Data Retention and Deletion Policy
Last updated: October 22, 2026
Effective since October 22, 2026
1. Introduction
This Policy describes how long cepaos LLC retains different types of data and the secure deletion process upon termination.
It supplements our Privacy Policy and the Terms of Service.
2. Retention Table by Data Type
| Data type | Retention period | Basis / Reason |
|---|---|---|
| Account data | Contract duration + 30 days | Service provision |
| Vineyard and cellar operational data | Contract duration + 5 years | INV obligation |
| Audit and sign-in logs (what each user did in the account; sign-ins with IP address and browser) | While the account exists and, afterwards, for as long as they are needed to evidence the integrity of the winery’s regulatory and tax records or to defend against claims. If the data subject requests erasure, their personal data is removed and only the event is kept | Security and integrity of mandatory records (GDPR Art. 17(3)(b) and (e)) |
| Billing data | 10 years | Tax obligation |
| General backups | 7-day rotation | Operational continuity |
| Support data | 2 years | Service improvement |
| Marketing and waitlist data | Until opt-out or 2 years of inactivity | Consent |
3. Deletion Process Upon Cancellation
- Cancellation confirmed — client initiates from dashboard or email.
- Read-only access — 30 days — export available in CSV/JSON.
- Logical deletion — data becomes inaccessible after 30 days.
- Backup purge — up to 7 additional days.
- Complete deletion — maximum 60 days from cancellation.
4. Exceptions to Deletion
Billing data: 10 years. INV operational data: 5 years. Audit logs: not deleted on cancellation; only the personal data of a data subject who requests erasure is removed. Data under legal proceedings: retained until resolution.
5. Data in Backups
Backups have a 7-day rotation cycle. After purge, data is not recoverable.
6. Deletion Certificate
Request at privacy@cepaos.com. Delivery: 10 business days.
7. Right to Export
The client may export all data at any time in CSV and JSON format.
8. Contact
- privacy@cepaos.com
- cepaos LLC — Wyoming, United States
These terms may be updated from time to time. The current version is the one published at cepaos.com. For legal inquiries, contact legal@cepaos.com.