The short version
- This schedule sets out how long Zinstruct keeps each category of Personal Data, and why. Each period is the longest we keep the data. We often delete it sooner.
- Creator accounts are kept while they are open. When a Creator's Agreement ends, the Creator has 30 days to export Creator Content and Member Data. We then delete it from our active systems within 30 days, and from backups within 30 days after that.
- We keep payment and tax records for 6 years, support requests for 3 years, security logs for 1 year, and identifiable usage data for 14 months.
- Database backups expire within 30 days.
- A legal hold or a legal requirement can pause deletion, but only for the data it covers and only for as long as it applies.
- You can reach us about this schedule at legal@zinstruct.com.
This summary is for convenience. The full text below controls.
1.About this schedule
1.1Who we are
In this Retention Schedule, "Zinstruct," "we," and "us" mean Lawton, LLC, a Colorado limited liability company doing business as Zinstruct. Capitalized terms that are not defined here, such as Creator, Member, Account, Agreement, Services, Creator Content, Member Data, Personal Data, AI Input, AI Output, and Aggregated Data, have the meanings given in the Terms of Service and the AI Terms.
1.2What this schedule covers
This schedule is part of our Privacy Notice, our US State Privacy Notice, our Workforce Member Privacy Policy, our Cookie Notice, and our AI Terms. Those documents point here for how long we keep Personal Data.
- Personal Data we control. Section 3 covers Personal Data about Creators, Authorized Users, Partners, visitors to zinstruct.com, and other people who contact us or hear from us.
- Member Data and Creator Content. Section 4 covers data we process for Creators. For Member Data, the Creator is the controller and we are its processor. The Data Processing Addendum governs that processing. If this schedule and the Data Processing Addendum conflict about Member Data, the Data Processing Addendum controls.
- Workforce Members. Section 5 covers Personal Data about our Employees, Contractors, and Applicants, and about Related Individuals, as those terms are defined in the Workforce Member Privacy Policy.
1.3Periods are maximums
Each period in this schedule is the longest we keep the data for the purpose shown. We delete data sooner when we no longer need it, when you delete it with the tools in the Services, or when you ask us to and the law allows it.
If the same data is needed for more than one purpose, we keep only the data the longer purpose needs, and only for that longer period. For example, when an Account is deleted, the records of its payments stay with our payment records for the period in Section 3, but the rest of the Account data is deleted.
2.How we set retention periods
We keep Personal Data only for as long as we need it for the purposes described in our privacy notices. To set each period, we consider:
- how long we need the data to provide the Services or keep the relationship going;
- how long the law requires us to keep it, such as for tax, accounting, and employment records;
- how long someone could bring a legal claim that the data would help resolve; and
- how sensitive the data is, and the risk of keeping it longer.
Where the law sets a minimum period, the "Why" column in each table names it. Where no law sets one, the period is the shortest that still serves the purpose. When a period ends, we delete the data or de-identify it as Section 8 describes.
3.Retention periods for Personal Data we control
The first column uses the category names in the US State Privacy Notice and the Privacy Notice.
| Category | How long we keep it | Why |
|---|---|---|
| Identifiers and Account and profile data (name, email, login credentials, business details, Authorized Users, Partner profiles) | While the Account is open. When the Agreement ends, the 30-day export period in Section 4 applies, and we then delete the data from our active systems within 30 days. | We need it to provide the Services and to let you export your data. Deleting it within 60 days of the Agreement ending keeps it no longer than needed. |
| Trial workspaces that never became paid Accounts | 90 days after the trial ends. A workspace with nothing in it is deleted 30 days after the trial ends. We email the owner before deletion: 30 days and 7 days ahead, or 7 days ahead for an empty workspace. | Long enough for the owner to come back and subscribe, with notice before anything is deleted. |
| Payment and transaction data (Fees, invoices, refunds, payouts, records of Member Transactions, Partner commissions, and tax forms such as Form W-9 and Form 1099). Zinstruct does not store full card numbers. | 6 years after the end of the tax year the record relates to. | Federal tax law requires records that support a tax return (26 C.F.R. § 1.6001-1), and the IRS can review a return for up to 6 years in some cases (26 U.S.C. § 6501(e)). Colorado requires tax records for at least 4 years (C.R.S. § 39-21-113), and allows 6 years to bring a claim to recover a debt (C.R.S. § 13-80-103.5). |
