Data Retention Policy

Storage limitation principle

In accordance with Article 5(1)(e) of the General Data Protection Regulation (GDPR),ORBIS ML applies the principle of storage limitation: personal data is kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it is processed.

Once those periods expire, data is subject to either permanent deletionor irreversible anonymisation, rendering it impossible to re-attribute to any individual.

Retention periods

The table below summarises the retention periods applicable to each category of data:

Data category

Duration

Details

Account data (email, profile, preferences)

Account lifetime

Deleted when you delete your account from the interface, after a keyword confirmation. Deleting the account erases the personal data that is not subject to a legal retention obligation. The necessary accounting records are kept for the applicable legal period.

Call audio recordings

24 hours maximum

Deleted as soon as transcription completes. No audio recording is kept on a lasting basis, nor beyond 24 hours.

Call transcripts

6 months

Automatically deleted after 6 months. You can delete them sooner from the interface, by deleting the corresponding call: that deletion takes the call and its transcript. Excerpts recorded during a live call do not go with them, they are erased by the 6-month purge or by the deletion of your account.

Call analyses

As long as the call exists

Kept after the transcript has been deleted. Deleted together with the call when you delete it from the interface.

Team invitations (Agency plan)

30 days after expiry

An invitation that has not been accepted is automatically deleted 30 days after it expires, which is itself 7 days after it was sent. An accepted invitation is kept for as long as the team exists.

Team data (Agency plan)

Account lifetime

Kept for as long as the account exists: date of joining and monthly limit, acceptance of the team terms (date and version of the text), and each departure (dates and reason). Deleted with the account. The monthly ranking keeps nothing more: it is computed each time it is shown. Team criteria are deleted 30 days after a canceled Agency subscription ends; each verdict is kept with the call's analysis, and deleted with it. The team offer analysis is kept until the next generation, which replaces it, and deleted 30 days after a canceled Agency subscription ends.

Company documents (Agency plan)

30 days after a canceled subscription ends

Only the text extracted from the documents is kept, never the file. The documents are kept until the admin account removes them; the team brief drawn from them is replaced at every upload or removal. Documents and brief are automatically deleted 30 days after a canceled Agency subscription ends; a team that takes out a subscription again before then keeps them.

Call shares and comments (Agency plan)

6 months at most

Kept for as long as the share exists. Deleted when the member removes the share, when they leave the team, when the call is deleted, and at the latest together with the transcript, after 6 months.

Billing data (invoices, payment history)

Applicable legal period

The necessary accounting records are kept for the applicable legal period, including after the account is deleted.

Technical logs (system logs, access logs)

Host's own policy

Technical traces are retained by the host according to its own policy. We neither produce nor retain any on our own account.

Browsing data on public pages

13 months

Page viewed, site the visitor came from and a temporary visit identifier, with no IP address and no link to an account. Automatically deleted after 13 months. The visit identifier itself disappears when the tab is closed. ClosePeak sets two cookies, strictly necessary to keep you signed in and unrelated to this measurement: see the Cookie Policy.

Deletion & anonymisation

Once the retention periods defined above expire, ORBIS ML automatically carries out:

Permanent deletion

Irremediable erasure of data from active databases and storage systems.

Irreversible anonymisation

In certain cases, transformation of data into aggregated and non-re-identifiable data, used solely for statistical purposes.

The deletion or anonymisation of active data does not result in their immediate removal from backups. Deleted data disappears according to the backup rotation cycle (see Backups section below).

Right to erasure

In accordance with Article 17 of the GDPR, you have the right to erasure ('right to be forgotten') of your personal data. You may exercise this right at any time through two channels:

📱 From your account

Delete a call and its transcript from 'My calls', using the 'Delete' button on the relevant row. Excerpts recorded during a live call do not go with it: they are erased by the automatic 6-month purge, or by the deletion of your account. To erase your entire account and everything attached to it, open 'Settings', the 'Danger zone' section, then 'Delete my account'. The effect is immediate. The admin account of an Agency team must first cancel the Agency subscription: deletion becomes possible once the paid period has ended.

✉️ By email

Send your request to privacy@closepeak.io. We will acknowledge receipt and process your request within a maximum of one (1) month.

Deleting the account erases the personal data that is not subject to a legal retention obligation. The necessary accounting records are kept for the applicable legal period.

Backups

ORBIS ML maintains regular backups of its databases for business continuity and disaster recovery purposes. These backups are:

Stored securely and in encrypted form.
Subject to limited retention: older backups are automatically overwritten according to a rotation cycle.
Data deleted by the user or upon expiry of retention periods is permanently removed from backups at the end of the applicable rotation cycle.

Contact

For any question relating to the retention of your data or to exercise your rights:

ORBIS ML, Data Protection Team
Email: privacy@closepeak.io
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