Data Retention and Deletion Policy
Version 1.0 · Last updated: October 2, 2026
| Periodic review | Annually or following relevant regulatory changes |
|---|---|
| Applicable regulations | GDPR · LGPD · Law 25,326 · AFIP regulations |
1. Purpose and scope
1.1 This Policy establishes how long Destinatarium retains the different kinds of data generated or processed while providing its email infrastructure service.
1.2 It applies to all customer data, final-recipient data, operational logs, billing data, and audit records managed by Destinatarium.
1.3 It supplements Destinatarium's Privacy Policy, DPA, and Terms of Service. Applicable law prevails in the event of a conflict.
2. Retention periods by category
| Data category | Period | Legal/operational basis | Deletion method |
|---|---|---|---|
| Email message body (content) | NOT STORED | Privacy by design — competitive differentiator | Not applicable |
| Sending metadata (sender, recipient, subject, timestamp) | 30 days | Operations / deliverability | Automatic |
| Delivery logs (sent, bounced, rejected) | 30 days | Operations / technical support | Automatic |
| Engagement data (opens, clicks) | 60 days | Analytics / customer reports | Automatic |
| Suppression lists (opt-outs / unsubscribes) | Indefinite | Anti-spam compliance | Manual at Customer request |
| Hard-bounce records | Indefinite | IP reputation protection | Manual at Customer request |
| Customer account data (name, email, company) | 90 days after cancellation | Contract / possible reactivation | Automatic |
| Billing and transaction records | 10 years | Legal obligation — AFIP / Insolvency Act art. 67 | Manual |
| Security audit logs | 12 months | Security / incident investigation | Automatic |
| Platform access logs (IP, user agent) | 90 days | Operational security | Automatic |
| Support tickets and communications | 24 months | Service improvement / dispute resolution | Automatic |
| API keys | Until revoked | Functional | Immediately upon revocation |
Privacy-by-design note: Destinatarium does NOT store email message bodies. This deliberate architectural decision reduces security-incident risk and differentiates Destinatarium from platforms that retain message content.
3. Deletion procedures
3.1 Automatic deletion. Destinatarium systems run automatic deletion routines when each retention period expires. Data is removed by secure overwriting or cryptographic destruction.
3.2 Deletion at Customer request. The Customer may request early deletion in writing to technical support. Destinatarium will process the request within 30 business days.
3.3 After cancellation. Destinatarium will begin deleting Customer data under these periods after Service cancellation. The Customer may request an exported archive during the first 30 days after cancellation.
3.4 Exceptions. Destinatarium may retain data beyond these periods solely due to a legal retention obligation, a court order or competent-authority request, or the establishment, exercise, or defense of legal claims.
3.5 Backups. Backups may contain data for up to 30 additional days after production deletion. They are encrypted and unavailable for ordinary operations.
4. Security during retention
Throughout retention, data is protected with AES-256 encryption at rest, role-based access control, and logical separation between customers. Access is limited to personnel with a justified operational need and recorded in audit logs.
5. Data-subject rights
Destinatarium will assist the Customer with rights of access, correction, deletion, objection, and portability of Personal Data under the current DPA.
6. Policy review and updates
This Policy will be reviewed at least annually or following relevant regulatory changes. Customers will receive at least 30 days' notice of material amendments by email or through the administration panel.