Data Retention Policy

Effective: August 11, 2026 · Version: 1.4 · Owner: James Kang, Founder (hello@nudgelearn.app)

Published pursuant to the Children's Online Privacy Protection Act (16 CFR Part 312) as amended effective April 22, 2026. This policy is binding on NudgeLearn and is referenced from our public Privacy Policy.

1. Purpose

NudgeLearn collects personal information from account holders (teachers and parents) and from the student work they upload, to operate the NudgeLearn Grader: a photo-based grader for worksheets, tests and essays. This policy specifies, for each category of personal information we collect: (a) the purpose of collection, (b) the specific business need that justifies continued retention, and (c) the timeline after which the information is deleted or anonymized.

No personal information is retained indefinitely. No personal information is retained longer than reasonably necessary to fulfill the purpose for which it was collected.

2. Retention schedule

CategoryPurposeBusiness needTimeline
Account holder email, Stripe customer ID, subscription statusAccount management and billingRequired to service the account and to meet tax and accounting obligationsActive subscription + 7 years after cancellation
Uploaded image of student work + grading results (transcribed problems, the student’s answers, correct answers, score)Grade the work and let the account holder review past gradesAvailable while the account is active for the account holder to revisitFree plan: each graded paper is automatically deleted 90 days after upload, and only the 50 most recent are retained. Pro / Organization plans: retained while the account is active. Any graded paper can be deleted on demand from grading history, and all grader data is permanently deleted when the account is deleted.
Teacher-entered roster (student names, optional notes, optional student email for returning work, class/assignment labels)Organize a teacher’s grades by student and class, and return marked workNeeded to group grades for class analyticsRetained while the account is active; permanently deleted when the account is deleted
Application error logsOperational debugging and abuse investigationShort-term reliability30 days
Resend email delivery metadata (sign-in codes, returned work)Deliverability monitoringOperational90 days

Any category not listed above is not retained.

3. What we do not collect or retain

From students we do not collect: account credentials, ages, addresses, phone numbers, geolocation, audio, video, biometric identifiers, government IDs, cookies, IP addresses, or persistent identifiers used for cross-site tracking. Students have no accounts and never sign in. The only student information we hold is what a teacher or parent uploads or enters: the photo of the written work, which may carry a name, and the roster labels in the schedule above. We do not sell or license any student data, we do not use it for advertising, and we do not load advertising trackers on pages that display student work.

4. Deletion mechanisms

  • Scheduled purge (free plan). Daily, deletes graded papers from free-plan accounts older than 90 days, and any beyond the 50 most recent.
  • Delete on demand. A teacher or parent can delete any individual paper from grading history at any time.
  • Account deletion. Email to hello@nudgelearn.app or deletion via the dashboard. Hard delete permanently removes all data for the account: uploaded student-work images, grading results, teacher roster (student names and notes), and any grading corrections.
  • School request. Where a school or district is the account holder, we delete or return all student data covered by the agreement on written request, or within 30 days of the end of the agreement, and confirm in writing. See the Data Processing Addendum.

5. Parent, teacher and school rights

An account holder may, at any time, in the app or via email to hello@nudgelearn.app:

  • Review the personal information held about a student;
  • Correct a grade, a student name or a class label;
  • Export the graded work;
  • Request deletion of that information (honored within 30 days).

Where a school is the account holder, parent and student requests go through the school, since the school holds the education record. We complete our part within 15 business days of the school's request.

6. Review cadence

This policy is reviewed at least annually and whenever (a) data practices materially change, (b) a new regulation takes effect, or (c) a new collection category is introduced. The Founder approves revisions in writing.

7. Change log

  • 2026-08-11, v1.4: Narrowed to the Grader, which is the only service NudgeLearn operates. Removed every category belonging to the retired messaging tutor (child profile with phone number, raw answer text, response rows, consent events, webhook logs) since none of it is collected. Added school deletion and rights handling, and error-log and email-metadata windows.
  • 2026-06-27, v1.3: Introduced an automated free-plan retention window for the Grader: graded papers are deleted 90 days after upload, keeping the 50 most recent. Paid plans retain until deletion or account closure.
  • 2026-06-27, v1.2: Clarified that account deletion permanently purges all grader data (student-work images, grading results, teacher roster, and grading corrections), not only messaging-service records.
  • 2026-06-25, v1.1:Added Grader data categories (uploaded student-work images, grading results, teacher roster). Corrected the prior blanket "no photos" statement, which describes the messaging tutoring service only.
  • 2026-04-22, v1.0: Initial policy. Published ahead of the COPPA 2026 amendment compliance deadline.