GDPR Data Retention Policy

This Data Retention Policy is effective on May 25th, 2018

Definitions

The following definitions apply throughout this Data Retention Policy.

Personal Data

Personal data means any information relating to an identified or identifiable natural person that is not also considered to be Sensitive Personal Data, Operational Personal Data, Marketing Personal Data, or Metric Personal Data.

Natural Person

Natural person means one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

HR Personal Data

HR Personal Data means any Personal Data necessary for Human Resources employment purposes according to applicable law.

Sensitive Personal Data

Sensitive Personal Data means any data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or data concerning health or data concerning a natural person’s sex life or sexual orientation.

Operational Personal Data

Operational Personal Data means any personal data that is used by Best Case Leads for the purpose of operating its systems and the Services and includes, but is not limited to, internal identifiers that Best Case Leads’ systems and/or the Services use as references for or to leads, events, clicks, or actions performed by Users.

Metric Personal Data

Metric Personal Data means any personal data that is used by Best Case Leads for the purpose of measuring the performance of its systems and the Services or the systems and services of Best Case Leads’ customers.

Marketing Personal Data

Marketing Personal Data means any personal data that is used by Best Case Leads or Best Case Leads’ customers solely for marketing purposes.

Contract Duration

The Contract Duration is the length of time measured in months from the date a contract or agreement is executed between Best Case Leads and any customer or relevant third party and the date such contract or agreement is terminated.

Retention Period

The Retention Period is the length of time measured in months after which the data to which the Retention Period applies is purged. If the Retention Period is described as Permanent,” the data type is held indefinitely.

Default Retention Periods

As Processor

The following retention period profiles are in effect when Best Case Leads acts as a Data Processor on behalf of any third party who qualifies as a Data Controller. These are default values that may only be changed through a special request and payment for all necessary engineering steps.

Data Category Default Retention Period
Personal Data Contract Duration + 1 month (after last usage)
Operational Personal Data Contract Duration + 1 month (after last usage)
Metric Personal Data Contract Duration + 1 month (after last usage)
Marketing Personal Data Contract Duration + 1 month (after last usage)

 

As Controller

The following retention period profiles are in effect when Best Case Leads collects data as the Data Controller.

Data Category Default Retention Period
Personal Data Contract Duration + 1 month (after last usage)
HR Personal Data Permanent (while in use); As Required by Law
Operational Personal Data Contract Duration + 1 month (after last usage)
Metric Personal Data Contract Duration + 1 month (after last usage)
Marketing Personal Data Contract Duration + 1 month (after last usage)
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