Data Retention & Deletion Policy

1.1 This Policy describes how long, and under what conditions, 404 Emails retains various categories of data processed in connection with the Service, and how data is deleted when use of the Service ends.

1.2 This Policy supplements the Terms, the Privacy Policy, and the Data Processing Agreement (DPA); where any of those documents contains a more specific provision for a given situation, this Policy does not override it.

1.3 Capitalised terms not defined in this Policy have the meaning given to them in the Service's Terms of Service (the "Terms").

2.1 How long a given piece of data is retained depends on the type of data, the purpose of its processing, the Customer's instructions, the contractual lifecycle, applicable law, security and anti-abuse requirements, and the technical lifecycle of backups.

2.2 This Policy does not set a single universal retention period applicable to all data.

2.3 To the extent the GDPR applies to the processing, 404 Emails follows the storage-limitation principle: personal data is not retained for longer than necessary for the applicable purpose, subject to legal obligations and legitimate or legal reasons for further retention.

2.4 This Policy does not constitute individualised legal advice.

3.1 For the purposes of this Policy, two basic categories of data are distinguished: (a) Customer Data and (b) 404 Emails' own records.

3.2 "Customer Data" means, in particular, marketing and subscriber data processed on behalf of the Customer, which may, depending on use, include:

• contacts;
• email addresses, names and other contact fields;
• subscriptions and topics;
• consent evidence;
• suppressions;
• campaigns;
• recipients;
• message, delivery and event data;
• forms and their submissions;
• automation data;
• sending-domain and configuration data;
• integration data and configuration.

3.3 With respect to Customer Data, the Customer generally acts as controller and 404 Branding s.r.o. generally acts as processor within the meaning of the GDPR.

3.4 "404 Emails' own records" means, in particular:

• Customer and account-administrator data;
• contractual records;
• LegalAcceptance (evidence of acceptance of legal documents);
• billing and subscription records;
• Stripe identifiers and state;
• accounting and tax records;
• security and anti-abuse records, where necessary;
• PrivacyRequest and other evidence of handling deletion-related requests;
• operational and legal records necessary to establish, exercise or defend legal claims.

3.5 With respect to its own records, 404 Branding s.r.o. may act as an independent controller of personal data, as described in the Privacy Policy.

3.6 Closure and deletion of a workspace does not necessarily mean the deletion of every single piece of information 404 Branding s.r.o. is legally required to retain in connection with the commercial relationship.

4.1 For as long as a workspace remains active, 404 Emails generally retains Customer Data to the extent needed to provide the Service and in accordance with the Customer's use and instructions.

4.2 This Policy does not introduce automatic age-based deletion of campaigns, contacts, messages, or consent evidence unless such a mechanism is actually implemented in the Service.

4.3 The Customer remains responsible for determining whether its own Customer Data should continue to be retained under applicable law, even where the Service technically retains it.

5.1 Workspace closure is currently initiated exclusively through 404 Emails support (staff-assisted); a self-service button to close an account or workspace is not available at this stage.

5.2 The moment closure begins, the workspace's status changes to "closing" and a standard 30-day period until the scheduled permanent deletion is set.

5.3 When closure begins, in particular: every non-terminal campaign is cancelled; every active automation enrollment is stopped; API access keys are revoked; and, to a reasonable extent, cancellation of the related paid subscription is initiated.

5.4 During the closure period, Customer Data remains accessible and exportable; however, new sending and collection activity (sending campaigns, running automations, receiving form submissions, access via integrations/API) is restricted.

5.5 Closure may be cancelled during the 30-day period, again only through 404 Emails support; once permanent deletion has occurred, closure can no longer be cancelled.

5.6 Cancelling closure restores the ability to continue using the Service; it does not necessarily automatically restore already-cancelled campaigns, stopped automation enrollments, or the state of a paid subscription, which must be addressed separately.

6.1 Approximately 20 days after closure begins, 404 Emails will attempt to send a notice of the upcoming permanent deletion to the workspace owner's email address. Sending this notice is a good-faith attempt, not a guarantee; its failure does not, by itself, extend or stop the 30-day period.

6.2 After the 30-day period from the start of closure has elapsed, 404 Emails permanently deletes Customer Data from active systems in accordance with the implemented deletion process.

6.3 This deletion covers, in particular, data relating to:

• contacts;
• subscriptions and topics;
• consent evidence;
• suppressions;
• campaigns and their revisions;
• templates;
• contact groups, tags and segments;
• messages and delivery events;
• forms and their submissions;
• automations and related enrollments and messages;
• sending domains;
• integrations and API access keys.

