeds assessment may represent one moment in a person's development. The journey continues, and retained information should remain connected to a genuine purpose within that journey.
Our Commitment

Information Should Have a Reason to Stay.

BrainSeeds seeks to ensure that information is retained when it genuinely contributes to the developmental journey, protected while it is retained, and responsibly removed when its legitimate purpose has ended.

Retention is not about keeping everything forever. It is about retaining information with purpose and responsibility.
What to collect
Why to collect it
How to protect it
How long it is needed
When it should be deleted
And, most importantly: who the data belongs to.
Policy at a Glance

One Framework. Six Decisions. One Responsible Lifecycle.

The BrainSeeds approach connects collection, service delivery, protection, review, legitimate retention and responsible disposal into one continuous data lifecycle.

Six Questions Guide Retention

Responsible data management begins with knowing what information exists, why it is needed, how it should be protected and when its legitimate purpose has ended.

01 What to collect
02 Why to collect it
03 How to protect it
04 How long it is needed
05 When it should be deleted
06 Who the data belongs to

When Information Reaches a Decision Point

BrainSeeds' policy describes several possible outcomes depending on the purpose of the information and the applicable requirements.

Retain
Keep information where there is a legitimate reason for continued retention.
Anonymise
Convert information so it is no longer reasonably capable of identifying an individual.
Delete
Securely remove information when appropriate and no lawful retention reason applies.
In certain circumstances, information may instead need to remain restricted or isolated while being retained for a required purpose.
A Responsible Data Lifecycle
The policy describes retention as an ongoing process rather than a single end-point decision.
01
COLLECT
02
USE
03
PROTECT
04
REVIEW
05
RETAIN
06
ANONYMISE / DELETE
Information should move through this lifecycle according to its legitimate purpose, applicable requirements and the needs of the relevant service.
“Retain With Purpose. Protect With Care. Delete With Responsibility.”
Final Commitment

Every Data Decision Should Respect the Journey.

BrainSeeds seeks to retain information when it genuinely contributes to the developmental journey, protect it while it is retained, and responsibly remove it when its legitimate purpose has ended.
Our Data Retention Promise
Responsible Data Management Is Not About Keeping Everything Forever.
It is about knowing what to collect, why to collect it, how to protect it, how long it is needed, when it should be deleted, and—most importantly— who the data belongs to.
Retain With Purpose. Protect With Care. Delete With Responsibility.
01
Collect for a defined purpose
02
Protect while retained
03
Review continued necessity
04
Delete or anonymise when appropriate
Implementation Note

Build the Internal Schedule Before Publishing Fixed Periods

The policy recommends avoiding arbitrary fixed periods until the actual BrainSeeds operating model is finalised.

Student master data
Parent/guardian data
Assessment responses
Assessment reports
Psychometric profiles
Multiple Intelligence profiles
Personalised learning records
Reassessment history
Certificates
Payment records
Marketing data
Customer-support records
Security logs
Backups
Deleted-account data
Companion Policy

Continue the Privacy Journey

Data retention explains how information may be retained, reviewed, anonymised or deleted. A practical companion policy can explain how parents, students and other users can exercise applicable privacy rights.

Your Privacy Rights & Data Request Policy
Recommended companion page covering practical mechanisms for access, correction, deletion, consent withdrawal, information about processing, complaints or grievances, and other applicable rights.
Every Mind Matters. Every Talent Counts. Every Privacy Right Matters.
BrainSeeds
Discovering Potential. Nurturing Excellence. Empowering Futures.
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