Legal

5.8 DATA LIFECYCLE, RETENTION, AND DEFENSIBLE DELETION POLICY

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Effective Date: August 15, 2026


1. RETENTION PRINCIPLE

The Platform retains Personal Data only for as long as reasonably necessary and proportionate to fulfill the purposes for which it was collected, including the provision of Services, compliance with legal obligations, resolution of disputes, enforcement of agreements, and protection of the Platform’s legitimate business interests, security posture, and operational resilience.

The Platform determines retention periods based on criteria including data sensitivity, risk of harm from unauthorized use, regulatory requirements, and the necessity of the data for providing reliable and secure Services. Retention practices are designed to support defensible data governance and responsible lifecycle management consistent with modern cloud service expectations. The Platform maintains internal documentation supporting its retention decisions where appropriate.

Retention periods are designed to ensure that Personal Data is not kept longer than necessary while allowing the Platform to meet its legal, security, and operational obligations.

2. RETENTION SCHEDULE

The Platform applies standard retention periods to different categories of data. These periods are designed to balance service availability with data minimization principles. Nothing in this Policy shall be interpreted as creating an obligation to retain data for the benefit of the User beyond what is operationally necessary or legally required.

2.1 Representative Retention Framework

The following table provides a representative framework of standard retention ranges applied by the Platform. Actual retention periods may vary at the Platform’s sole reasonable discretion depending on legal requirements, security needs, contractual obligations, or legitimate business interests.

The Platform may retain data for longer periods where necessary to comply with legal obligations or establish, exercise, or defend legal claims.

3. ACCOUNT DATA & USER DELETION

3.1. Active Accounts.

Personal Data associated with an active account is retained for the duration of the contractual relationship between the User and the Platform. Upon account termination, such data will be deleted or anonymized within a commercially reasonable period unless retention is required or permitted by law. The timing of deletion may vary depending on system architecture, backup cycles, legal obligations, fraud prevention requirements, and operational constraints.

3.2. User-Initiated Deletion.

Users may request deletion of their Personal Data at any time through the account interface or by contacting the Platform. The Platform may retain limited information necessary to:

  • Comply with legal and regulatory obligations.

  • Satisfy accounting, tax, and financial reporting requirements.

  • Detect or prevent fraud, abuse, or security incidents.

  • Resolve disputes or enforce contractual rights.

  • Ensure the integrity and continuity of system architecture, backups, and audit trails.

Retained data will be limited to what is reasonably necessary and proportionate for these purposes and will remain subject to appropriate security protections. Where deletion would require disproportionate technical effort or would materially impair system security or integrity, the Platform may instead implement measures designed to render the data permanently inaccessible.

Where obligations relating to platform security, fraud prevention, or legal compliance conflict with a deletion request, the Platform’s security and compliance obligations shall take precedence where legally justified and to the extent permitted by applicable law.

4. BACKUP AND SYSTEM RESIDUALS

Deleted data may persist in encrypted backups, disaster recovery systems, or archival media for a limited period. Such data will remain isolated from active processing (except where restoration is required for security testing, disaster recovery validation, or legal compliance) and will be automatically overwritten in accordance with the Platform’s backup lifecycle policies (typically 30–90 days, but potentially longer where required for security, legal compliance, or disaster recovery integrity).

Retained backup data is not used for operational decision-making, profiling, or active service delivery.

5. INACTIVE ACCOUNTS & TIER TRANSITIONS

5.1. Inactivity.

The Platform reserves the right to classify accounts as inactive after a prolonged period without login activity (for example, but not limited to, 12 months). The Platform may initiate a structured deletion process, which may include prior notice where reasonably feasible. Failure to respond to such notice may result in permanent deletion of the account and associated data. The Platform is not obligated to provide multiple notices prior to deletion where doing so would create disproportionate operational burden or security risk.

5.2. Storage Tier Transitions.

If an account is downgraded to a free or restricted tier due to non-payment or subscription changes, the Platform may limit storage capacity. Data exceeding the permitted quota may become inaccessible and subject to deletion following a defined grace period. The duration of any grace period is determined by the Platform in its sole reasonable discretion unless otherwise specified in a service agreement. The Platform is not responsible for data loss resulting from the User’s failure to maintain an appropriate subscription level.

The User acknowledges that maintaining an appropriate subscription tier is their responsibility, and the Platform has no duty to preserve data that exceeds applicable service limits. The existence of billing disputes, renewal discussions, or contract negotiations does not obligate the Platform to extend retention beyond the defined grace period unless expressly agreed in writing.

6. OPERATIONAL & AGGREGATED DATA

6.1. Service-Generated Metadata.

Operational metadata—including system logs, access records, diagnostic events, and security telemetry—may be retained for longer periods (see Schedule) when reasonably necessary and proportionate to ensure platform stability, abuse prevention, forensic capability, and infrastructure reliability, including for threat detection, behavioral analysis, and preventative security measures.

