Data Retention Policy
Last Updated: February 20, 2024
This Data Retention Policy describes how Relvadnom ("we", "us", or "our") collects, stores, and removes personal data and other information gathered through our platform and services available at relvadnom.com. We are committed to retaining data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
1. Scope
This policy applies to all personal data and non-personal information processed by Relvadnom in connection with the operation of our online education platform, website, and related services. It covers data collected from registered users, visitors, instructors, and other individuals who interact with our services.
2. Types of Data We Retain
2.1 Account and Profile Data
Information provided during registration and profile setup, including name, email address, contact details, and account preferences.
2.2 Learning and Activity Data
Records of course enrollments, progress, completed lessons, quiz results, certificates, and interaction history within the platform.
2.3 Communication Data
Messages, support requests, feedback submissions, and any correspondence exchanged between users and Relvadnom through official communication channels.
2.4 Technical and Usage Data
Log files, IP addresses, browser type, device identifiers, session data, and usage analytics collected automatically during platform use.
2.5 Payment and Transaction Data
Records of purchases, subscription activity, and billing history, including transaction identifiers and payment status. Full payment card details are not stored by us directly.
2.6 Content and Submissions
User-generated content such as forum posts, comments, assignments, and uploaded materials submitted through the platform.
3. Retention Periods
We apply specific retention periods based on the category of data and the purpose for which it is held. The table below outlines our standard retention schedule.
| Data Category | Retention Period | Basis for Retention |
|---|---|---|
| Account and profile data | Duration of account plus 3 years after closure | Service delivery, legal compliance |
| Learning and activity data | Duration of account plus 5 years after closure | Certification validity, service continuity |
| Communication data | 3 years from last interaction | Dispute resolution, service improvement |
| Technical and usage data | 12 months from collection | Security, performance, fraud prevention |
| Payment and transaction data | 7 years from transaction date | Financial record-keeping obligations |
| User-generated content | Duration of account plus 1 year after closure | Platform integrity, user access |
| Support and feedback records | 3 years from case closure | Quality assurance, legal claims |
| Marketing consent records | Until consent is withdrawn plus 3 years | Compliance verification |
Retention periods may be extended where required by applicable law, ongoing legal proceedings, regulatory investigations, or legitimate business necessity. Where data is retained beyond standard periods, we apply additional access controls and review requirements.
4. Criteria for Determining Retention Periods
Where a specific retention period is not defined in the table above, we determine the appropriate retention period by considering the following criteria:
- The nature and sensitivity of the personal data involved
- The purpose for which the data was collected and whether that purpose has been fulfilled
- The potential risk of harm arising from unauthorized use or disclosure
- Whether the data is required to fulfill contractual or legal obligations
- Whether the data is necessary to protect the rights or legitimate interests of Relvadnom or third parties
- The volume and scope of data held and the cost and feasibility of secure deletion
5. Data Deletion and Anonymization
5.1 Deletion Process
At the end of the applicable retention period, personal data is securely deleted or destroyed from all active systems and backups in a manner that prevents reconstruction or recovery. Deletion is carried out on a scheduled basis through automated processes or manual review, depending on the data category.
5.2 Anonymization
In certain circumstances, rather than deleting data, we may anonymize it so that it can no longer be associated with any identifiable individual. Anonymized data may be retained indefinitely for analytical, research, or statistical purposes without further restriction under this policy.
5.3 Backup Systems
Personal data contained in backup copies may persist for a limited additional period beyond the standard retention period due to the nature of backup rotation schedules. Such data remains subject to appropriate security controls and is deleted as backups are overwritten according to our standard backup cycle.
6. Account Closure and User-Initiated Deletion
When a user closes their account or submits a verified request for deletion of their personal data, we will initiate the deletion process in accordance with the timelines set out in this policy. Some data may be retained beyond the account closure date where we have a legitimate legal or contractual basis to do so, as described in Section 3.
Users who wish to request deletion of their personal data may contact us using the details provided in Section 10 of this policy. We will respond to verified deletion requests within a reasonable timeframe.
7. Data Held by Third Parties
Relvadnom uses carefully selected third-party service providers to support platform operations, including payment processing, analytics, hosting, and communication services. These providers may retain data independently in accordance with their own retention policies. We require third-party processors to implement retention practices consistent with applicable data protection obligations and our contractual requirements.
8. Security During Retention
All retained data is protected by appropriate technical and organizational security measures throughout the retention period. These measures include:
- Encryption of data at rest and in transit
- Access controls limiting data access to authorized personnel on a need-to-know basis
- Regular security assessments and vulnerability monitoring
- Audit logging of access to sensitive data categories
- Secure physical and logical storage environments
Security measures are reviewed and updated periodically to address evolving risks.
9. Your Rights Regarding Retained Data
Depending on your location and applicable law, you may have rights in relation to personal data we hold about you, including the right to:
- Access a copy of your personal data
- Request correction of inaccurate or incomplete data
- Request erasure of your personal data where no longer necessary
- Object to or restrict processing of your personal data in certain circumstances
- Request data portability in a structured, machine-readable format
- Withdraw consent where processing is based on consent
To exercise any of these rights, please contact us using the information provided in Section 10. We may require verification of your identity before processing your request. We will respond without undue delay and in compliance with applicable obligations.
10. Contact Information
If you have questions about this Data Retention Policy, wish to exercise your data rights, or need to report a concern regarding the handling of your personal data, please contact us:
Relvadnom
Rus'ka St, 15, Ternopil, Ternopil Oblast, Ukraine, 46001
Email: contact@relvadnom.com
Phone: +380504739339
Website: relvadnom.com
11. Changes to This Policy
We may update this Data Retention Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will update the "Last Updated" date at the top of this document and, where appropriate, notify users through the platform or by email. Continued use of our services following the publication of updates constitutes acceptance of the revised policy.
We encourage you to review this policy periodically to stay informed about how we retain and manage your data.