| Records of your acceptance of our terms and policies | While the Account is open, and 6 years after it closes. | They prove what was agreed for as long as a claim under the Agreement could be brought (C.R.S. §§ 13-80-101 and 13-80-103.5). |
| AI Input and AI Output, and the instructions, sources, and insights in a Creator's AI features | While the Creator keeps them in the Services. Items the Creator deletes are removed from our active systems and leave our backups as they expire under Section 6. All of it is deleted with the Account, as the first row describes. Usage records we use to bill for AI features are kept as payment and transaction data. | The Creator decides how long to keep them. Member conversations with Community AI are Member Data, covered by Section 4. |
| Usage and device data (pages viewed, actions taken, device and browser information, approximate location derived from IP address, and attribution data) | 14 months after we collect it. After that we delete it or keep it only as Aggregated Data. | Long enough to compare the same period a year apart, and no longer. |
| Cookies and similar technologies | Each cookie lasts for the lifespan shown in Section 5 of the Cookie Notice. Your cookie choice is stored in your browser for 1 year. | Lifespans are set per cookie. Data collected through cookies is kept for the period in the usage and device data row. |
| Security and sign-in logs (sign-in events, IP addresses, security events, and records of staff actions in our administrative console) | 1 year. | We need them to investigate security incidents and abuse. Twelve months is the common benchmark for security logs, such as PCI DSS Requirement 10.5.1. |
| Application and error logs | 90 days. | We use them to find and fix problems. They are not needed after that. |
| Communications (support requests, emails and chats with us, and conversations with our support assistant) | 3 years after the request is closed or the conversation ends. | They can show what was reported or promised if a dispute arises. Colorado's limit for contract and consumer protection claims is 3 years (C.R.S. §§ 13-80-101 and 6-1-115). |
| Marketing preferences (email subscriptions and your choices about our marketing) | Until you unsubscribe. We keep evidence of your consent for 3 years after your subscription ends. | So that we email only people who asked to hear from us, and can show that they did. |
| Our marketing suppression list (the email addresses of people who have unsubscribed) | For as long as we send marketing email. | So that we never email you again after you opt out (15 U.S.C. § 7704). We keep only what we need to recognize your address. |
| Records of privacy requests and our responses | 3 years after the request is closed. | California and Colorado rules require at least 24 months (Cal. Code Regs. tit. 11, § 7101 and 4 CCR 904-3, Rule 6.11). Colorado allows 3 years to bring a consumer protection claim (C.R.S. § 6-1-115). |
| Security incident records | 3 years after the incident is closed. | To learn from incidents, show what we did, and answer questions from Creators and regulators. |
| Law enforcement and other legal requests, and copyright notices and counter-notices | 3 years after the request or notice is closed. | Copyright claims must be brought within 3 years (17 U.S.C. § 507(b)). Requests to preserve data follow Section 7. |
| Records of repeated copyright infringement by an Account | While the Account is open, and 3 years after it closes. | We need them to apply our repeat-infringer policy, which the law requires (17 U.S.C. § 512(i)). |
4.Creator Content and Member Data
4.1During the Agreement
The Creator decides how long to keep Creator Content and Member Data, and can delete it at any time with the tools in the Services. When a Creator permanently deletes an item, we remove it from our active systems, and it leaves our backups as they expire under Section 6. Some items, such as lesson comments, can first be moved to a deleted list from which the Creator can restore them. Those items stay until the Creator deletes them permanently or the Agreement ends.
4.2When the Agreement ends
When a Creator's Agreement ends:
- Export period. For 30 days, the Creator can export Creator Content and Member Data, as Section 19.5 of the Terms of Service and Section 14.2 of the Data Processing Addendum describe.
- Deletion from active systems. Within 30 days after the export period ends, we delete Creator Content and Member Data from our active systems. That includes files and videos stored with our storage providers.
- Deletion from backups. Copies in database backups expire within 30 days after that, as Section 6 describes.
All Creator Content and Member Data is therefore deleted within 90 days after the Agreement ends. A Creator can ask us to delete it sooner by emailing legal@zinstruct.com.
4.3Trial workspaces
A workspace that never became a paid Account is deleted on the schedule in the trial workspaces row of Section 3, including its Creator Content and Member Data.
4.4What we keep after deletion
As Section 14.3 of the Data Processing Addendum allows, we keep records of Member Transactions that we need for Fees, tax, and accounting for the period in the payment and transaction data row of Section 3. We keep them confidential and use them only for that purpose.
