Effective Date: July 27, 2025 Applies To: CLO, CTO, Legal Ops, Platform Admins, Privacy Officer (if appointed) Review Cycle: Semi-annual or when data regulations are updated Related Legal Depot Sections: Section 4.4, Privacy Policy, Terms of Use, CrownThriveU/Affiliates Addenda
1. Purpose
To ensure that all legal data inquiries (e.g., subpoenas), user-submitted privacy requests, and backend data storage practices follow current law, protect member rights, and uphold the operational integrity of CrownThriveâs hosted platforms.
2. Scope
This SOP applies to:
- All data collected from CrownThrive users, partners, affiliates, and instructors
- Subpoenas and lawful government requests involving:
- Email addresses
- Payment history
- Login logs
- Account communications
- Privacy requests under:
- CCPA (California Consumer Privacy Act)
- GDPR (General Data Protection Regulation)
- U.S. federal consumer privacy laws
3. Subpoena & Legal Data Request Handling
3.1 Verification
- Subpoenas or legal requests must be:
- Issued by a verifiable U.S. court or legal authority
- Delivered via official email or certified mail
- Reviewed and confirmed by CLO prior to any action
3.2 Response Protocol
- Upon CLO approval:
- CTO gathers only the minimum legally required data
- Data is securely transferred to requesting party
- Member is notified unless a gag order is attached
- Record of compliance is stored in Legal Archive (7 years)
4. Member Privacy Requests (CCPA, GDPR)
4.1 Types of Requests
| Request Type | Response Time |
| Access (What data do you have?) | 30 days |
| Correction (Fix my info) | 30 days |
| Deletion (Forget me) | 30 days |
| Portability (Send me my data) | 30 days |
4.2 Submission
- Member must email:
- Required:
- Proof of account ownership (email verification, ID match if needed)
- Specific request type (access, delete, correct, export)
4.3 Review & Execution
- Legal Ops or Platform Admin processes request
- CTO verifies backend logs, deletes or exports data
- Member is notified once request is completed
5. Data Retention Schedule
| Data Type | Retention Period | Owner |
| Account credentials | While account is active | CTO |
| Affiliate payouts & earnings | 7 years (IRS compliance) | Finance Ops |
| Legal correspondence | 7 years | CLO |
| Customer support tickets | 3 years | Support Admin |
| Video/audio uploads | While course is active | Platform Admin |
| IP logs and system events | 18 months | DevOps |
6. Red Flags & Non-Compliance Prevention
- CrownThrive will not:
- Comply with fake legal requests, non-verified subpoenas, or anonymous demands
- Sell or license user data to third parties
- Delay a user privacy request without legal justification
All staff handling legal data requests must:
- Complete data compliance training
- Use secure folders for all exports
- Log each request with timestamp and resolution
7. Escalation Contacts
| Situation | Escalation Contact |
| Subpoena or court order | CLO â [email protected] |
| GDPR/CCPA privacy request | Privacy Team â [email protected] |
| System-side deletion failure | CTO â [email protected] |
| Retention policy clarification | Legal Ops â [email protected] |
8. Compliance Markers
â Subpoenas reviewed and logged before action â Privacy requests completed within 30 days â Minimum required data shared during legal processes â Deletion and retention policies reviewed quarterly â Data never sold or exploited for marketing
9. Version Control
- Version: 1.0
- Last Updated: July 27, 2025
- Maintained By: CLO + CTO + Privacy Admin
- Next Review Due: January 2026