Data Protection Policy
Last updated: September 10, 2026
This Data Protection Policy supplements our Privacy Policy and describes how [COMPANY LEGAL NAME] ("Company," "we," or "us") retains, deletes, and protects personal information collected through the Sip Trip mobile application (the "Service").
1. Retention Principles
We retain personal information only for as long as reasonably necessary to provide the Service, fulfill the purposes described in our Privacy Policy, comply with our legal and regulatory obligations, resolve disputes, prevent fraud and abuse, maintain security, and enforce our agreements.
When personal information is no longer reasonably necessary for these purposes, we will delete, anonymize, or otherwise securely dispose of it in accordance with our retention procedures.
When a user requests deletion of an account or personal information, we will process the request within the timeframe required by applicable law. Certain information may be retained where required or permitted by law, including for legal compliance, fraud prevention, security, dispute resolution, financial recordkeeping, or the establishment, exercise, or defense of legal claims. Residual information may also remain temporarily in encrypted backup systems until those backups are overwritten or deleted through our ordinary retention cycle.
2. Retention Schedule by Category
We apply different retention periods based on the type of data:
- Account data: Retained while the account is active and for a reasonable period after deletion to comply with legal and recordkeeping obligations.
- Trip plans and stop data: Retained while the account is active; deleted with the account or when the user removes the trip.
- GPS / location history: Live GPS coordinates are used transiently for search and navigation and are not retained as a persistent location history.
- Blocked-IP logs: IP addresses of users who indicate they are under 21 are retained for fraud and abuse prevention. [ATTORNEY NOTE: Specify the retention period for blocked IPs — e.g., 12 months — and document the legitimate basis.]
- Payment records: Transaction identifiers and receipts are retained as required for financial recordkeeping and tax compliance.
3. What "Deletion" Means
Deletion may take the form of hard deletion from the active database, anonymization, or aggregation, depending on the data type and system. Deletion from the primary database does not always mean immediate deletion from backups or from our processors' systems. Residual copies may persist temporarily in encrypted backups until the normal backup cycle overwrites them.
4. Backup and Subprocessor Lag
When data is deleted from the active database, copies may remain in encrypted backup systems and in the systems of our processors (Base44, analytics, and mapping providers) until those systems complete their own retention and deletion cycles. We require our processors to delete or return data consistent with our retention commitments.
5. Blocked-IP List
The blocked-IP list is maintained to prevent underage users from circumventing the age gate. Blocked IP addresses are retained for fraud and abuse prevention and are not used for any other purpose. [ATTORNEY NOTE: Specify the retention period and the process for reviewing and purging stale entries.]
6. Verification Before Deletion
Before honoring a deletion request, we verify that the request comes from the actual account holder. This may include confirming the email associated with the account or other reasonable verification steps.
7. Legal Holds
We may retain data beyond its normal retention schedule when required by a litigation hold, regulatory inquiry, or other legal obligation. Data subject to a legal hold is not deleted until the hold is released and the standard retention period expires.
8. Vendor Flow-Down
We require our processors, including Base44, analytics providers, and mapping providers, to delete or return personal data consistent with our retention commitments and applicable law. We review our processor relationships periodically to ensure continued compliance.
9. Security Safeguards
We protect personal information using encryption in transit and at rest, access controls, and regular review of our systems. Access to personal data is limited to authorized personnel who need it to perform their duties.
10. Your Rights and Requests
You may request access to, correction of, or deletion of your personal information at any time. To submit a request, contact us at [SUPPORT EMAIL]. We will verify your identity and respond within the timeframe required by applicable law.
11. Contact
Questions about this Data Protection Policy? Contact us at [SUPPORT EMAIL] or [COMPANY ADDRESS].
Sip Trip is for adults 21+. Please drink responsibly.