Data Retention Policy

Last Updated: October 1, 2025

This Data Retention Policy explains how Pevlamiso retains, stores, and deletes personal data and other information collected through our educational platform and services.

1. Purpose and Scope

This policy establishes guidelines for the retention and deletion of data collected from users of our documentary editing courses and educational services. It applies to all data processing activities conducted by Pevlamiso.

2. Types of Data Retained

We retain the following categories of data:

• Account information including name, email address, and profile details
• Course enrollment and progress data
• Payment and transaction records
• Learning materials and user-generated content
• Communication records including support inquiries
• Technical data including IP addresses, device information, and usage logs
• Assessment results and certifications

3. Retention Periods

3.1 Active Account Data

Data associated with active user accounts is retained for the duration of account activity plus the periods specified below:

• Account Information: Retained while account is active and for 3 years after last activity
• Course Progress and Enrollments: Retained for 5 years after course completion or account closure
• Certificates and Achievements: Retained for 10 years to verify credentials
• User-Generated Content: Retained while account is active and for 2 years after deletion request

3.2 Financial Records

Payment and transaction data is retained for 7 years from the date of transaction to comply with accounting and tax requirements.

3.3 Communications

Support tickets, email correspondence, and other communications are retained for 3 years from the date of last interaction.

3.4 Technical and Analytics Data

• Server Logs: Retained for 90 days
• Analytics Data: Retained in aggregated form indefinitely; individual user data for 2 years
• Security Logs: Retained for 1 year

3.5 Marketing Data

Marketing communications preferences and interaction data are retained until consent is withdrawn, plus 1 year for compliance verification.

4. Inactive Accounts

Accounts with no activity for 3 consecutive years are considered inactive. We will:

• Send notification to the registered email address 90 days before deletion
• Provide options to reactivate the account or export data
• Delete the account and associated data if no response is received
• Retain certification records and financial data per specified retention periods

5. Data Deletion Procedures

5.1 Automated Deletion

Our systems automatically delete data when retention periods expire through scheduled processes that run monthly.

5.2 User-Requested Deletion

Users may request deletion of their data at any time by contacting us at info@pevlamiso.com. We will process deletion requests within 30 days, subject to the following exceptions:

• Data required for legal or regulatory compliance
• Financial records within mandatory retention period
• Data necessary to resolve disputes or enforce agreements
• Backup copies, which are deleted according to backup retention schedules

5.3 Secure Deletion Methods

Data deletion is performed using secure methods including:

• Permanent deletion from production databases
• Overwriting of storage media for sensitive data
• Removal from backup systems according to backup rotation schedules
• Anonymization where complete deletion is not possible

6. Legal and Regulatory Holds

We may suspend normal retention and deletion procedures when data is subject to:

• Legal proceedings or investigations
• Government or regulatory requests
• Audit requirements
• Dispute resolution processes

Data subject to legal hold will be preserved until the hold is lifted, after which normal retention periods apply.

7. Backup and Archival Data

Backup copies of data are maintained for disaster recovery purposes:

• Daily Backups: Retained for 30 days
• Monthly Backups: Retained for 1 year
• Annual Backups: Retained for 3 years

Data deleted from production systems may persist in backups until the backup itself expires and is overwritten.

8. Third-Party Service Providers

When we share data with third-party service providers, we require them to:

• Implement retention policies consistent with this policy
• Delete or return data upon termination of services
• Comply with our data deletion requests
• Maintain appropriate security during retention period

9. Anonymized and Aggregated Data

We may retain anonymized or aggregated data indefinitely for research, analytics, and service improvement purposes. This data cannot be used to identify individual users and is not subject to deletion requests.

10. Data Portability

Before data deletion, users may request a copy of their data in a structured, commonly used format. Requests should be submitted to info@pevlamiso.com and will be processed within 30 days.

11. Changes to Retention Periods

We may update retention periods based on:

• Changes in legal or regulatory requirements
• Business needs and operational requirements
• Security considerations
• User feedback and privacy best practices

Material changes will be communicated through our website and via email to active users.

12. Review and Compliance

This Data Retention Policy is reviewed annually to ensure:

• Compliance with applicable laws and regulations
• Alignment with current business practices
• Implementation of security best practices
• Effectiveness of deletion procedures

13. Contact Information

For questions about this Data Retention Policy or to submit data deletion requests, please contact us:

Email: info@pevlamiso.com
Phone: +380507470726
Address: Yelyzavety Chavdar St, 2, Kyiv, Ukraine, 02000

14. Effective Date

This Data Retention Policy is effective as of the last updated date shown above and applies to all data collected from that date forward.