6.4 The workspace itself is not physically removed from the database; its status changes to "deleted," and a record remains confirming that the workspace existed and was deleted. This record does not contain the former subscriber or contact database.

6.5 This Policy does not claim that: every byte of data instantly disappears from every physical medium; all copies held by third-party providers disappear instantly; backups are immediately overwritten; or that business records 404 Branding s.r.o. is legally required to retain are removed by this deletion.

7.1 After permanent deletion has been successfully carried out, 404 Emails will attempt to send a confirmation that deletion is complete to the former workspace owner, at the current email address recorded on the relevant user account.

7.2 Sending this confirmation is a repeated good-faith attempt; its delivery to every recipient in every circumstance is not guaranteed.

7.3 The confirmation request itself does not store a permanent copy of the recipient's email address; the email address is read from the current user-account record at the time of sending.

7.4 After sending, or after a reasonable number of sending attempts has been exhausted, only a narrowly scoped record remains confirming that deletion and a notification attempt occurred - not the content of the deleted Customer Data.

8.1 Before permanent deletion, the Customer may export available Customer Data, including throughout the entire 30-day closure period.

8.2 The export is provided as a file (ZIP) containing data in structured formats (e.g. CSV/JSON), to the extent currently supported by the Service - see the separate Data Portability page for details and the current technical description.

8.3 This Policy does not guarantee or promise that exported data can be re-uploaded into the Service using the bulk CSV contact import described in the Terms - CSV import supports only a limited set of contact fields, not the full range of exported data categories under Section 8.2.

8.4 After permanent deletion has occurred, the Customer cannot rely on 404 Emails to reconstruct or re-provide the deleted Customer Data.

8.5 The Customer is responsible for exporting, in good time, any consent or legal-compliance evidence it needs to retain for its own purposes, before the 30-day period elapses.

9.1 For as long as a workspace remains active, 404 Emails retains consent evidence to the extent needed to demonstrate the lawful basis for contacting individual contacts and to prevent unwanted contact with the same contacts.

9.2 The Customer may need consent or other lawful-basis evidence for its own legal-compliance purposes - see the Acceptable Use / Anti-Spam Policy, Section 4.

9.3 404 Emails does not promise to retain the Customer's former subscriber database or evidence of their consent on the Customer's behalf indefinitely after use of the Service ends.

9.4 Consent evidence is deleted together with the rest of Customer Data upon permanent deletion of the workspace under Section 6; it is not a hidden "compliance archive" retained for future use.

9.5 The Customer must export the consent evidence it needs to retain for its own purposes before the 30-day closure period elapses - see Section 8.

9.6 404 Emails' own narrowly scoped record that deletion occurred (see Section 14) is separate from, and does not replace, the Customer's consent database.

10.1 During active use of the Service, suppression, unsubscribe, hard-bounce and complaint records are retained to the extent necessary to prevent further unwanted or repeated contact with the affected contacts.

10.2 After permanent deletion of a workspace, 404 Emails does not retain the Customer's former list of suppressed or unsubscribed contacts for any other future use unrelated to that Customer.

10.3 The governing principle is that 404 Emails does not maintain a permanent database of suppressions or marketing contacts of former customers for its own future use.

11.1 Closure and permanent deletion of a workspace does not automatically delete the user account that was associated with that workspace as a member or owner.

11.2 A user account is separate from the Customer Data of any particular workspace; a single user account may be a member of multiple workspaces.

11.3 A user's membership in the workspace being closed is removed upon permanent deletion of the workspace; the user account itself, its login sessions, and its evidence of acceptance of legal documents (LegalAcceptance) are not affected.

11.4 No self-service function currently exists to delete an entire user account independent of workspace closure. Where a user requests deletion or another change to its personal data beyond the deletion of a particular workspace's Customer Data, it must contact 404 Emails at 404branding@gmail.com.

12.1 Login sessions have a limited validity period and are regularly removed from the application database after that period expires.

12.2 Short-lived security records used for purposes such as rate limiting also have a time-limited validity and are not retained as permanent records.

12.3 Short-lived verification tokens, used for example for password-reset, are intended for one-time use and have a time-limited validity. Unused tokens whose validity has expired are also regularly removed from the application database; they are not intended for long-term storage.

12.4 This Policy does not disclose security-sensitive implementation details of authentication, nor exact retention periods beyond what is stated here.

13.1 404 Emails does not store full payment-card details; payment processing is handled through a solution hosted by Stripe.

13.2 404 Emails retains limited billing identifiers and state (e.g. a Stripe customer and subscription identifier, subscription and plan status) necessary to administer the subscription and billing.

