Data Retention and Disposal Policy

Last Updated: April 22, 2026
Owner: Security Officer

1. Purpose

This policy establishes how Happee, Inc. retains, manages, and disposes of data — including Customer Data, personal data, operational data, and internal business records. It governs the retention commitments made in our Cloud Computing Service Agreement and Security Policy and supports compliance with GDPR, CCPA, and applicable US law.

2. Scope

This policy applies to all data held by or on behalf of Happee, Inc., including:

Customer Data stored in tenant databases
Personal data of customers, Authorized Users, leads, and employees
Operational and infrastructure logs
Backup and disaster recovery copies
Financial and business records
Communications (email, internal channels)

3. Data Categories and Retention Periods

Category	Examples	Retention Period	Basis
Customer Data (active tenant)	Tenant database, uploaded files, accounting records	Duration of active subscription + 30-day export window after termination	Contractual obligation
Customer Data (deleted on request)	Same as above	48 hours for active systems; 14 days for backup media	Contractual obligation (service agreement §7.3)
Personal data — customers/users	Name, email, billing address, IP logs	Duration of account + 3 years	Legitimate interest / legal obligation
Payment data	Card details, billing history	Not stored — held by payment processor (Stripe) per Stripe's retention policy	PCI DSS
Infrastructure and access logs	Server logs, sign-in records, IP addresses	90 days rolling	Security / legitimate interest
Application error logs	Stack traces, debug output	30 days rolling	Operational necessity
Backup data	Tenant database snapshots	30 days rolling; one monthly snapshot retained for 12 months	Operational / disaster recovery
Financial records	Invoices, SOWs, revenue records	7 years	US tax / legal obligation
Employee records	HR files, contracts, payroll	Duration of employment + 7 years	Legal obligation
Communications	Internal channel messages, email	3 years, then deleted unless subject to legal hold	Legitimate interest
Marketing and lead data	CRM leads, email campaign data	3 years from last interaction, or until opt-out request	Legitimate interest / CCPA/GDPR

4. Customer-Initiated Deletion Requests

When a customer requests deletion of their Customer Data:

Request received — logged within 24 hours
Active systems — tenant database and associated files deleted within 48 hours of confirmed request
Backup media — all backup copies destroyed within 14 days
Confirmation — written confirmation sent to the customer's account email upon completion
Exceptions — deletion may be suspended if required for an active incident investigation or pursuant to a court order; customer notified if a delay applies

5. Automated Retention Enforcement

Where technically feasible, retention periods are enforced automatically:

Infrastructure logs are rotated on a 90-day schedule by the hosting provider
Application logs are rotated on a 30-day schedule
Backup snapshots older than 30 days (except monthly snapshots) are purged automatically

6. Disposal Methods

Medium	Disposal Method
Tenant database files	Secure file deletion; hosting provider confirmation
Cloud storage objects	Provider-level deletion API with deletion confirmation
Backup media (cloud)	Provider-level purge with audit log
Backup media (physical, if any)	Cryptographic erasure or physical destruction
Logs	Provider-managed rotation

7. Legal Hold

Normal retention schedules are suspended for data subject to a legal hold triggered by litigation, a court order, subpoena, or government demand. Customers are notified of any delay in their deletion request caused by a legal hold, to the extent permitted by law.

8. Policy Review

This policy is reviewed annually, or sooner if there is a material change in applicable law or our data practices.

Happee, Inc. · security@happee.ai · Delaware, USA