5.Workforce Members and Related Individuals
The categories below match Section 3 of the Workforce Member Privacy Policy. Where a period runs from a "personnel action," that means a decision such as hiring, promotion, a change in pay, discipline, or the end of employment or engagement.
| Category | How long we keep it | Why |
|---|---|---|
| Recruitment data (applications, résumés, interview notes, and assessments), whether or not we hire the Applicant | 5 years after the later of the date we received the record or the hiring decision. | Colorado requires employers to keep application forms and other hiring records for 5 years (C.R.S. § 24-34-408). |
| Employment and engagement data, and performance and conduct data (including complaints and investigations) | 5 years after the later of the date the record was made or the personnel action it relates to. | Colorado requires employers to keep personnel and employment records for 5 years (C.R.S. § 24-34-408). |
| Compensation, payroll, and benefits data | 5 years after the end of the year the record relates to. | Colorado requires payroll records for 5 years (C.R.S. § 8-72-107). Federal tax law requires 4 years (26 C.F.R. § 31.6001-1), and federal and Colorado wage laws require 3 years (29 C.F.R. § 516.5 and C.R.S. § 8-4-103). |
| Contractor invoices and payments | 6 years after the end of the tax year the payment relates to. | They are business payment records, kept under the payment and transaction data row of Section 3. |
| Government identifiers and work authorization | Form I-9 records: 3 years after the date of hire or 1 year after employment ends, whichever is later. Other government identifiers are kept with payroll records for the period above. | Federal immigration rules set the Form I-9 period (8 C.F.R. § 274a.2). |
| Health and leave data, including accommodation requests | 5 years after the later of the date the record was made or the personnel action it relates to. We keep it separately from other personnel records. | Colorado's 5-year rule covers accommodation requests (C.R.S. § 24-34-408). Paid sick leave records must be kept for at least 2 years (C.R.S. § 8-13.3-409). |
| Equal opportunity data | 5 years after we receive it. We keep it separately from the information we use to make decisions. | It is part of the hiring records Colorado requires us to keep (C.R.S. § 24-34-408). |
| Emergency contact data | Until employment or engagement ends, then deleted within 90 days. | We need it only while you work with us. |
| Dependent and beneficiary data | With benefits records, for the period in the compensation, payroll, and benefits row. | We need it to show how benefits were provided. |
| Records of use of Company Systems, including monitoring records | 1 year. | The same period as our other security logs in Section 3. |
6.Backups
Our database provider backs up the database automatically. Each backup is kept for no more than 30 days and then expires. Data deleted from our active systems stays in backups only until those backups expire.
We use backups only to recover from data loss or a security incident. If we restore a backup, we delete again any data that was due to be deleted. Files and videos stored with our storage providers are not part of these backups. They are deleted as Section 4 describes.
7.Legal holds and other exceptions
7.1Legal holds
We pause scheduled deletion of specific data when we must preserve it because of a legal claim, an investigation, an audit, or a valid legal request. That includes a request to preserve records under 18 U.S.C. § 2703(f), which lasts 90 days and can be renewed once for another 90 days. The pause covers only the data that is needed, and it ends when the reason for it ends. Normal deletion then resumes. The Law Enforcement and Legal Request Guidelines explain how we handle preservation requests.
7.2When the law requires longer
If a law requires us to keep data longer than this schedule says, we keep it for as long as that law requires, and we use it only for the purpose the law requires.
7.3Aggregated Data
We may keep Aggregated Data without a time limit, because it does not identify any individual. We will not try to re-identify any person from Aggregated Data or from other data we have de-identified.
7.4Asking us to delete sooner
You may have the right to ask us to delete Personal Data before the end of its period. Section 12 of the Privacy Notice and Section 8 of the US State Privacy Notice explain how. Members should contact the Creator whose Creator Site they use about Member Data.
8.How we delete Personal Data
When a retention period ends, we delete the Personal Data or de-identify it.
- Electronic records. We erase them, or change them so that the Personal Data can no longer be read or reconstructed.
- Paper records. We shred them or have them destroyed securely.
- Service providers. Our service providers delete Personal Data they process for us when we tell them to, or when their contracts with us end, as those contracts require.
- De-identified data. We keep data in de-identified form only where we have taken reasonable steps so that it cannot be linked to an individual.
9.Changes to this policy
We may update this schedule from time to time. When we do, we will post the updated version in the Policy Center and change the "Last updated" date at the top.
If we make a change that lets us keep Personal Data materially longer, we will notify you by email or through the Services at least 30 days before it takes effect, unless the law requires a change to take effect sooner.
10.Contact us
Lawton, LLC d/b/a Zinstruct
2403 E 28th Ave, Denver, CO 80205, USA
legal@zinstruct.com