Data Retention Policy
Last updated: 13 octobre 2024
This Data Retention Policy describes how Trackfloworavex collects, stores, and removes personal and operational data generated through the use of our platform and services. By using our services, you acknowledge the practices described in this document.
1. Purpose
Trackfloworavex retains data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, resolve disputes, and enforce our agreements. This policy establishes clear timelines and procedures for the retention and deletion of data across all categories.
2. Scope
This policy applies to all data processed by Trackfloworavex in connection with the delivery of its online education platform and related services. It covers data relating to registered users, visitors, and any individuals whose information is processed as part of service delivery.
3. Categories of Data and Retention Periods
3.1 Account and Registration Data
Data collected during account creation, including name, email address, and authentication credentials, is retained for the duration of the active account relationship. Upon account deletion, this data is removed within 30 days, except where retention is required by applicable obligations.
3.2 Learning Activity and Progress Data
Records of course progress, completed lessons, assessment results, and engagement history are retained for the lifetime of the user account plus 12 months following account closure. This period allows users to request certificates or transcripts after leaving the platform.
3.3 Payment and Billing Data
Transaction records, invoices, and billing history are retained for a minimum of 7 years from the date of the transaction. This retention period reflects standard financial recordkeeping requirements applicable to commercial service providers.
3.4 Technical and Log Data
Server logs, access records, error reports, and diagnostic data are retained for a maximum of 90 days. Aggregated and anonymized derivatives of this data may be retained indefinitely for performance analysis and service improvement.
3.5 Communication Records
Support tickets, email correspondence, and in-platform messages are retained for 2 years from the date of last interaction. Records related to unresolved disputes may be retained until final resolution.
3.6 Marketing and Consent Data
Records of user consent for marketing communications, including opt-in timestamps and preference selections, are retained for the duration of the consent relationship plus 3 years following withdrawal or account closure.
3.7 Anonymized and Aggregated Data
Data that has been irreversibly anonymized so that it can no longer be attributed to any individual is not subject to retention limits and may be retained and used indefinitely for research, analytics, and product development purposes.
4. Retention Schedule Summary
| Data Category | Retention Period |
|---|---|
| Account and registration data | Duration of account + 30 days post-deletion |
| Learning activity and progress | Duration of account + 12 months |
| Payment and billing records | 7 years from transaction date |
| Technical logs and access records | 90 days |
| Support and communication records | 2 years from last interaction |
| Marketing consent records | 3 years after consent withdrawal |
| Anonymized and aggregated data | Indefinite |
5. Data Deletion Procedures
5.1 Automated Deletion
Trackfloworavex employs automated processes to identify and remove data that has reached the end of its applicable retention period. These processes run on a scheduled basis and are subject to internal audit to confirm accuracy and completeness.
5.2 Manual Review
Certain categories of data, particularly those associated with ongoing legal matters or unresolved disputes, are subject to manual review before deletion. Deletion of such data is deferred until the relevant matter is concluded.
5.3 Backup Systems
Data deleted from primary systems may persist in encrypted backup storage for up to 60 additional days before being purged from backup archives. During this period, backup data is not accessible for operational use.
6. Legal Holds
When Trackfloworavex becomes aware of litigation, regulatory inquiry, or other legal proceedings that require the preservation of specific data, a legal hold will be applied. Data subject to a legal hold is exempt from standard retention schedules and will be retained until the hold is formally lifted by authorized personnel.
7. User Rights Regarding Retained Data
Users may submit requests to access, correct, or delete their personal data. Deletion requests will be honored within the timeframes established by this policy, subject to the following limitations:
- Data required for the completion of an active transaction or service cannot be deleted until the relevant obligation is fulfilled.
- Data subject to a legal hold cannot be deleted until the hold is released.
- Data that has been anonymized is no longer attributable to any individual and falls outside the scope of deletion requests.
To submit a data request, contact us at contact@trackfloworavex.com.
8. Third-Party Data Processors
Where Trackfloworavex engages third-party service providers to process data on its behalf, those providers are required by contract to adhere to retention and deletion standards consistent with this policy. Trackfloworavex conducts periodic reviews of third-party data handling practices to verify compliance.
9. Security During Retention
All retained data is protected using appropriate technical and organizational measures, including encryption at rest and in transit, access controls, and activity monitoring. The level of protection applied is proportionate to the sensitivity of the data and the risks associated with its retention.
10. Policy Review and Updates
This policy is reviewed at least annually and updated as necessary to reflect changes in our services, data processing practices, or applicable requirements. Material changes will be communicated to users through the platform or by email. Continued use of the platform following notification of changes constitutes acceptance of the revised policy.
11. Contact
For questions or concerns regarding this Data Retention Policy, please contact Trackfloworavex using the details below:
Trackfloworavex
51 Rue Lamalgue, 83000 Toulon, France
Email: contact@trackfloworavex.com
Phone: +33 1 34 42 75 56