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TumbleTrust

Privacy Policy

This Policy explains how Chaos Goblin Development Studios, referred to as CGDS, processes information through TumbleTrust. TumbleTrust helps participating gyms, authorized coaches, and parents or legal guardians manage athlete enrollment, coaching reports, private messages, and temporary media. The service is designed for authorized adults. Athletes do not receive accounts in the current product.

Who We Are

TumbleTrust is operated by Chaos Goblin Development Studios (CGDS), 137 Long Creek Way, Centreville, MD 21617. Privacy questions and requests may be sent to kevin@chaosgoblin.dev.

Scope and Party Roles

A participating Gym decides which athletes and authorized adults to enroll and directs routine coaching activities. CGDS provides, secures, and governs the platform. CGDS centrally controls TumbleTrust privacy notices, consent requirements, and platform-policy publication. Individual gyms cannot edit or publish TumbleTrust legal policies.

A Gym and CGDS may have different legal roles for different processing activities. The final Gym agreement must state those roles by purpose and cannot rely on one label for every activity.

Information We Process

  • Adult account information, including email address, display name, Gym role, account status, password hash material, session records, and password-security events.
  • Gym and athlete records, including athlete display name or roster identifier, Gym association, enrollment status, Coach assignments, and guardian relationships. Athlete information is limited to name, link to parent or guardian, and performance tracking for lessons from coaches, which may include temporary photographs or video.
  • Guardian authorization evidence, including contact verification, claimed authority type, attestation, Gym corroboration, review status, policy version, notice presentation and acknowledgement, consent decisions, withdrawal, and reauthorization records.
  • Coaching content, including lesson reports, skill assessments, practice suggestions, and coaching notes.
  • Coach and Parent conversations, message contents, participants, ordering, and timestamps.
  • Coach-uploaded photographs and short videos, plus filename, file type, file size, duration, upload time, expiration time, and lifecycle status.
  • Invitation and recovery records, including intended adult email, role, linked athlete where applicable, token digest, status, timestamps, and delivery outcome. Raw invitation and reset credentials are not stored in application records.
  • Security and operational records, including request identifier, route, response status, environment, duration, audit events, and limited error classifications.

Information We Ask Users Not to Submit

Users must not place Social Security numbers, financial account information, government identification, health-insurance information, medical diagnoses, or custody documents in reports, messages, filenames, or media unless CGDS later provides a specifically approved workflow. Currently all Personal Health Information (PHI) is prohibited, including but not limited to all injury and health content.

Sources

We receive information from authorized Gym Admins, Coaches, Parents or guardians, and the adult devices they use. The service generates relationship, authorization, security, media-lifecycle, and audit records. Hosting, object-storage, email-delivery, build, distribution, and device-platform providers may generate service data under their own terms.

How We Use Information

  • Authenticate adults, restore sessions, and provide password changes and password recovery.
  • Establish and enforce Gym roles, Coach assignments, guardian relationships, and athlete activation requirements.
  • Provide lesson reports, messages, temporary media, and authorized account administration.
  • Present approved platform notices, record authorization evidence, process withdrawal, and require reauthorization when an adopted policy changes.
  • Prevent, investigate, and respond to misuse, security incidents, disputes, and service failures.
  • Maintain, troubleshoot, and improve service reliability using limited operational information.
  • Respond to privacy requests and meet contractual or legal obligations.

No Sale Advertising or AI Training

CGDS does not intend to sell athlete information, use private athlete information for behavioral advertising, or use private reports, messages, or media to train artificial-intelligence models. Optional marketing use of athlete images is outside the TumbleTrust service authorization and would require a separate reviewed process.

Guardian Enrollment and Athlete Activation

A Gym Admin may create a minimal pending athlete record and invite an adult. Invitation redemption confirms control of the invited account; it does not by itself prove legal guardianship or activate the athlete. The guardian independently attests authority, opens and acknowledges the applicable notice, and makes required consent decisions. A distinct Gym Admin corroborates authority against the Gym's existing authorized-contact process. The backend activates the athlete only after every applicable approved requirement passes.

