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Data retention schedule

Draft for legal review

This text is not in force yet. Highlighted items wait for an owner decision

How long iCall keeps each kind of data by default, who can change it, and how deletion works. Periods are proposals.

Version 0.1-draft · Updated

Draft for legal review. The periods below are proposals for the owner to confirm (D13, D14). Where the table says "statutory", the exact period must be confirmed with an accountant and a lawyer.

1. Principles

  • We keep data only as long as it is needed for the purpose it was collected for, then delete it.
  • For call content that iCall processes for a business customer, the customer is the controller and sets the retention within the range the product allows. These periods are the defaults and the maximum we apply unless the order form says otherwise.
  • Technical logs must not contain personal content such as the words spoken, full phone numbers or message text.
  • Deleting data means removing it from the database, file storage, search indexes and exports we control. Backups age out on their own cycle (section 4).

2. Schedule

  • Data
    Call audio recordings
    Default retention
    [60 days · to be confirmed]
    Notes
    Only if recording is switched on for the assistant. Customer may shorten it.
  • Data
    Call transcripts and summaries
    Default retention
    [180 days · to be confirmed]
    Notes
    A transcript is kept even where audio is not. Customer may shorten it.
  • Data
    Call metadata (time, duration, numbers, outcome, cost)
    Default retention
    [13 months · to be confirmed]
    Notes
    Needed for billing, usage and reporting. Phone numbers can be masked after 90 days on request.
  • Data
    Operational and technical logs
    Default retention
    [30 days · to be confirmed]
    Notes
    Without call content.
  • Data
    Audit log (who accessed or changed what)
    Default retention
    [12 months · to be confirmed]
    Notes
    Security evidence. Append only.
  • Data
    Demo audio and transcripts (website visitors)
    Default retention
    [30 days audio, 90 days transcript, as in the first privacy draft · to be confirmed]
    Notes
    Planned, with the live voice demo. Anonymous visitors.
  • Data
    Demo and abuse-prevention records (anonymous identifier, risk signal built from a keyed hash of the IP address)
    Default retention
    [30 days · to be confirmed]
    Notes
    Planned, with the live voice demo. The raw IP address is not kept in the application log.
  • Data
    Phone verification code requests
    Default retention
    codes expire after 5 minutes; request records [30 days · to be confirmed]
    Notes
    Planned, with the live voice demo. No code or message text is stored in telemetry.
  • Data
    Account data (names, work email or phone, roles)
    Default retention
    while the account is active, then [30 days after closure · to be confirmed]
    Notes
  • Data
    Contact form requests and sales correspondence
    Default retention
    [12 months from the last contact · to be confirmed]
    Notes
  • Data
    Support tickets
    Default retention
    [24 months after closing · to be confirmed]
    Notes
  • Data
    Invoices, payment status and accounting records
    Default retention
    statutory period [confirm with accountant · to be confirmed]
    Notes
    Georgian accounting and tax rules. No card numbers are held by iCall.
  • Data
    Opt-out and suppression lists
    Default retention
    as long as needed to honour the opt-out [until the customer deletes the contact or the account closes · to be confirmed]
    Notes
    Minimal data (a hash or the number).
  • Data
    Customer knowledge base and assistant settings
    Default retention
    while the account is active, then deleted per section 3
    Notes

3. When the agreement ends

After the agreement ends, the customer can export its data for [30 days · to be confirmed]. When that period ends, we delete the customer's call content and workspace data. Records we must keep by law (for example invoices) stay for the statutory period, separately and only for that purpose.

A business customer can also ask us to delete specific calls or contacts earlier. We confirm in writing when the deletion is done.

4. Backups

Backups are kept for a limited cycle, and deleted data leaves the backups when they expire, which happens within [35 days · to be confirmed] of the deletion from the live system. Data in a backup is not used for anything else and is deleted again if a backup is restored. Backup and restore testing is a planned practice [confirm the backup plan before launch · to be confirmed].

5. Legal hold and exceptions

We may keep data longer if the law or a competent authority requires it, or if it is needed to establish, exercise or defend a legal claim, and only for as long as that need lasts. In that case we limit access to the data.

6. Subprocessors

Our subprocessors delete data under the terms of their contract with us, and in line with the periods above. The current list is in the DPA.

7. Asking for earlier deletion

If you are a caller and want data about you deleted, contact the business you called. If you are a visitor to our website or a demo user, write to [privacy contact email · to be confirmed]. See the privacy policy for your rights.