Data Retention Policy

Platinum Health Equipment Pty Ltd
Version 2.0 | Effective: April 24, 2026 | Updated: Privacy-First Zero-Retention Policy

1. Purpose

This Data Retention Policy defines how long different types of data are stored by AegisGates Vision AI and the procedures for data deletion. This policy ensures compliance with GDPR, CCPA, Australian Privacy Principles, and industry best practices.

2. Scope

This policy applies to all data collected, processed, and stored by the AegisGates Vision AI platform, including:

• Video footage and images
• AI-generated narratives and metadata
• User account information
• Billing and payment records
• System logs and analytics
• Communications

3. Data Categories and Retention Periods

3.1 Video Footage

Processing Stage	Retention Period	Details
Raw Video Clips	ZERO (0 seconds)	Deleted immediately after AI processing completes (typically within 2-30 seconds of upload)
Processing Frames (temporary)	During inference only	Extracted keyframes exist in memory only during AI analysis, never written to disk
Failed Clips (debug)	7 days	Clips that fail AI processing are quarantined for debugging, then auto-deleted

3.2 AI-Generated Narratives and Metadata

Important: Narratives are text-only descriptions of what was observed in video clips. They do NOT contain any video footage, images, or biometric data.

Data Type	Retention Period	Storage Location
Narratives (text descriptions)	90 days	PostgreSQL database (encrypted)
Alert records	90 days	PostgreSQL database
Timestamps	Same as narratives	PostgreSQL database
Motion detection events	90 days	Redis + PostgreSQL

3.3 Account and User Data

Data Type	Retention Period	Deletion Trigger
Active account information	Duration of subscription + 90 days	Account deletion + 90 days
Deleted account data	30 days (soft delete), 90 days (hard delete)	Immediate upon deletion request
Email addresses	Subscription + 12 months	Opt-out or deletion request
Password hashes	Subscription only	Immediate upon account deletion
Login history	12 months	Rolling 12-month window

3.4 Billing and Payment Records

Data Type	Retention Period	Legal Requirement
Invoices	7 years	Australian tax law (ATO requirements)
Payment transactions	7 years	Financial record keeping
Failed payment attempts	3 months	Fraud prevention
Stripe payment IDs	7 years	Payment processor requirements

Note: We do NOT store complete credit card numbers. Stripe securely tokenizes payment information.

3.5 System Logs and Analytics

Log Type	Retention Period	Purpose
Access logs (web/API)	90 days	Security monitoring, debugging
Error logs	90 days	Troubleshooting, service improvement
Security logs (failed logins, suspicious activity)	12 months	Security investigations
Aggregated analytics (anonymized)	Indefinite	Product improvement, trends
Redis task queue logs	7 days	Operational monitoring

3.6 Communications

Communication Type	Retention Period	Storage
Support tickets	24 months after resolution	Help desk system
Transactional emails (sent)	12 months	Email service provider logs
Marketing emails (if opted in)	Until opt-out	Email marketing platform
SMS alerts (sent)	90 days	Twilio logs

4. Deletion Procedures

4.1 Automated Deletion

• Video Footage: Deleted immediately after AI processing completes (within seconds)
• Orphaned Clips: Automated hourly cleanup removes any clips older than 1 hour that failed to process
• Narratives: Automated daily cleanup at 02:00 UTC deletes narratives older than plan retention period
• Failed Clips (debug): Auto-deleted after 7 days
• Logs: Automated cleanup scripts run weekly

4.2 Manual Deletion Requests

Users may request early deletion by:

1. Emailing [email protected]
2. Using self-service deletion feature (if available)
3. Contacting customer support

4.3 Secure Deletion Methods

• Video Files: Deleted using os.remove() immediately after processing (raw clips never hit persistent storage)
• Database Records: Overwritten with NULL values, then row deleted
• Backups: Deleted narratives removed from all backup locations within 90 days
• Third-Party Storage: No video footage sent to third parties (only extracted frames for AI analysis, not persisted)

5. Backup Retention

5.1 Backup Schedule

Backup Type	Frequency	Retention Period
Database (full)	Daily	30 days
Database (incremental)	Every 6 hours	7 days
Configuration files	Weekly	90 days
Disaster recovery snapshot	Monthly	12 months

5.2 Backup Deletion

• Backups are automatically purged after retention period expires
• Deleted account data is removed from backups within 90 days
• Legal hold data is retained in backups until hold is lifted

6. Legal Hold and Preservation

6.1 When Legal Hold Applies

Data is retained beyond standard periods when:

• Litigation is pending or reasonably anticipated
• Government investigation or subpoena is active
• Regulatory audit is in progress
• User has filed a formal complaint or claim

6.2 Legal Hold Procedure

1. Legal team issues preservation notice
2. Automated deletion is suspended for affected data
3. Data is copied to secure legal hold repository
4. Hold is documented with case number and expiration criteria
5. Hold is lifted only upon legal team authorization

7. Third-Party Data Retention

Service Provider	Data Type	Their Retention	Our Control
Google Gemini API	Image analysis requests	30 days (per Google policy)	None (processed on-the-fly)
Stripe	Payment transactions	Indefinite (compliance)	Limited (can request deletion)
Twilio	SMS logs	6 months	Can request deletion
Resend	Email logs	30 days	Can request deletion
Cloudflare	CDN cache, logs	7-30 days	Can purge cache
GCP	Server infrastructure	Duration of contract	Full control (encryption keys)

8. Data Subject Rights

Users have the right to:

1. Access: Request a copy of all data we hold about them
2. Rectification: Correct inaccurate or incomplete data
3. Erasure: Request deletion (subject to legal obligations)
4. Portability: Receive data in machine-readable format
5. Restriction: Limit processing of their data
6. Objection: Object to processing based on legitimate interests

How to Exercise Rights: Email [email protected] with subject line "Data Subject Request"

9. Children's Data

• We do NOT knowingly collect data from children under 16
• If discovered, children's data is deleted within 72 hours
• Parents/guardians may request deletion by providing proof of guardianship

10. Data Breach Retention

10.1 Incident Data

• Security incident reports: 7 years (compliance requirement)
• Forensic evidence: Until legal proceedings resolved
• Breach notification records: 7 years

10.2 Notification Timeline

• GDPR: 72 hours to data protection authority, immediate to affected users
• Australian Privacy Act: Immediate (if serious data breach)
• CCPA: Without unreasonable delay

11. Retention Schedule Review

This policy is reviewed:

• Annually: Every April
• After Legal Changes: When privacy laws are amended
• After Major Incidents: Post-breach or audit findings

Last Review: April 23, 2026
Next Review: April 2027
Responsible: Chief Privacy Officer / Legal Team

12. Exceptions and Overrides

12.1 Regulatory Requirements

If law requires longer retention (e.g., financial records, subpoenas), regulatory requirements supersede this policy.

12.2 User Requests for Longer Retention

Enterprise customers may negotiate custom retention periods via contract addendum.

12.3 Anonymized Data

Aggregated, anonymized data (no personal identifiers) may be retained indefinitely for analytics and research.

13. Contact Information

Data Retention Inquiries: [email protected]
Legal Hold Requests: [email protected]
General Support: [email protected]

Mailing Address:
Platinum Health Equipment Pty Ltd
7 Eden Park Drive, Unit 5 Suite #1061
Macquarie Park, NSW 2113
Australia

14. Policy History

Version	Date	Changes
2.0	April 24, 2026	Privacy-First Update: Implemented zero-retention policy for raw video footage. All video clips now deleted immediately after AI processing. Only text narratives retained.
1.0	April 23, 2026	Initial policy release

Next Review Date: April 2027