Data Retention, Erasure, and Portability Policy - Play258
ID: PLAY258-RET | Version: 1.0.0 | Effective: 05-04-2026
1. Purpose
Define how long personal data is retained, how it is erased or anonymized, and how data subjects may exercise data portability, aligned with the Privacy Policy.
2. General criteria
- Purpose: only as long as necessary for the purpose.
- Contract: for the contract term + limitation period for claims.
- Legal obligation: per tax/accounting deadlines.
- Dispute: until final judgment or limitation.
- Security: technical logs for the minimum period needed to detect incidents.
3. Guideline table
| Category | Indicative period | Notes |
|---|---|---|
| Active account | life of account | continuously updated |
| After account closure | 24 months | varies by subsystem |
| Invoices and tax documents | 10 years | local law |
| Access / security logs | 180 days | extended if investigation |
| Music requests (metadata) | 24 months | listener ID may be anonymized |
| Communication recordings (support) | 24 months | unless dispute |
| Marketing (no interaction) | until objection + 30 days | |
| Reports and moderation cases | 3 years after closure | adjust |
4. Erasure and anonymization
4.1. Logical deletion first (soft delete); physical purge in a scheduled job.
4.2. Anonymization: removal of direct identifiers; aggregation for statistics.
4.3. Backups: data may persist until backup rotation; controlled restore process without reactivating a deleted account.
5. Portability
5.1. Structured, commonly used, machine-readable format (e.g. JSON/CSV) when technically feasible.
5.2. Delivery timeframe: 30 days after identity verification.
5.3. Third-party trade secrets and other data subjects’ data without consent are excluded.
6. Manual intervention requests
https://play258.com/legal/privacidade#direitos-dos-titulares or dpo@voneka.co.mz — abusive volume limits may apply.