Purpose
This Data Retention Policy (the “Policy”) sets out the retention periods, deletion methods and procedures that ME24 Limited (the “Company”) applies to personal data and other information processed through the Areela platform. It is cross-referenced to and intended to be consistent with Schedule 5 (Data Retention Schedule) of the Subscription Services Agreement and the retention and deletion provisions in the Data Processing Addendum at Schedule 2 and 5 of the Subscription Services Agreement.
Scope
This Policy applies to all personal data and business information processed by the Company in connection with the Areela platform, whether in the capacity of data controller or data processor. It covers data relating to coaches, business users, end-user clients and any other individuals whose data is processed through the Platform. It should be read with the Privacy Notice: Trainer and Business Users (Document 1), the Privacy Policy: ME24 Limited (Corporate) (Document 1A), the Privacy Notice: End Users (Document 2), the Data Processing Addendum at Schedule 2 of the Subscription Services Agreement.
Retention Schedule
The following table sets out the retention periods and deletion methods for each category of data: AI Service Provider (OpenAI): Under the Modified Retention Amendment dated 6 September 2026, ZDR is confirmed for eligible text-based API endpoints. Covered inputs and outputs are not logged for abuse monitoring or human review and are not retained beyond the time needed to generate a response. Image and file inputs may be retained for automated Safety Classification. Following termination, the OpenAI Services Agreement requires deletion of Customer Content within 30 days, subject to legal-retention exceptions. ME24 Limited’s own copies remain subject to this Policy, which is aligned with the Data Processing Addendum (Schedule 2) and Schedule 5 of the Subscription Services Agreement.
Data Category | Retention Period | Deletion Method | Legal Basis for Retention |
|---|---|---|---|
Account information (name, email, phone, profile) | Account lifetime + 14-day grace period following account deletion request | Permanent erasure from all production systems | Contract (Article 6(1)(b)) |
AI conversations and summaries | Account lifetime, or earlier upon user deletion of individual items; OpenAI does not retain eligible text-based API interactions beyond the time needed to generate a response under ZDR | Permanent erasure from all production systems | Contract / Consent (Article 6(1)(b) / Article 9(2)(a)) |
AI memory (coaching context, preferences, insights) | Account lifetime, or earlier upon user edit or deletion | Permanent erasure from all production systems | Contract / Consent |
Subscription and purchase records | Account lifetime; after account deletion, retained without user-identifying information for the period required by applicable tax and accounting law | User-identifying information permanently erased; de-identified financial records retained | Legal obligation (Article 6(1)(c)) |
Support correspondence | Account lifetime | Erased upon account deletion | Contract (Article 6(1)(b)) |
Security and operation logs | Account lifetime | Erased upon account deletion | Legitimate interests (Article 6(1)(f)) |
App usage and AI telemetry | Account lifetime; after account deletion, retained without user-identifying information | Anonymised upon account deletion; anonymised data retained indefinitely | Legitimate interests (Article 6(1)(f)) |
Deletion record (de-identified: internal ID, reason, deletion date, completion date) | Indefinite | Not deleted, maintained as a compliance record | Legal obligation (Article 6(1)(c)) |
Backups | Short rolling period (overwritten on rotation) | Automatically overwritten; not selectively restored | Legitimate interests (Article 6(1)(f)) |
Client health and activity data (injuries, PAR-Q, allergies, medication, blood type, measurements, workouts, nutrition, journals, photos) | Account lifetime, or earlier upon deletion of individual items by the user or their coach | Permanent erasure from all production systems | Consent (Article 9(2)(a)) |
Raw wearable payloads (Terra API) | Raw payload data redacted after 30 days; fully deleted after 90 days | Progressive deletion (redaction then full erasure) | Contract (Article 6(1)(b)) |
Structured wearable metrics (processed data from wearables) | Account lifetime | Permanent erasure upon account deletion | Contract (Article 6(1)(b)) |
OpenAI image and file inputs | Image and file inputs transmitted to OpenAI for AI processing may be retained by OpenAI for automated Safety Classification. Safety Classifiers consist only of metadata (classifier types, dates, counts, and confidence scores) and do not contain user content. Current retention and deletion periods are governed by OpenAI’s Your Data documentation at https://platform.openai.com/docs/guides/your-data. | Subject to OpenAI’s Safety Classification retention and deletion processes; review during quarterly policy monitoring | OpenAI DPA / Modified Retention Amendment dated 6 September 2026 |
OpenAI text-based API interactions (eligible endpoints) | No retention by OpenAI beyond the time needed to generate a response under ZDR; user content is not logged for abuse monitoring or human review | OpenAI does not retain covered content beyond response generation; ME24 Limited’s own copies remain subject to this Policy | OpenAI DPA / Enterprise Agreement / Modified Retention Amendment dated 6 September 2026 |
General Retention Period
Where a specific retention period is not defined above, the Company will retain the relevant data only for as long as necessary for the applicable purpose or legal obligation. No general seven-year period should be applied automatically to all data categories; any category- specific period should be confirmed against the applicable statutory, contractual and operational requirements.
Anonymisation Procedures
Where data is anonymised rather than deleted (e.g., usage telemetry, financial records), the following procedures apply:
a) All direct identifiers (name, email, phone number, IP address) are permanently and irreversibly removed.b) Internal user identifiers are replaced with non-reversible hashed or randomised identifiers.
c) The anonymised dataset is assessed to confirm that re-identification is not reasonably likely, taking into account all means reasonably likely to be used.
d) Anonymised data is no longer considered personal data under UK GDPR and may be retained indefinitely for analytical and statistical purposes.
Deletion Verification
Upon completion of a deletion request (whether initiated by a user or triggered by account deletion), the Company:
a) Confirms that personal data has been permanently erased from all production databases and file storage systems.
b) Records the deletion in the deletion register, including the internal identifier, reason for deletion, date of request, and date of completion.
c) Notes that data within existing backup rotations will be naturally overwritten within the backup rolling period and is not selectively restored.
Backup Handling
Backups are maintained on an encrypted, short rolling basis and are overwritten on rotation. Personal data that has been deleted from production systems may persist in backups until the relevant backup is overwritten. Backups are not selectively searched or restored except in the event of a genuine disaster recovery scenario. If a backup is restored for disaster recovery purposes, any data that should have been deleted during the backup period will be re-deleted as part of the restoration process. Backup encryption ensures that data within backups remains protected even during the rolling retention period.
Policy Review
This Data Retention Policy is reviewed at least annually, or more frequently if required by changes to applicable law, regulatory guidance, the Company’s data processing activities, or the platform’s functionality. All changes are documented and communicated to relevant personnel.
Changes to This Policy
We may update this Policy from time to time. The most current version will be available at areela.com/legal. Where we make material changes, we will provide at least 30 days’ advance notice by: (a) displaying a prominent notice on the Platform; (b) sending an email to the address associated with your account; or (c) both. Material changes include changes that affect: your rights and obligations; how your personal data is processed; the scope of services or features available to you; or any other matter that could reasonably be expected to affect your use of the Platform.