Data Retention & Deletion Policy
Effective Date: January 1, 2023
Last Updated: December 11, 2024
1. Purpose
This Data Retention & Deletion Policy outlines how Coropos Web Services collects, stores, retains, and deletes personal and business data. This policy ensures compliance with privacy regulations including GDPR, CCPA, and other applicable data protection laws.
2. Scope
This policy applies to all data collected, processed, or stored by Coropos Web Services, including:
- Client account information
- Website visitor data
- Project files and assets
- Communications and support tickets
- Payment and billing information
- Analytics and usage data
- Backup and archived data
3. Data Categories and Retention Periods
3.1 Account and Profile Data
- Type: Name, email, phone, company information, login credentials
- Retention Period: Duration of account existence + 7 years after account closure
- Legal Basis: Contract fulfillment, legal obligations (tax, accounting)
- Deletion: 7 years after account closure or upon written request if no legal obligation exists
3.2 Billing and Payment Data
- Type: Invoices, payment history, credit card tokens (tokenized only - we never store full card numbers)
- Retention Period: 7 years from transaction date
- Legal Basis: Tax and accounting compliance, fraud prevention
- Deletion: 7 years after final transaction (required by tax laws)
3.3 Project Files and Deliverables
- Type: Website code, design files, logos, images, content
- Retention Period: 90 days after project completion for active clients; 1 year after account closure
- Legal Basis: Contract fulfillment, legitimate business interest
- Deletion: Automated deletion after retention period unless extended storage is purchased
3.4 Website Backups
- Type: Full website backups including database and files
- Retention Period:
- Daily backups: 30 days
- Weekly backups: 90 days
- Monthly backups: 12 months (premium plans only)
- Legal Basis: Legitimate business interest, service provision
- Deletion: Automatic rolling deletion per backup schedule
3.5 Support and Communication Data
- Type: Support tickets, emails, chat logs, phone call notes
- Retention Period: 3 years from last communication
- Legal Basis: Legitimate business interest, quality assurance
- Deletion: Automated deletion after 3 years; redaction of personal details after 1 year
3.6 Marketing and Analytics Data
- Type: Website analytics, email campaign metrics, cookie data
- Retention Period: 26 months maximum (Google Analytics default)
- Legal Basis: Consent, legitimate business interest
- Deletion: Automatic deletion after 26 months; immediate deletion if consent withdrawn
3.7 Email Data (Google Workspace)
- Type: Emails stored in client Google Workspace accounts
- Retention Period: Under client control; our backups retain 30 days
- Legal Basis: Contract fulfillment
- Deletion: Client-managed; our backups follow standard backup retention
3.8 Security and Access Logs
- Type: Server logs, access logs, security event logs
- Retention Period: 90 days for routine logs; 2 years for security incidents
- Legal Basis: Legitimate business interest, security, legal compliance
- Deletion: Automated rolling deletion; security incident logs retained for investigation
4. Data Deletion Procedures
4.1 Automated Deletion
We employ automated systems to delete data according to retention schedules:
- Daily automated scans identify data past retention periods
- Secure deletion processes remove data from active systems
- Backup systems are purged according to backup retention schedules
- Deletion logs are maintained for compliance auditing
4.2 Manual Deletion Requests
Clients may request early deletion of personal data by:
- Emailing privacy@coroposws.com with deletion request
- Providing account verification information
- Specifying which data should be deleted
- Acknowledging that deletion may affect service availability
4.3 Deletion Timeline
- Active Systems: Within 30 days of request
- Backup Systems: Up to 90 days (next backup rotation cycle)
- Archived Data: Up to 180 days
- Legal Hold Data: Cannot be deleted until legal obligation expires
4.4 Secure Deletion Methods
- Database records: Permanent deletion with no recovery option
- File systems: Secure overwrite using industry-standard algorithms
- Backups: Removal from backup sets with verification
- Cloud storage: Cryptographic erasure and account removal
- Physical media: Destruction following NIST 800-88 guidelines (when applicable)
5. Right to Erasure ("Right to be Forgotten")
5.1 GDPR Rights
Under GDPR, EU residents have the right to request deletion of personal data when:
- The data is no longer necessary for the purpose it was collected
- Consent is withdrawn and there is no other legal basis for processing
- You object to processing and there are no overriding legitimate grounds
- The data has been unlawfully processed
- Deletion is required for compliance with legal obligations
5.2 Exceptions to Right to Erasure
We may refuse deletion requests when data retention is required for:
