Data Retention and Deletion Policy

Time4IT Sp. z o.o.
Plonowa 24I / 2, 05-500 Nowa Wola, Poland

KRS: 0001140137
NIP: 1231569806

For privacy-related questions, please contact:

Version: 1.0
Effective Date: 23 June 2026

1. Purpose

The purpose of this policy is to establish requirements for retaining, archiving and securely deleting information processed by ECOMMIGO GROUP Sp. z o.o.

The Company seeks to ensure that information is retained only for as long as necessary and is securely deleted when no longer required.

2. Scope

This policy applies to:

Personal data
Customer information
Business information
Operational records
System logs
Documentation
Backup data

3. Retention Principles

Information shall be retained only when necessary for:

Business operations
Contractual obligations
Legal requirements
Accounting requirements
Security purposes
Dispute resolution

The Company follows the principle of storage limitation.

4. Retention Periods

Retention periods may vary depending on:

Type of information
Legal obligations
Business requirements
Security requirements

Information shall not be retained indefinitely unless a legitimate reason exists.

5. Data Subject Requests

Where applicable, the Company may receive requests relating to:

Access
Rectification
Erasure
Restriction of processing

Such requests shall be reviewed and handled in accordance with applicable laws and contractual obligations.

6. Secure Deletion

When information is no longer required, the Company shall take reasonable steps to ensure secure deletion.

Deletion methods may include:

Removal from active systems
Deletion from storage environments
Secure destruction procedures
Anonymization where appropriate

7. Backup Data

Backup systems may contain historical information retained for recovery and continuity purposes.

Backup retention periods are determined according to operational and security requirements.

Expired backups may be deleted according to established procedures.

8. End of Customer Relationship

Upon termination of a customer or partner relationship, information may be retained only where necessary to:

Meet legal obligations
Resolve disputes
Maintain security records
Fulfill contractual requirements

Information that is no longer required shall be deleted or anonymized.

9. Responsibilities

Management is responsible for ensuring that appropriate retention and deletion practices are maintained.

Personnel are responsible for following applicable procedures and reporting potential issues.

10. Policy Review

This policy shall be reviewed annually or following significant legal, operational or technological changes.

Approval

Prepared and approved by:

Mateusz Michał Śliwka
President of the Management Board