Este documento es un borrador de trabajo: quedan 8 marcadores por completar, y el texto debe revisarse antes de tener validez. Se publica aquí para poder leerse, no para servir de referencia.

Privacy Policy — BadgeLane

DRAFT — legal review still required before publication. The product-specific blanks and your quick choices (contact address, retention) are now filled. What remains in [BRACKETS] is only what depends on your legal entity decision (name, jurisdiction, supervisory authority, postal address) or on a lawyer's review (children's-data obligations, international-transfer safeguards). This is a starting scaffold, not legal advice — three points stay in focus for your reviewer: children's data (students are minors), GDPR (France/EU + global users), and who the data controller is (depends on your entity). The single question worth a professional's time is under "Children's data": a student's date of birth is mandatory and cannot be left blank, so the service always knows a child's age — read that section first. Last updated: [DATE — set on publication].

Who we are

BadgeLane is class-management software for schools and clubs that teach skills — swimming, gymnastics, dance and others — operated by [LEGAL ENTITY NAME] ("we", "us"). For questions about this policy or your data, contact us at privacy@badgelane.com.

When a school uses BadgeLane, the school is the controller of the families' and students' data it enters; we act as its processor, handling that data on the school's behalf and instructions. For the school's own account and billing data, we are the controller.

What we collect

How we use it

To provide the service — scheduling, enrolment, tuition billing, skill badges, and the parent portal — to communicate with you about your account, and to keep the service secure. We do not sell personal data, and we do not use it for advertising.

Children's data

Schools on BadgeLane serve minors. Student records are entered by the school or the parent to deliver the service to that family. We process them only for that purpose and only within the school the family belongs to. Parental consent is obtained by the school as part of enrolling a family.

The school is the controller; we are its processor. The school is responsible for the lawful basis of the processing and for any parental consent required; we process children's data on the school's documented instructions and for no other purpose. Requests to access, correct, delete or export a child's data are handled by the school, and we support the school in answering them.

Where COPPA applies — a school in the United States enrolling children under 13 — the school provides consent under the school-consent exception, for educational purposes only.

We collect only what is needed to run the class, the enrolment and the billing: a student's name, date of birth, class or level, badges earned and attendance. We ask for nothing beyond that, and the school decides what it enters.

We do not sell children's data, we do not use it for advertising, and we do not use it to train artificial-intelligence models. No third party receives it other than the providers listed below, each of which processes it only to run the service.

A student's date of birth is required. It cannot be left blank at enrolment, and it is collected both by the school's enrolment widget and by staff on the family record. We use it to place a child in the right class and level. [Legal review — this is the decisive fact for your assessment: we store the age of every child, and the field is mandatory. That is the exact datum on which COPPA (US) and the GDPR's children's-data regime turn. Confirm the consent mechanism is adequate for the markets you operate in, and whether an age threshold changes what consent is required.]

Who we share it with (processors / sub-processors)

We share data only with the providers that run the service, each bound by its own data-protection terms:

We do not share personal data with anyone else except when required by law.

International transfers

Several of these providers are based in the United States and process data internationally. Each transfer relies on a valid mechanism: the EU-US Data Privacy Framework where the provider is certified under it, or Standard Contractual Clauses together with the provider's Data Processing Agreement. [Legal review: confirm the transfer mechanism and safeguards that apply for your entity's jurisdiction.]

How long we keep it

We keep each category of data only as long as it is needed, and for a stated reason:

Nothing is kept "just in case": if a category is not on this list, we do not keep it.

Your rights

Depending on where you live (and under GDPR for EU users), you may have the right to access, correct, delete, export, or restrict the use of your personal data, and to object to certain processing. To exercise these, contact privacy@badgelane.com — or, for data your school controls, contact your school. EU users may also lodge a complaint with a supervisory authority ([your jurisdiction's authority — e.g. the CNIL in France]).

Security

We protect data with access controls and tenant isolation, so one school cannot see another's data. No system is perfectly secure, but we take reasonable measures to safeguard your information.

Changes

We may update this policy; we'll post the new version here and update the date above. We'll notify account holders of material changes.

Contact

[LEGAL ENTITY NAME] · privacy@badgelane.com · [POSTAL ADDRESS — if required for your entity]

Los textos legales se publican únicamente en inglés. Una traducción tendría que revisarse por separado, y ninguna lo ha sido.