Data Processing Addendum
For organisations that run groups.
Last updated September 25, 2026. This addendum is part of the terms for any organisation on the organiser plan. Buying or using the plan accepts it. If you need a signed copy, email hello@lorewheel.com.
1. Who this is between
You are the school, camp, club or other organisation that buys the organiser plan. You're the controller: you decide which groups exist and who's in them. We are Media Yard LLC, PO Box 73, Pennsauken, NJ 08110, United States. We're the processor: we handle your groups' data only to run Lorewheel for you. The definitions in the GDPR, the UK GDPR and, where they apply, US state privacy laws have the same meaning here.
2. What we process
- Subject matter and purpose: keeping your groups' online Almanacs, showing your organiser dashboard, running Cabin Cups, and making the Season Yearbooks you order.
- Duration: for as long as you have the plan, then as set out in section 9.
- People: your groups' members, who may include children, and the adults who run them.
- Data: group names; the lines, first names or nicknames, dates, candles, night cards and Legacy Letter recordings your groups add; counts and dates of use; and, for a hardcover Season Yearbook, the delivery name, address and phone number you give.
- Special categories: none. Lorewheel doesn't ask for them, and your groups shouldn't add them.
3. Your instructions
We process your data only on your documented instructions: these terms, this addendum, and what you do in Lorewheel. The only exception is where the law requires otherwise, and then we'll tell you first unless the law forbids it. We'll tell you if we think an instruction breaks data protection law. We never sell your data, use it for advertising or profiling, or use it to train AI.
4. Confidentiality
Only people who need access to run Lorewheel have it, and they're bound to keep your data confidential.
5. Security
We keep technical and organisational measures that suit the risk, including:
- encryption in transit (HTTPS);
- storing group links, sign-in links and sessions only as one-way fingerprints;
- an adult sign-in with a confirmation of age and permission before any device can open an online Almanac;
- least-privilege access to production systems;
- deleting data on the schedules on our privacy page.
6. Sub-processors
You authorise these sub-processors:
- Cloudflare, Inc. (US): hosting and storage.
- Resend (US): sign-in emails.
- Stripe, Inc. and Link (US): payment for the plan and for Season Yearbooks.
- Lulu Press, Inc. (US): printing and posting hardcover Season Yearbooks.
We'll give at least 30 days' notice on this page before adding or replacing a sub-processor. You can object on reasonable data protection grounds; if we can't resolve it, you may cancel and get a refund of the unused part of the plan. Each sub-processor is bound by data protection terms at least as protective as this addendum, and we stay responsible for them.
7. International transfers
We and our sub-processors are in the United States. For personal data from the EU or the EEA, the European Commission's Standard Contractual Clauses (Decision 2021/914, Module Two, controller to processor) apply. They are incorporated into this addendum by reference, with Clause 7 not used, option 2 in Clause 9 with the notice period in section 6, the optional wording in Clause 11 not used, and Irish law and courts for Clauses 17 and 18. The details in sections 2, 5 and 6 fill in Annexes I to III. For personal data from the UK, the UK Information Commissioner's International Data Transfer Addendum also applies. For Swiss data, the Clauses apply with the Swiss FDPIC as the supervisory authority.
8. Helping you
We'll help you, as far as we reasonably can:
- answer requests from people exercising their rights (you can also delete an Almanac from inside Lorewheel at any time);
- with data protection impact assessments and consultations with regulators.
If we become aware of a personal data breach affecting your data, we'll tell you without undue delay, and within 48 hours where we can. We'll give you what we know and keep you updated.
9. When the plan ends
When the plan ends, your organisation and its groups keep the data as described on the privacy page. Almanacs are deleted after 18 months without use, or at once when you or a group deletes them. If you ask us to delete everything sooner, we'll do it within 30 days, unless the law requires us to keep something.
10. Audits
We'll make available the information you reasonably need to show that we meet this addendum, and answer written questions within 30 days. If that isn't enough, or a regulator requires it, we'll allow an audit by you or an independent auditor bound by confidentiality. You give 30 days' notice, it happens no more than once a year unless there's been a breach, and it's at your cost.
11. US schools and student data
If you're a US school or district:
- We act as a "school official" with a legitimate educational interest under FERPA, under your direct control over the use of education records.
- We use student data only to provide Lorewheel, never for targeted advertising, building profiles, or sale.
- You're responsible for giving any parental notice and getting any consent that COPPA or your state's student privacy law requires. The adult sign-in in Lorewheel asks the adult opening an Almanac on a device to confirm they have that permission.
If your state requires its own student data privacy agreement, email us and we'll consider signing it.
12. How this fits with the terms
If this addendum conflicts with the terms, this addendum wins for personal data. If it conflicts with the Standard Contractual Clauses, the Clauses win. The liability limits in the terms apply to this addendum, as far as the law and the Clauses allow.