13.3 Billing, accounting, tax and related contractual records may be retained even after a workspace or account is closed, for the period required by applicable accounting and tax law or necessary for audit, fraud prevention, or the establishment of legal claims.

13.4 The specific statutory retention period varies by record type and applicable law. Under current Czech accounting law, this generally includes, for example, approximately 10 years for financial statements and annual reports and approximately 5 years for many other accounting documents and related records; this information is stated as general background, not as a binding interpretation for any specific category of 404 Emails record, and may change over time.

13.5 This Policy does not set a single retention period applicable to all billing or accounting data; the period required by applicable law for the specific record type always governs.

13.6 Billing and accounting records are not Customer Data within the meaning of Section 3, and retaining them after a workspace is deleted does not conflict with Section 6.

14.1 404 Emails may retain a narrowly scoped record that a deletion request, or a workspace closure and deletion process, occurred, including its status and timing, where necessary to demonstrate legal compliance or for internal accountability.

14.2 This record does not contain the content of the deleted Customer Data, only limited metadata such as the type and status of the request, timing information, and summary figures describing the scope of the deletion performed.

14.3 This record does not constitute a retained copy of the Customer's deleted marketing database and must not be treated as one.

14.4 Internal technical identifiers are not disclosed as part of this Policy.

15.1 404 Emails may, to a reasonable and necessary extent, retain narrowly scoped records for purposes such as: fraud prevention; investigating security incidents; investigating abuse of the Service; enforcing agreements; and the establishment, exercise or defence of legal claims, including compliance with legal or regulatory obligations.

15.2 This Policy does not create a blanket right to retain all Customer Data indefinitely for "security."

15.3 The scope of records retained on this basis is limited to what is reasonably necessary for the relevant purpose.

15.4 Operational logs are retained only to the extent reasonably necessary for operation, security, and troubleshooting; this Policy does not set a single fixed retention period for operational logs.

16.1 404 Emails maintains database backups for disaster-recovery and business-continuity purposes. A detailed technical description and the currently applicable backup retention cycles are set out in the DPA (Section 14.8 and Annex 2).

16.2 Deleting data from active systems does not necessarily immediately overwrite historical backups; deleted data may temporarily persist in finite backup copies until their set retention cycle expires.

16.3 Backup copies are not intended to be used to resume ordinary processing of a deleted Customer workspace's data.

16.4 Where restoration from a backup is necessary following a security or operational incident, the applicable deletion or processing-restriction requirements must be properly re-applied.

16.5 This Policy does not claim that backups are immutable beyond what is stated in the DPA, nor that the production server's data volume is encrypted in full (full-disk encryption).

17.1 Customer Data and related operational data may be processed through the subprocessors and other providers listed on the Subprocessors and Other Service Providers page, in particular the cloud-infrastructure and backup-storage provider (OVHcloud) and the email-sending infrastructure provider (Resend).

17.2 These providers may, to a limited extent, retain data in accordance with their own applicable retention and deletion processes and legal obligations.

17.3 404 Emails issues and processes deletion instructions in accordance with its contractual obligations toward these providers, but cannot guarantee instantaneous deletion from every system of every provider.

17.4 This Policy does not adopt or disclose specific provider-level retention periods beyond what is stated in the Subprocessor List, the DPA, or the Privacy Policy.

18.1 With respect to Customer Data, the Customer generally acts as controller. Requests from data subjects (e.g. the Customer's subscribers or contacts) relating to such data may therefore, to the extent 404 Emails acts as processor, be handled through, or in cooperation with, the relevant Customer.

18.2 404 Emails does not claim to be the controller of the Customer's subscribers' or contacts' personal data in every case.

18.3 With respect to its own records for which 404 Branding s.r.o. acts as an independent controller (e.g. user-account, billing, or security records), requests concerning data-subject rights under the GDPR may be sent directly to 404branding@gmail.com.

19.1 Retention and deletion practices may change over time as a result of product changes, legal obligations, security requirements, or changes at infrastructure providers.

19.2 404 Emails will give reasonable notice of material changes to this Policy, consistent with the general versioning and change-notice approach applied to the Terms.

19.3 The Customer's silence is not automatically treated as acceptance of a change in every circumstance.

19.4 The current version and effective date are always stated in the header of this Policy.

19.5 This Policy may be made available in Czech and in English. The Czech version shall prevail.

19.6 This Policy relates to, and where applicable refers to, the Terms (Section 11), the Privacy Policy (Sections 9-10), the Data Processing Agreement (DPA) (Section 14), and the Acceptable Use / Anti-Spam Policy.

19.7 Provider contact: 404branding@gmail.com.