Data Retention Policy

Last updated: May 16, 2025

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This Data Retention Policy describes how Ulvinka collects, stores, and deletes personal and operational data generated through the use of its platform and services. By using our services, you acknowledge the practices described in this document.

1. Purpose and Scope

This policy applies to all data collected by Ulvinka through its website, platform, and associated services. It covers data relating to registered users, session participants, facilitators, and visitors. The purpose of this policy is to ensure that data is retained only for as long as necessary to fulfil the purposes for which it was collected, and that it is securely deleted or anonymised thereafter.

2. Types of Data We Collect

2.1 Account and Identity Data

This includes information provided during registration such as name, email address, contact details, and account credentials. This data is used to maintain your account and provide access to the platform.

2.2 Usage and Session Data

This includes records of activity within the platform such as session attendance, interaction logs, participation records, and feature usage. This data is used to improve service quality and support facilitation processes.

2.3 Communication Data

This includes messages, feedback submissions, and support correspondence submitted through the platform or contact channels. This data is used for service delivery and quality assurance.

2.4 Technical and Device Data

This includes IP addresses, browser type, device identifiers, and log files generated automatically during use of the platform. This data is used for security monitoring, troubleshooting, and performance analysis.

2.5 Payment and Transaction Data

This includes billing information, transaction identifiers, and purchase history. Sensitive financial details such as full card numbers are processed by third-party payment providers and are not stored on our systems.

3. Retention Periods

Data is retained for the minimum period necessary to fulfil its original purpose, comply with legal obligations, and support legitimate business operations. The table below summarises standard retention periods by data category.

Data Category	Retention Period	Basis for Retention
Account and identity data	Duration of account plus 24 months after closure	Contractual obligation and service continuity
Usage and session data	24 months from date of activity	Service improvement and legitimate interests
Communication and support data	36 months from last interaction	Customer support and dispute resolution
Technical and device data	12 months from collection	Security monitoring and system integrity
Payment and transaction data	7 years from transaction date	Financial and legal compliance obligations
Marketing preferences	Until withdrawal of consent or account closure	Consent-based processing
Anonymised and aggregated data	Indefinite	Statistical analysis, no personal identifiers

4. Legal and Compliance Retention

Certain categories of data may be retained beyond the standard periods described above where required by applicable law, regulatory obligation, or to establish, exercise, or defend legal claims. In such cases, access to the data is restricted to authorised personnel and the data is not used for any other purpose during the extended retention period.

5. Data Deletion and Anonymisation

5.1 Deletion Process

When the applicable retention period expires, data is scheduled for secure deletion. Deletion processes are applied to live systems, backups, and archived storage within a reasonable operational timeframe. The deletion of data from backup systems may take up to 90 days due to scheduled backup cycles.

5.2 Anonymisation

Where complete deletion is not practicable or where aggregated insights are required for service improvement, personal data may be anonymised rather than deleted. Anonymised data cannot be used to identify any individual and is not subject to the same retention limits as personal data.

6. User Rights and Data Requests

You have the right to request access to, correction of, or deletion of your personal data at any time. Requests to delete data are processed in accordance with this policy and applicable legal obligations. Where a legal basis requires us to retain data beyond your requested deletion date, we will inform you of the reason and the applicable period.

To submit a data request, contact us at contact@Ulvinka.com. We aim to respond to all requests within 30 days of receipt.

7. Data Stored by Third Parties

Our platform may use third-party service providers for functions such as payment processing, communication tools, and infrastructure hosting. Data shared with these providers is governed by their respective retention policies. We endeavour to ensure that all third-party providers apply retention standards consistent with this policy and applicable data protection requirements.

8. Backup and Archival Storage

Data held in backup and archival systems is subject to the same retention periods as live data. Where a retention period expires, data is flagged for removal during the next applicable backup rotation cycle. Backup systems are not used to restore or access data that has reached the end of its retention period in the live environment.

9. Security During Retention

All retained data is protected by appropriate technical and organisational measures throughout its retention period. These measures include access controls, encryption at rest and in transit, and regular security reviews. Access to retained data is limited to personnel who require it for legitimate operational purposes.

10. Policy Review and Updates

This policy is reviewed periodically and updated as necessary to reflect changes in our practices, services, or applicable legal requirements. The date at the top of this document indicates when the policy was last revised. Continued use of our services following an update constitutes acceptance of the revised policy.

11. Contact Information

If you have questions about this Data Retention Policy or wish to exercise your data rights, you may contact us using the details below.