Data Deletion & Retention Policy

This Data Deletion & Retention Policy explains how Pivot Technologies Holdings Inc. ("Pivot") deletes and retains customer data in the Pivot Services, including timelines for deletion from active systems and backups, and how customers can export, delete, and request erasure of data.

1. Purpose

This policy describes the lifecycle of Customer Data — from creation to deletion — and provides transparency about Pivot’s data retention periods.

2. Scope

This policy applies to Customer Data that Pivot processes as a processor on behalf of customers under the Data Processing Addendum (DPA) and Agreement. For Pivot’s own website or account data where Pivot is a controller, see the Privacy Policy.

3. Key Definitions

• Customer Data: Personal data that customers and their users submit to the Services.
• Active systems: Production databases, storage, and search indexes used to operate the Services.
• Backups: Encrypted disaster‑recovery copies not used for day‑to‑day processing.
• Soft delete: Data is placed in a trash/recycle state and recoverable by admins for a limited time.
• Permanent delete: Data is irreversibly removed from active systems and later expires from backups.

4. Overview (At a Glance)

• Customer deletes content
• Soft delete to trash; recoverable by workspace/org admins (if enabled).
• Timeframe: 7–30 days (configurable).
• Permanent deletion from active systems
• Purged from production databases, search indexes, and caches.
• Timeframe: ≤ 30 days.
• Backup expiration
• Encrypted backups age out and are overwritten on a rolling schedule.
• Timeframe: ≤ 90 days after active deletion.
• Account termination
• Customer may request data export before full deletion; same deletion timelines apply.
• Timeframe: Export on request; deletion within 30/90 days.
• Sub-processors
• Instructed to delete data on equivalent or faster timelines.
• Timeframe: Aligned with 30/90-day standard.

5. Retention & Deletion Details

5.1 Default Retention

Pivot retains Customer Data for the duration of the Agreement unless the Customer configures shorter retention windows (where features exist) or requests deletion.

5.2 Customer‑Initiated Deletion

• Item‑level delete: Users with appropriate permissions can delete messages, posts, files, or rooms/spaces. Deleted items enter soft delete for 7–30 days and may be restored by admins (if supported). After this window, items are permanently deleted from active systems.
• Workspace/org delete: Org owners can request deletion of a space or an entire organization. Pivot will confirm ownership and begin permanent deletion. 5.3 Account Termination

Upon contract termination or Customer request, Pivot will return or delete Customer Data. Deletion occurs from active systems within 30 days and from backups within 90 days of active deletion. Written confirmation available upon request.

5.4 Backups

Backups are encrypted and used only for disaster recovery. Deletions propagate as backups naturally expire. Pivot does not edit or restore individual records within backups.

5.5 Legal Holds

If Customer instructs Pivot to preserve specific data for legal reasons and it is technically feasible, Pivot will suspend deletion until the hold is released.

5.6 Exceptions

Certain records (e.g., billing, tax, or security logs) may be retained as required by law or to protect Pivot’s rights, detect abuse, or comply with audit obligations. Access is restricted.

6. Customer Controls

• Export: Customers can export data in supported formats (CSV/JSON/ZIP) using in‑product tools or by contacting [email protected].
• Retention settings: Where available, org owners/admins can configure retention settings.
• Administrative restore: Admins may restore deleted items during the soft‑delete window.
• APIs: Admins can automate export or deletion via APIs.

7. Data Subject Requests (GDPR/CCPA, etc.)

When Pivot acts as a processor, we will direct Data Subject requests (access, deletion/erasure, portability, restriction) to the relevant Customer (the controller) and assist as described in the DPA. Customers should submit authorized requests to [email protected] with sufficient detail to identify the data.

8. Sub‑processors

Pivot requires Sub‑processors to implement deletion processes and timelines equivalent to or faster than Pivot’s. The current Sub‑processor list is available at /legal/subprocessors.

9. Verification & Auditability

• Deletion operations are logged and subject to access controls.
• Pivot can provide attestation that Customer Data was deleted per this policy upon request from an authorized Customer representative.
• Where available, Pivot may provide summaries of independent security assessments.

10. Security of Deletion

• Data in transit is protected with TLS 1.2+; data at rest uses AES‑256 (or equivalent).
• Media sanitization follows cloud provider standards.
• Access is controlled via least‑privilege and MFA requirements for production systems.

11. Service Restoration

If a Customer requests restoration from backups after accidental deletion or a disaster event, Pivot may restore the latest backup snapshot at the environment or dataset level, subject to disaster‑recovery procedures and reasonable limits.

12. Changes

Pivot may update this policy to reflect changes in laws, standards, or Services. Material changes will be communicated via [email protected] and the "Last updated" date will be revised.

Appendix A — Object Retention

Messages and comments

• Soft-delete window: 7–30 days

• Permanent deletion (active): ≤ 30 days

• Backups TTL: ≤ 90 days Files and uploads

• Soft-delete window: 7–30 days

• Permanent deletion (active): ≤ 30 days

• Backups TTL: ≤ 90 days Rooms, spaces, and projects

• Soft-delete window: 7–30 days

• Permanent deletion (active): ≤ 30 days

• Backups TTL: ≤ 90 days User accounts

• Soft-delete window: n/a

• Permanent deletion (active): ≤ 30 days after account deletion

• Backups TTL: ≤ 90 days Audit logs

• Soft-delete window: n/a

• Permanent deletion (active): 12–24 months (security/ops)

• Backups TTL: ≤ 90 days

Appendix B — How to Request Deletion or Export

1. Submit requests via [email protected] or the Help & Support section.
2. Provide organization name, workspace/space URL, and a description of the data to delete or export.
3. Pivot will verify requestor identity and authorization before taking action.
4. Pivot will respond without undue delay and within applicable legal timeframes.