- Compliance with legal obligations (tax records, financial reporting)
- Defense against legal claims
- Exercise of freedom of expression and information
- Public interest or official authority tasks
- Archiving purposes in the public interest
6. Data Portability
Before deletion, clients have the right to receive their data in a structured, commonly used format:
- Account Data: Exported as JSON or CSV
- Website Files: Provided as ZIP archive
- Database: Exported as SQL dump
- Emails: Exported via IMAP or provided as PST/MBOX files
- Delivery Time: Within 30 days of request
7. Account Closure and Data Deletion
7.1 Voluntary Account Closure
When you close your account voluntarily:
- Immediate: Account access disabled, services suspended
- 30 days: Active data archived
- 90 days: All backups purged except long-term retention items
- 7 years: Financial records deleted (per legal requirements)
7.2 Involuntary Account Closure
If we close your account for Terms of Service violations:
- Immediate access suspension
- Data retention for investigation purposes (up to 2 years)
- Standard deletion schedules apply after investigation period
- Financial records retained per legal requirements
7.3 Inactive Accounts
- Definition: No login or service activity for 24 months
- Notification: Email notice 30 days before account deactivation
- Deactivation: Account suspended, data enters deletion schedule
- Recovery: 90-day grace period to reactivate before permanent deletion
8. Third-Party Data Processing
8.1 Subprocessor Data Retention
Third-party services we use have their own retention policies:
- Google Workspace: Client-controlled retention
- Payment Processors: Minimum 7 years per PCI-DSS requirements
- Analytics Providers: 26 months (Google Analytics)
- CDN Services: 90 days for logs
We ensure all subprocessors comply with applicable data protection laws.
8.2 Data Processing Agreements
We maintain Data Processing Agreements (DPAs) with all subprocessors that:
- Define retention and deletion obligations
- Require secure deletion upon contract termination
- Mandate compliance with data protection regulations
- Include audit rights for compliance verification
9. Legal and Compliance Retention
9.1 Legal Hold
Data subject to legal proceedings or investigations:
- Placed on "legal hold" - automatic deletion suspended
- Retained until legal obligation expires
- Secured separately from active data
- Access restricted to authorized personnel only
9.2 Regulatory Requirements
We comply with retention requirements including:
- IRS: 7 years for tax-related records
- PCI-DSS: Minimum 7 years for payment records
- State Laws: Varying requirements (longest period applied)
- GDPR: Storage minimization principle
10. Breach Response and Data Deletion
In the event of a data breach:
- Compromised data is immediately isolated
- Affected users notified within 72 hours (GDPR requirement)
- Unauthorized copies deleted wherever possible
- Breach response documented and retained for 5 years
- Post-breach review may lead to early deletion of affected data types
11. Employee and Contractor Data
Data related to employees and contractors follows different retention schedules:
- Employment Records: 7 years after employment termination
- Payroll Data: 7 years per IRS requirements
- Performance Reviews: 3 years after termination
- Access Logs: 2 years after termination
12. Data Minimization
We practice data minimization by:
- Collecting only data necessary for service provision
- Regularly reviewing data categories for necessity
- Implementing "privacy by design" in new features
- Anonymizing data when personally identifiable information is not required
- Automatically purging temporary data (caches, session data) within 24 hours
13. Client Responsibilities
Clients are responsible for:
- Managing data retention settings in their own systems
- Downloading backups before account closure if needed
- Understanding that deleted data cannot be recovered
- Notifying us of any data subject requests from their users
- Complying with retention requirements for their own industry/jurisdiction
14. Audit and Compliance
14.1 Internal Audits
- Quarterly review of retention compliance
- Annual comprehensive data inventory
- Verification of automated deletion processes
- Review of subprocessor compliance
14.2 Documentation
We maintain records of:
- Data categories and retention periods
- Deletion requests and completion dates
- Legal holds and their justifications
- Subprocessor agreements and DPAs
- Data breach incidents and responses
15. Policy Updates
This policy is reviewed annually and updated as needed for:
- Changes in applicable laws
- New service offerings
- Technology updates
- Best practice evolution
Material changes will be communicated 30 days in advance.
16. Contact Information
For data retention, deletion, or portability requests:
This Data Retention & Deletion Policy is part of our Privacy Policy and Terms of Service. By using our services, you acknowledge and agree to these data retention and deletion practices.