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TacTile›Launch TacTile›Foundations›Legal & Compliance·33 in this wave

Approve: Legal & ComplianceTo do · blocker NEEDS MATTHEW: privacy-policy §6 publishes an admission against interestBlocked · blocker Verify support@tactile-connect.com delivers end-to-endTo do · blocker MATTHEW: eight legal documents marked DRAFT — NOT IN FORCE are published and now linked from marketingTo do · blocker Draft Terms of ServiceDone Draft Privacy PolicyTo do Draft Acceptable Use PolicyDone DMCA takedown policy + register agentTo do DSAR + account-deletion processTo do App Store privacy labels + Play Data SafetyTo do DECIDE: "no third-party data sales" pledge dropped from canonical S13To do Add IP-assignment and NDA agreements to S13's pre-launch checklistTo do Add product liability + workers' comp to S13's insurance planTo do Fix cap table misstatement: S13 says "no SAFEs" while one is actively being raisedTo do Decide: restore or drop the "no third-party data sales, ever" pledgeDone Resolve the data-retention contradiction between S13 and Pro analyticsDone Execute IP assignment and NDA agreementsTo do Appoint an Article 27 EU representativeTo do Execute SCCs with all seven sub-processorsTo do Publish the legal pack — /legal index + a page per documentDone Verify entity name "TacTile Connect, Inc." across docsTo do Write support policyDone Audit business plan Section 13 for policy driftTo do Confirm marketing claims match capabilitiesTo do Confirm co-founder equity resolution note and trademark class 45 in S13To do Draft Cookie PolicyDone Draft DPA templateTo do Sign DPAs with sub-processorsTo do Draft refund policyDone Write incident-response planDone Stand up compliance mailboxesDone Publish sub-processor list pageTo do Resolve retention conflict: S13's 90-day blanket vs indefinite Pro analytics retentionTo do

Wave

Legal & Compliance

v1.0 legal + compliance docs and processes — agent-drafted, Matthew signs off. Entity: TacTile Connect, Inc.

TacTile › Launch TacTile › Foundations › Legal & Compliance

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Resolve the data-retention contradiction between S13 and Pro analytics

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Unlocks 1Approve: Legal & Compliance

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```

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## The task

**Resolve the data-retention contradiction between S13 and Pro analytics** · done

Where it sits: TacTile › Launch TacTile › Foundations › Legal & Compliance

## Unlocks 1

- Approve: Legal & Compliance

## The brief on file

RESOLVED by Matthew 2026-07-28. There are TWO retention periods, not one, and the apparent contradiction was really two different categories of data being conflated:

  • Scan and interaction logs — 90 days. Behavioural data about visitors. This is the S13 commitment and it stands.
  • Audit records — 24 months. Security and billing evidence that protects both the customer and TacTile.

Regulators expect these to differ, so this is defensible rather than inconsistent — but the Privacy Policy must state both periods explicitly in separate sentences, or it reads like a contradiction.

REASONING FOR 24 MONTHS: breaches are typically discovered 6-9 months after they happen, so anything under a year destroys the evidence before anyone knows it is needed. Billing disputes and chargebacks also run long — contesting a charge 8 months later is ordinary. Past two years the investigative value drops sharply while storage cost and "why do you still hold my data" both rise. Lawful basis is legitimate interest (security, fraud prevention, defending legal claims), which satisfies GDPR storage limitation because the period is defined and justified.

IMPLEMENTED in supabase/migrations/202607281400_audit_log.sql — prune_audit_log() runs nightly at 03:20 UTC via pg_cron, offset from the analytics rollup so they do not contend. It is SECURITY DEFINER and is the only thing permitted to delete rows, since UPDATE/DELETE are revoked from every application role.

STILL OPEN, SEPARATELY: the Pro-tier "indefinite analytics retention" claim. Indefinite is not a lawful period under GDPR. If that is a real selling point it needs a long-but-finite number (24 or 36 months) with the purpose stated. Tracked in the Business & documentation wave alongside the other pricing-page reconciliations.

## How to work this

- Do the work, don't just plan it. If the fix is obvious and safe, make it.
- Surface anything needing Matthew's sign-off instead of deciding it yourself.
- Short replies. Lead with the answer, then stop.
- Finish by saying what changed, what you verified, and what you'd do next.

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Legal & Compliance

Resolve the data-retention contradiction between S13 and Pro analytics