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Data Retention Policy

BALLABLE OÜ DATA RETENTION POLICY
Introduction
Ballable OÜ (“Ballable” or “we” or “us” or “our”), a company registered in Estonia with registered number 16539801. Our trading and registered office address is at Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151, Estonia.
We hold a variety of data including customer/user details, employee information as well as confidential information about the organization and how it operates. These documents are a vital part of our business and it is important that we ensure that we protect the documents and information contained in them in order to ensure the smooth running of the business and also to comply with the requirements laid down by law.
Ballable is committed to protecting the privacy of all personal data collected in the course of our business, including via this Website altrovedanza.eu. We will at all times ensure that the minimum amount of personal data is kept, and for no longer than necessary, for us to meet our document retention objectives and data protection obligations.
The need to retain data varies widely with the type of data and the purpose for which it was collected. Ballable strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth Ballable OÜ’s guidelines on data retention and is to be consistently applied throughout the organization.
We shall always comply with the General Data Protection Regulation (“GDPR”) when dealing with your personal data.
Ballable reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations. Please check back frequently to see any updates or changes to our Policy.
Who does this Policy apply to?
This policy applies to all employees of the organization who are required to be familiar with and comply with its requirements.
The person within the organization responsible for Data Protection is V. Gravina and responsible for maintaining this policy and ensuring compliance with its terms.
Scope
This policy covers electronic documents (including photographs, video and audio recordings) and those held in a manual filing system. It includes emails, databases and documents contained in any other system operated by the organization. The documents can be created by the organization or created elsewhere and sent to us.
Reasons for Data Retention
Ballable retains only that data that is necessary to effectively conduct its program activities, fulfill its mission and comply with applicable laws and regulations.
Reasons for data retention include:
  • Providing an ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing offers or updates to an individual etc.)
  • Compliance with applicable laws and regulations associated with financial and programmatic reporting by Ballable to its funding agencies and other donors.
  • Compliance with applicable labor, tax and immigration laws
  • Other regulatory requirements
  • Security incident or other investigation
  • Intellectual property preservation
  • Litigation
Retention of Data
We retain documents no longer than necessary and based on the time limits set by law for some documents and where there is no statutory period, we have set the time based on how long we think the document will be required. Once the statutory period has been reached then the documents shall be destroyed unless there is a good reason to keep them (e. g. ongoing legal proceedings). In such events, the responsible person should make the final decision on whether documents are retained beyond the minimum retention period.
Type of Data
Description
Retention Period
User Accounts
Online accounts created by Customer/User
Non buyers – 3 years Buyers & Closed accounts – 3 years
Orders Database
Customers/User name and contact details
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7 years after last contact from a customer. Delete if unsubscribe request is received.
Marketing Database
Customers/User name and contact details
3 years after last contact from a customer. Delete if unsubscribe request is received.
Consent Forms/Photos
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15 years
Teacher Dance Conference Records
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3 Years
Online chat
Any information you give us
Live chat information is stored in line with our service provider (Whatsapp)
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Manual records
After processing manual records are shredded.
Electronic records
Emails are archived (deleted from our email server) once they have passed their minimum retention period date.
Databases - Once records have matured past their minimum retention date they will be deleted or anonymised.
Database backups are retained for a maximum of 2 years.
Data Destruction
Data destruction ensures that when the retention period for the data as outlined above expires, we shall actively destroy the data covered by this policy unless there is a legitimate reason to keep them and the responsible person has agreed to extend the retention period. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.
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