6.2. Aggregated and Irreversible Data.

The Platform may retain data that has been anonymized, aggregated, or irreversibly de-identified. Such data no longer constitutes Personal Data and may be used for analytics, security modeling, service improvement, and business intelligence. This may include the use of derived datasets that do not reasonably permit the identification of any individual.

Where data is subject to a legal hold, regulatory request, investigation, or dispute, the Platform may suspend the standard deletion process until the matter is fully resolved. This Legal Hold overrides all standard retention schedules and may remain in effect until the Platform determines, in its sole reasonable discretion, that the underlying matter has been fully resolved. The Platform may also preserve data where it reasonably believes such preservation is necessary to anticipate or defend against potential legal claims. The Platform may further retain data as necessary to support internal investigations, policy enforcement, security incident response, or risk management activities.

8. THIRD-PARTY PROCESSING

Where Personal Data has been shared with authorized subprocessors (see Document 5.6), the Platform will instruct such parties to delete or return the data in accordance with contractual obligations, unless continued storage is legally required.

9. LIMITATIONS & USER RESPONSIBILITY

9.1. Deletion Limitations.

Deletion requests apply only to Personal Data controlled by the Platform. Users remain responsible for deleting data they have exported, shared, or independently transferred outside the Platform environment.

9.2. Restoration Limitation.

Once deletion is completed (and any applicable grace period has expired), restoration of the data may not be possible. The User acknowledges sole responsibility for exporting or backing up any data prior to submitting a deletion request or closing an account. The Platform is under no obligation to restore data following deletion, even where such deletion results from user error, account misconfiguration, or service tier changes.

10. SECURE DISPOSAL

The Platform implements commercially reasonable technical and organizational measures consistent with generally accepted industry standards designed to ensure secure deletion of Personal Data, including logical erasure, cryptographic methods (crypto-shredding), or destruction of storage media where appropriate.

Secure deletion methods may vary depending on the underlying technology, storage architecture, and data environment. Not all deletion methods require physical media destruction where logical or cryptographic techniques achieve equivalent protection.

11. POLICY UPDATES

Retention periods may be modified to reflect legal, operational, or technological developments. Material changes will be communicated in accordance with the Platform’s notification procedures. Continued use of the Services following such updates constitutes acceptance of the revised retention practices to the extent permitted by applicable law.

12. TRANSITIONAL STORAGE STATE

If a User account enters suspension due to non-payment, policy violations, or security concerns, the Platform may place associated data into a restricted transitional storage state prior to deletion. During this period, data may remain inaccessible to the User but preserved to support reinstatement, legal compliance, fraud prevention, or dispute resolution.

The duration of such transitional states is determined by operational and legal requirements.

13. NO GUARANTEE OF DATA PRESERVATION

While the Platform implements commercially reasonable safeguards designed to protect data, the User acknowledges that no system can be guaranteed to be completely free from deletion risks, corruption, cyber incidents, hardware failures, or unforeseen operational events.

The Platform does not guarantee indefinite data preservation and expressly disclaims any obligation to store data beyond the defined retention periods. Users are solely responsible for maintaining independent backups of any data they consider critical. The User acknowledges that data retention and deletion processes operate within complex distributed systems and may not occur instantaneously.

14. CONTROLLER AND PROCESSOR ROLES

Where the Platform processes Personal Data on behalf of a customer acting as a data controller, retention periods may be determined by the customer’s documented instructions, contractual terms, or applicable Data Processing Agreements.

The Platform shall not be responsible for defining retention obligations where it acts solely as a processor, except as required to comply with applicable law or protect the security and integrity of the Services.

15. JURISDICTIONAL RETENTION REQUIREMENTS

Retention periods may be adjusted where required to comply with applicable laws, regulatory obligations, governmental requests, or lawful orders in relevant jurisdictions.

Where multiple legal frameworks apply, the Platform reserves the right to retain data for the longest period required to ensure compliance and mitigate legal risk.

16. BUSINESS CONTINUITY AND PLATFORM SAFETY

The Platform may retain or isolate data where reasonably necessary to ensure business continuity, maintain service availability, protect platform infrastructure, or prevent widespread service disruption.

Such retention shall be limited to what the Platform determines is operationally necessary. Such measures are intended to support platform-wide stability rather than preserve individual datasets.

17. FORCE MAJEURE AND UNCONTROLLABLE EVENTS

Notwithstanding anything to the contrary, the Platform shall not be responsible for data loss, corruption, delay, or retention failure resulting from events beyond its reasonable control, including but not limited to natural disasters, acts of government, war, terrorism, cyberattacks of extraordinary sophistication, widespread internet failures, power grid disruptions, or failures of critical third-party infrastructure.