Inactivity Policy

Company: FindPlay, Inc.
EIN: 36-5170181
Effective Date: 27 March 2026
Governing Law: Delaware, United States (primary); Australian Privacy Act 1988 (Cth); EU/UK GDPR; and applicable laws in all jurisdictions in which FindPlay operates, including the United States, Australia, the European Union, the United Kingdom, and Asia-Pacific markets.

Version: v1.0

This Inactivity Policy governs how FindPlay manages user and provider accounts that have been inactive for extended periods. It applies globally to all account types.

1. Purpose

Inactive accounts create data security risks, consume platform resources, and may hold listings or credentials that are no longer current. This policy establishes clear and fair rules for account inactivity management that are consistent with FindPlay's data minimisation obligations under applicable privacy law globally.

2. Definitions

Active account means an account where the account holder has logged in, made a booking, processed a transaction, updated a listing, or otherwise engaged with the FindPlay platform within the preceding 12 months.
Inactive account means an account that does not meet the active account definition.
Provider account means any account registered as a Play Provider, including coaches, clubs, venues, federations, and organisations.
User account means any account registered as an individual user (Active Person or Player).

3. Inactivity Thresholds

Account Type	Inactivity Notice Period	Inactivity Action
User account	12 months inactive → notification; 18 months inactive → suspension	Account suspended; data retained per retention schedule
Provider account	6 months inactive → notification; 12 months inactive → listing suspension; 24 months inactive → account closure

Jurisdiction	Data Retention Obligations
Australia	As required under the Privacy Act 1988 (Cth), Australian Privacy Principle 11, and applicable tax and financial records laws (typically 7 years for financial records).
United States	As required under applicable federal and state law, including IRS record-keeping requirements (typically 7 years). CCPA deletion rights apply to personal data not subject to a legal retention obligation.
European Union / United Kingdom	As required under EU/UK GDPR data minimisation and storage limitation principles (Articles 5(1)(e) and 17); right to erasure (Article 17) applies to personal data not subject to a legal retention obligation.
Singapore	As required under the PDPA and applicable tax and financial records law.
Japan	As required under the APPI and applicable commercial and tax records law.

Inactivity Policy

1. Purpose

2. Definitions

3. Inactivity Thresholds

Inactivity Policy

1. Purpose

2. Definitions

3. Inactivity Thresholds

4. Inactivity Notification Process

5. Reactivation

6. Account Closure and Data Handling

7. Unclaimed Funds

8. Exceptions