Data Retention Policy

Effective Date: June 2025  |  Last Reviewed: June 2025  |  Version: 1.1

1. Purpose and Scope

This Data Retention Policy ("Policy") sets out the principles and specific retention periods that SkyL4rk (Pty) Ltd applies to personal and operational data collected and processed across all platforms operated under the SkyL4rk umbrella, including xCrypt, Verilink, TermsCon, SkyVault, and SkyDome.

This Policy applies to all data in SkyL4rk's custody or control, whether held in production systems, backup systems, archives, or offline storage. It applies to SkyL4rk as a data controller for its own data, and informs the obligations SkyL4rk undertakes as a data processor under client DPAs.

This Policy supports SkyL4rk's compliance with:

2. Retention Principles

SkyL4rk adheres to the following principles in determining data retention periods:

3. Retention Schedule

Data Category Specific Data Types Retention Period Legal / Business Basis Action at End of Period
Merchant Account Data Name, email, contact details, company info, user UUID, role, password hash Duration of account + 5 years post-termination Contractual obligation; tax and financial record-keeping (Tax Administration Act) Secure deletion / anonymisation
Sub-Client Account Data Name, email, client ID, API key, webhook URL, status Duration of active relationship + 3 years, or 24 months of inactivity (whichever comes first) Contractual necessity; merchant instruction as data controller Secure deletion upon expiry or merchant instruction
License Keys and Entitlement Records License key hash, expiration date, activation history, revocation records and reasons, usage count 7 years from date of issuance or last activity Financial record-keeping obligations (Tax Administration Act S29); audit trail requirements; potential legal disputes Secure deletion; key hashes may be anonymised and statistical records retained
API Usage Logs Endpoint accessed, timestamp, IP address, response code, parent and sub client IDs, metadata 12 months rolling Security monitoring; fair use enforcement; debugging; billing verification Automated deletion on rolling basis; aggregated statistical summaries retained indefinitely
Billing and Invoice Records Invoice amount, plan tier, overage charges, payment status, payment timestamps 7 years from invoice date Tax Administration Act; VAT records; financial audit requirements Secure deletion
Usage Summaries (Billing Rollup) Monthly validation counts, activation counts, webhook counts per merchant 7 years from billing period Financial record-keeping; overage dispute resolution Secure deletion
Webhook Delivery Logs Event type, payload, delivery response, success status, timestamp 6 months rolling Debugging; merchant support; delivery verification Automated deletion on rolling basis
Authentication and Security Logs Login events, failed authentication attempts, IP addresses, session tokens 12 months Security monitoring; incident investigation; fraud detection Secure deletion; anonymised aggregates retained for trend analysis
Identity Verification Data (Verilink KYC) ID document type and number, biometric scan data, liveness scores, MRZ data, verification outcome As required by applicable FICA and KYC regulations — typically 5 years from verification event FICA compliance; AML obligations; regulatory audit trail Secure deletion; biometric data deleted as soon as verification outcome is recorded unless legal hold applies
Support and Communications Email correspondence, support tickets, contact form submissions 3 years from date of communication Business record; dispute resolution; reference for recurring issues Secure deletion
Contractual Records Accepted terms versions, DPA acceptance timestamps, consent records Duration of relationship + 5 years Legal evidence of contractual agreement; regulatory compliance Secure deletion
Secret Keys and Cryptographic Material Secret keys used for API authentication and encryption Active use only; rotated or deleted upon revocation or account termination Security best practice; no legitimate purpose once revoked Immediate secure deletion upon revocation
Verified Email Records Email address, verification code, confirmation date, status Duration of account + 1 year Verification audit trail Secure deletion
Site Contact Submissions Name, email, message content, IP address, submission date 2 years from submission date Business follow-up; spam/abuse detection Secure deletion

4. Backup Retention

Database backups are created daily and retained on a rolling 30-day basis. Backups are:

Where a data deletion or erasure request is received for live data, the relevant data will be deleted from live systems immediately. Corresponding backup copies may persist for up to 30 days in encrypted backup archives before being purged in the normal rotation. During this period, backup data is not accessible or used in any way.

5. Right to Erasure and Early Deletion

5.1 Merchant-Initiated Deletion

Merchants may request deletion of their own account data or the data of their Sub-Clients at any time. Requests must be submitted in writing to legal@xcrypt.co.za. SkyL4rk will process the deletion within 30 days of the verified request, subject to legal retention obligations.

5.2 Legal Retention Override

Deletion requests may be partially or fully deferred where SkyL4rk is required to retain the data by law — for example, financial and invoice records subject to Tax Administration Act requirements. In such cases, SkyL4rk will:

5.3 Data Subject Requests via Merchants

Where a Sub-Client exercises their right to erasure against the Merchant (as data controller), the Merchant may instruct SkyL4rk (as processor) to delete the relevant Sub-Client data via the dashboard or API, or in writing to legal@xcrypt.co.za.

6. Automated Deletion Processes

SkyL4rk operates automated processes to enforce the following retention rules:

Automated deletion events are logged for audit purposes.

7. Data Destruction Standards

When data reaches the end of its retention period, SkyL4rk applies the following destruction standards depending on the storage medium:

8. Legal Holds

Where SkyL4rk becomes subject to litigation, regulatory investigation, or court order requiring preservation of data beyond its scheduled retention period, SkyL4rk will implement a legal hold on the relevant data. Legal holds suspend automated deletion processes for the affected data only. Legal holds are managed by the Information Officer and reviewed quarterly.

9. Retention of Anonymised Data

Anonymised or aggregated data — from which no individual can be identified, directly or indirectly — is not subject to this Policy's retention limits. SkyL4rk may retain aggregated usage statistics, trend data, and platform performance metrics indefinitely for product development and business intelligence purposes.

10. Cross-Border Considerations

Where personal data is stored by sub-processors in jurisdictions outside South Africa, SkyL4rk ensures that those sub-processors are contractually required to apply equivalent or stricter data retention and deletion standards. Deletion instructions are propagated to relevant sub-processors within a reasonable timeframe, typically within 30 days of the deletion instruction being applied to live systems.

11. Review of This Policy

This Policy is reviewed at least annually, or sooner where there are material changes to applicable legislation, SkyL4rk's data processing activities, or following a significant security or data incident. The current version is always published at https://xcrypt.co.za/legal/data-retention.html.

12. Contact

For queries about data retention, deletion requests, or this Policy: