1. Purpose and Scope

This Data Retention and Deletion Policy ("Policy") describes how Orange Sky Software Inc. ("Orange Sky," "we," "us," or "our") collects, retains, and deletes data in connection with the Echosaw Media Intelligence product ("Echosaw" or "the Product").

Echosaw is a cloud-based media intelligence platform where Users upload, submit, or connect media sources (e.g., links, files, search queries, monitored feeds) and generate outputs such as reports, alerts, summaries, analytics, and insights ("User Content" and "Generated Content").

We are committed to data minimization, storage limitation, and secure deletion practices in compliance with applicable privacy laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA/CCPA), and other relevant regulations. This Policy supplements our Privacy Policy, AI Use and Disclosure Policy, Terms of Service, and any applicable agreements.

This Policy applies to all data processed through Echosaw, including User Content, Generated Content, metadata, logs, and any derived or processed data.

2. Data Retention Principles

We retain data only for as long as necessary to fulfill the purposes for which it was collected or processed, including:

• Providing and maintaining the Product services
• Processing User requests and generating outputs
• Supporting account management, billing, and customer support
• Ensuring platform security, fraud prevention, and abuse detection
• Complying with legal obligations (e.g., audit trails, dispute resolution)
• Improving the Product (aggregated/anonymized usage analytics only; no training of external models on User Content without explicit opt-in consent)

Retention periods are determined based on operational needs, legal requirements, and the principle that personal data and sensitive User Content should not be kept longer than reasonably necessary.

3. Specific Retention Periods

The following outlines standard retention for key categories of data in Echosaw:

• User-Submitted Media and Content: Retained for 14 days for Single-Shot purchases (Basic and Premium) or 90 days for Subscription plans (Pro and Agency) from the date of submission or last processing activity. Automatically and permanently deleted after the applicable retention period unless a User explicitly requests extension via support (subject to approval and potential additional fees).
• Generated Reports, Summaries, Insights, Alerts, and Other Outputs: Retained for 14 days for Single-Shot purchases (Basic and Premium) or 90 days for Subscription plans (Pro and Agency) from the date of generation or last access/view. Automatically and permanently deleted after the applicable retention period. Users may export/save outputs locally at any time during the retention window.
• Account Metadata and Profile Information: Retained for the duration of the active subscription/account plus a 30-day grace period after cancellation/termination to allow for reactivation or data export requests. Thereafter, deleted unless required for legal/compliance reasons.
• Usage Logs and Analytics Data: Retained for up to 12 months to support product improvement, troubleshooting, and billing reconciliation.
• Security and Audit Logs: Retained for 90 days (or longer if required by law or for active incident response).
• Billing and Payment Records: Retained for 7 years to comply with tax, accounting, and financial regulations.
• Data Subject to Legal Hold: If we receive a valid legal request (e.g., subpoena, court order, preservation notice), relevant data may be retained beyond standard periods until the legal matter is resolved.

4. Automatic Deletion Process

• Echosaw implements automated deletion routines that permanently and irreversibly remove data after the applicable retention period expires.
• Deletion includes removal from primary storage, backups (within backup rotation cycles), and any derived indexes/caches.
• We use secure deletion methods (e.g., cryptographic wiping/overwriting) to prevent recovery.

5. User Rights and Requests

• Access and Export: During the 14-day window, Users may access, download, or export their User Content and Generated Content via the Product interface.
• Deletion Requests: Users may request earlier deletion of their data (subject to verification and any active subscription obligations). We will process verifiable deletion requests in accordance with applicable law (e.g., GDPR right to erasure, CPRA right to delete), typically within 45 days.
• Retention Extensions: If longer retention is required for legitimate business or legal reasons (e.g., ongoing litigation support), Users may contact support to discuss options.
• We honor data subject rights requests consistent with our Privacy Policy.

6. Exceptions and Compliance

• We may retain data longer than stated if required by law, regulation, or binding legal process.
• Necessary to protect our rights, safety, or property (or that of Users/third parties).
• Pursuant to a User’s explicit consent for extended retention.

We regularly review retention practices to align with evolving legal requirements (e.g., EU AI Act traceability obligations, CPRA disclosure rules) and technological best practices.

7. Updates and Contact

This Policy may be updated periodically to reflect changes in law, Product features, or our practices. Material updates will be communicated via email, in-app notification, or posting on our website.

Questions, requests, or concerns? Contact: contact@orangesky.ai.

By using Echosaw, you acknowledge and agree to this Policy.