Data retention schedule

Where no law fixes a period, we keep information only while at least one of these is true, and delete or anonymise it when none is:

• we still need it for the purpose we collected it for, for example to run an account or deliver a service the person asked for;
• a law requires us to keep it, for example tax and company records;
• we need it to establish, exercise or defend a legal claim, or a regulator or court has asked for it;
• the person has asked us to keep it, for example an opt-out we must remember.

When a period ends we delete the information from the live service, and it leaves backups on their normal cycle, which is within 90 days.

For this information the practice is the controller and we are its processor. We follow the practice's instructions and do not decide how long its records are kept.

• Matters, documents, notes, ledgers, contracts, recoveries accounts, signing records, invoices and workspace files are kept while the subscription is active. After it ends they stay available for export for 30 days, then we delete them from the live service, and they leave our backups within 90 days.
• A practice's own deletion of a document or matter removes it from the live service. Ledger, audit and signing records, and earlier versions of a document, are permanent controls and are kept for the life of the matter or workspace.
• Workspaces can be given a retention period by the practice. When it passes, documents nobody has changed are archived, not deleted, and can be restored. A legal hold stops archiving and deletion for the workspace or a single document until it is released.
• Enquiries a practice receives through its intake page are kept until the practice takes the person on or declines them. A declined or lapsed enquiry is deleted when the practice's retention period ends, which the practice sets and which is 12 months by default. Enquiries that become clients are kept as the practice's client records are kept.
• The permanent record of who did what in a workspace refers to every participant, including outside guests, so a guest's name, email address and organisation stay on that record for as long as the workspace exists.

Some laws require a practice to keep records for a long time, and the practice must not let a shorter period destroy them. For a regulated firm in the United Kingdom, regulation 40 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires copies of the identity evidence and supporting records obtained for customer due diligence to be kept for five years from the end of the business relationship, or from the date an occasional transaction is completed. A firm's regulator also sets rules for client account records (for solicitors in England and Wales, the SRA Accounts Rules). The Limitation Act 1980 sets the time within which claims can be brought, generally six years for contract and tort and twelve for deeds, and firms commonly keep files at least that long. Because we delete a practice's information 30 days after its subscription ends, a practice that is bound by one of these periods must export those records before it ends, and keep them elsewhere for the full period.

For this information we are the controller.

• Account details: while the account is active and for 12 months after it closes.
• Billing and tax records: six years from the end of the financial year, or longer if the law requires. This is meant to cover the longer of the periods that UK company and tax law set for accounting records.
• Security logs and the system audit trail: up to 24 months, or longer where needed to investigate a specific incident.
• Support requests and complaints: three years after they are closed.
• Website enquiries and demo requests: 24 months, or until you ask us to delete them.
• Marketing preferences, including opt-outs: for as long as needed to respect them.
• Email delivery records: 12 months.
• Records of personal data breaches: as long as the law requires us to document them, and at least until any investigation by the Information Commissioner's Office is closed.

We may keep information longer where a law requires it, where it is needed to establish, exercise or defend legal claims, or where a regulator or court asks. Article 17(3) of the UK GDPR allows this even when a person asks for erasure. We restrict access to it and use it only for that purpose.

Under Articles 15 to 22 of the UK GDPR you can ask to see your personal data, have it corrected, and have it erased where it is no longer needed, where you withdraw consent and nothing else justifies keeping it, where you object and nothing overrides that, where it was handled unlawfully, or where the law requires erasure. We answer without undue delay and within one month of your request. If a request is complex or we receive many, the law allows us to extend that by up to two further months, and we will tell you within the first month and give our reasons. If we cannot act on a request, we tell you why, and that you may complain to the Information Commissioner's Office and seek a judicial remedy. If your information is in a practice's records, we pass the request to the practice, because the practice decides what happens to it.

Deleted information is removed from the live service and then overwritten in backups on their normal cycle. Where we cannot delete something without breaking the integrity of a permanent record, such as a ledger entry or audit event, we remove or pseudonymise personal details where the law requires it and where that does not defeat the purpose of the record.

We review this schedule at least once a year and whenever a law it relies on changes. The effective date at the top of this page shows when the current version took effect.

You can reach us at privacy@olympuspay.co for data protection matters, legal@olympuspay.co for legal notices, and support@olympuspay.co for help. Our address for notices is 1111B S Governors Ave, STE 25834, Dover, DE 19904, USA. A written notice sent to that address, or an email to legal@olympuspay.co, is treated as delivered when received.