Each guardian relationship is evaluated separately. An active athlete may remain inaccessible to a guardian who has not completed their own authorization. Withdrawal, expiry, policy transition, or relationship removal may restrict access immediately.

Temporary Media

Authorized Coaches may upload private photos or short videos for an assigned active athlete. The service makes each item available for exactly 24 hours. The API refuses access after expiration even if physical cleanup has not finished. A scheduled cleanup job is designed to remove the private object and preserve limited lifecycle evidence.

Temporary access does not prevent an authorized person from taking a screenshot, screen recording, external photograph, or an entitled local copy. CGDS cannot recall copies outside its systems.

When We Disclose Information

  • To the participating Gym and authorized adult users, subject to current role and relationship checks.
  • To service providers used for hosting, database operations, private object storage, email delivery, mobile build and distribution, and support.
  • To professional advisers and insurers when needed and subject to confidentiality.
  • To authorities or others when lawfully required or necessary to protect safety, rights, or service security.
  • To a successor in a permitted transaction, subject to appropriate notice and safeguards.

Current provider categories include Render, Cloudflare R2 or another configured S3-compatible private store, Resend, Expo EAS, Apple, Google, and GitHub. TumbleTrust is under obligation to comply with the Terms and Conditions of the above mentioned entities.


Retention and Deletion

Media access lasts exactly 24 hours. Other information is currently retained according to application lifecycle rules, but several categories have no implemented purge schedule. The proposed schedule in this package is not yet a public guarantee. CGDS may retain narrowly limited information for security, fraud prevention, legal claims, or a documented preservation duty.

Deletion from active systems may be followed by expiration from encrypted rolling backups. A restored backup must reapply deletion records before ordinary use. An attempt to delete expired media will occur within 8 hours after the 24-hour access window. Media will remain inaccessible until deletion is completed. If deletion fails, removal will be attempted during the next cleanup window. At no time will expired media become accessible again.


Security

The reviewed service uses encrypted network connections, salted password hashing, opaque revocable sessions, private object storage, and server-side Gym, role, relationship, policy, and athlete-status checks. Security risk cannot be eliminated.



Privacy Choices and Requests

Subject to identity and authority verification and applicable law, an adult may request access, correction, deletion, relationship removal, consent withdrawal, an explanation of retention, or appeal of a denied request. Requests may be submitted through “Account Settings” in the application and selecting “Contact Gym Admin”. Additionally, an adult may request removal of their account and deletion of their personal information, directly in “Account Settings” and selecting “Request Account Deletion”. Deleting one adult account does not automatically delete another guardian, an athlete, or shared reports and messages.


Children and COPPA

TumbleTrust is designed for invited adults and is not directed to children. Adults may submit information about athletes, including images. FTC guidance distinguishes information collected online from children from information an adult submits about a child. Counsel has confirmed that the actual audience, marketing, app-store presentation, support practices, and data sources preserve this position.

If TumbleTrust becomes child-directed, allows athletes to use or submit information through the service, or gains actual knowledge that it collects personal information online from a child under 13, CGDS must reassess COPPA before collection. TumbleTrust’s Gym verification and guardian authorization procedures are a separate safeguard and does not establish that COPPA’s verifiable parental consent requirements apply. Additional assessment and review would be required if TumbleTrust expands into access by minors.


State and Geographic Scope

Residents may have additional rights under state law. CGDS intends to use a common access, correction, and deletion process where practical, but legal scope, exceptions, and verification may differ. The initial service is intended for the United States.

Policy Changes

CGDS will date material changes and provide notice appropriate to the change. When a successor platform policy requires fresh acknowledgement or consent, TumbleTrust requires new evidence for the version adopted by the Gym. Archived policy evidence remains linked to its original version.


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