Data Retention Policy

Last updated: November 5, 2026 · Version 1.1

1. Purpose and Scope

This Data Retention Policy describes how long Scrawlr retains the personal information and other data collected through The Personality Project (the “Service”), and what happens to that data when the retention period ends.

This Policy is intended to be read together with our Privacy Policy, which provides the user-facing summary of retention (Privacy Policy §4). This document is the detailed reference schedule.

If there is any apparent conflict between the user-facing Privacy Policy and this Retention Policy, the Privacy Policy governs the user-facing commitment; this Retention Policy describes the operational schedule by which we honor that commitment.

2. Retention Principles

We follow four principles for data retention, drawn from the Fair Information Principles in PIPEDA, the data-minimization principle in GDPR Article 5(1)(c), and the retention-limitation rule in Quebec Law 25:

• Purpose-bound. We retain personal information only as long as we need it for the purpose for which it was collected, plus a brief grace and backup period.
• Documented. Every category of data has a documented retention window (see §3 below).
• Minimum necessary. Where the law permits multiple retention periods, we choose the shorter unless there is a specific reason to choose longer.
• Anonymized or deleted. When the retention period ends, the data is either destroyed or anonymized (irreversibly stripped of identifiers) so it can no longer be linked to you.

3. Reference Schedule by Category

The following schedule shows how long each category of data is retained while the account is active, and what happens to that category when the account is deleted. The end-state for personal information is destruction; the end-state for aggregated, irreversibly anonymized analytics is indefinite retention in aggregate form only (see §6).

Swipe sideways to see every column

4. Account Deletion, Detailed Sequence

When you initiate account deletion via your privacy settings, the following sequence applies.

4.1 Grace period

• Your account is immediately marked for deletion. To stop a pending deletion during the 30-day grace period, contact us at privacy@thepersonalityproject.com.
• You will not be billed during this period and no further service communications will be sent.

4.2 Hard deletion

• At the end of the 30-day grace period, your account and all directly-linked personal information are hard-deleted from our primary systems. This includes account identifiers (§3.1), psychometric assessment data (§3.2), private user-generated content (§3.3), external reference scores (§3.5), and crisis-content detection signals (§3.8).
• Hard deletion is silent. No further communication is sent after deletion is complete.

4.3 Anonymized public content

• Public forum posts and public-room chat messages (§3.4) are not hard-deleted by default. They are anonymized, your identifier is replaced with a “deleted user” marker, and the post content is preserved to protect the integrity of conversations other users participated in.
• If you would prefer specific public posts be deleted rather than anonymized, you may request that at any time at privacy@thepersonalityproject.com. We will assess each request on a case-by-case basis, balancing your interest against the rights of other users who may have relied on the content.

4.4 Backup window

• Your deleted data may persist in encrypted backups for the rolling backup retention windows described at §3.10. We do not restore from backups for any operational purpose other than disaster recovery; in a disaster-recovery scenario, restored deleted-user records are re-deleted at the next backup-cleanup cycle.

4.5 Consent-evidence retention

• A minimal record of the consents you gave (e.g., marketing opt-in, age confirmation, terms acceptance) is retained for the period specified at §3.9, in a separate consent-evidence log, to support our compliance with applicable consent-based laws (CASL most directly). The log contains only the consent fact, the date, and a hashed identifier; it does not retain your full personal information.

5. Quebec, Law 25 Retention Limits

Quebec’s Act respecting the protection of personal information in the private sector, as amended by Law 25, requires that personal information be retained only as long as necessary for the purposes for which it was collected (Article 23). We comply with this requirement as follows:

• The retention windows in §3 are scoped to the operational purpose for each category.
• When personal information of a Quebec resident is no longer necessary for the purpose, it is destroyed or anonymized (per Article 23).
• Scrawlr is responsible for ensuring this Policy is followed in practice and updated when purposes change.

Quebec residents may exercise their right to access, correction, portability, and de-indexing as described in the State and Provincial Privacy Rights Notice, Section 4.2. To exercise retention-specific rights (for example, to request that a category of data be deleted earlier than the schedule in §3 allows), contact us at privacy@thepersonalityproject.com.

6. Aggregated and De-Identified Data

The retention schedule above applies to personal information, that is, information that identifies or can reasonably be linked to a specific individual. Once data has been irreversibly anonymized or aggregated such that it cannot be linked back to an individual, it is no longer personal information under applicable law, and we may retain it indefinitely. Examples:

• Total number of users who took a given assessment in a given month
• Average completion rate of a given exercise
• Aggregate distribution of OCEAN trait scores in a given cohort

The de-identification process is irreversible. No personal identifier, direct (name, email) or indirect (unique session ID, IP, browser fingerprint), is retained in aggregated outputs.

7. Regulatory and Legal Exceptions

We may retain specific personal information longer than the schedule in §3 if (and only as long as):

• We are required to do so by applicable law (e.g., tax records, audit obligations, CASL consent records, court orders)
• The information is necessary to defend ourselves against a legal claim, in which case we retain only the minimum necessary, and only for the duration of the claim
• The information is necessary to investigate a security incident or a credible safety threat, in which case we document the rationale and the additional retention period

Where we retain data under one of these exceptions, the retention is scoped to the specific legal or investigative purpose, and the data is destroyed when that purpose is satisfied.

8. Contact

For questions about how long we retain your data, or to request earlier deletion of a specific category:

• Email: privacy@thepersonalityproject.com
• Postal: Scrawlr, 1820-999 W Hastings St, Vancouver, BC, Canada, V6C 2W2