Data Retention Schedule and Policy
Internal and operational retention schedule specifying retention periods, statutory bases, and automated erasure mechanisms across all data categories.
Table of Contents
Notice: Engineering compliance draft for Mareante (not yet reviewed by an independent attorney).
1. Principles and Legal Framework
The Mareante platform enforces the principle of storage limitation pursuant to Article 5(1)(e) of Regulation (EU) 2016/679 (GDPR) and Article 6 of the Swiss Federal Act on Data Protection (nFADP). Personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, or as mandated by statutory retention obligations.
This document establishes the operational retention lifecycle, technical deletion mechanisms, and statutory justifications across every category of data handled by the platform.
2. Comprehensive Data Retention Schedule
| Data Category | Purpose & Description | Primary Storage Location | Retention Period | Statutory / Operational Basis | Technical Erasure / Anonymisation Mechanism |
|---|---|---|---|---|---|
| User Account Credentials & Profiles | Authentication, 2FA enforcement, and workspace authorization (FR-ID-01–FR-ID-02). | PostgreSQL database (users table). | Active duration of user account + 30 days post-cancellation grace period. | Contract performance (GDPR Art. 6(1)(b) / Swiss nFADP Art. 31(2)(a)). | Cryptographically purged upon account closure or tenant deletion (FR-AU-05). Passwords stored solely as Argon2id hashes. |
| Live Voice Audio Streams | Real-time speech interaction with the agent (FR-VC-01). | In-memory RAM buffers / ephemeral WebSockets. | Ephemeral (seconds); stream discarded immediately upon speech synthesis / chunk processing. | Contract performance (GDPR Art. 6(1)(b) / Swiss nFADP Art. 31(2)(a)). | Zero persistent storage on physical disk; RAM freed immediately upon WebSocket frame consumption. |
| Spoken Dialogue Transcripts & Chat History | Maintaining conversation context across sessions; enabling voice-to-text switching (FR-VC-03). | PostgreSQL database (conversations, messages tables). | Duration of active project or tenant lifecycle. | Contract performance (GDPR Art. 6(1)(b)). | Automatically purged when the corresponding project is deleted by user or upon tenant deletion (FR-AU-05). |
| Project Specifications, Plans & Memory | Versioned technical requirements, task graphs, recorded project standards (FR-IN-04, FR-PL-01, FR-ME-01–FR-ME-03). | PostgreSQL database (specs, plans, memory tables). | Retained for the duration of the project. | Contract performance (GDPR Art. 6(1)(b)). | Directly editable and deletable by users (FR-ME-03); permanently wiped on tenant deletion (FR-AU-05). |
| Sandbox Execution Containers & Volumes | Sandboxed Docker environments running automated builds, tests, and lints (FR-EX-01). | Docker container runtime & ephemeral local volume mounts. | Ephemeral (duration of the run); destroyed immediately upon completion or cancellation (FR-EX-07). Artifacts cached max 7 days. | Contract performance; security containment. | Container destroyed via docker rm -f; ephemeral storage volumes pruned and unlinked. |
| Cryptographic Hash-Chained Audit Logs | Non-repudiable audit trail for approvals, role grants, secret usage, and deployments (FR-AU-01–FR-AU-02). | PostgreSQL database (audit_log table) with append-only hash chains. | 12 months from the date of event entry. | Legitimate interest (security verification, dispute resolution) & DSA compliance (GDPR Art. 6(1)(f)). | Automated scheduled cleanup script purges log entries older than 12 months after archival digest verification. |
| Billing Records, Invoices & Spend Ledgers | Plan subscriptions, invoices, spend ledger balances, and payment confirmations (FR-BL-01–FR-BL-12). | PostgreSQL database (ledger_entries, billing_invoices tables) & Stripe. | 10 years following the end of the relevant fiscal business year. | Legal statutory duty under Swiss Code of Obligations (CO Art. 958f) and EU tax legislation. | Archived in immutable read-only storage; accessible solely for tax audit purposes; hard deleted after 10-year expiration. |
| Third-Party Connector Secrets & API Tokens | Tokens for Git hosts, cloud deployments, and external tools (FR-SC-01–FR-SC-02). | Encrypted vault storage via SecretBroker with tenant-specific encryption keys. | Retained only while the connector is actively authorized by the Admin. | Contract performance; security containment. | Immediate cryptographic erasure upon connector removal, tenant deletion (FR-AU-05), or Emergency Breach Rotation (FR-SC-09). |
| Safety Guardrail & Moderation Records | Records of blocked unlawful prompts, statements of reasons, and strike history (guardrails package). | PostgreSQL database (moderation_records table). | 24 months from the date of recorded violation. | Statutory compliance under Digital Services Act (DSA Art. 17) and defense against legal claims. | Automatically archived and purged after 24 months. |
3. Technical Deletion and Portability Procedures
3.1. Tenant-Wide Data Export (FR-AU-04)
- Self-Service Export: At any time during an active subscription or within the 30-day post-cancellation grace period, a Tenant Owner may trigger a full export of tenant data.
- Export Format: Structured JSON archive accompanied by project source repositories in standard
.tar.gzformat, satisfying GDPR Article 20 and Swiss nFADP Article 28 data portability standards.
3.2. Cascading Cryptographic Deletion (FR-AU-05)
- When a Tenant Owner executes the "Delete Tenant" action:
- The backend immediately disables all active user sessions and API tokens associated with the tenant;
- All running Docker execution sandboxes are terminated and removed;
- All database rows bearing the tenant's
tenant_idacross all tables (users, projects, specs, plans, conversations, memory, extensions) are permanently deleted via database cascading delete triggers; - Per-tenant data encryption keys stored in key management are cryptographically shredded, rendering residual backup blocks unreadable;
- The tenant deletion event is recorded as a final entry in the system operational audit trail before session termination.
3.3. Emergency Breach Rotation (FR-SC-09)
- In the event of a security compromise, an Owner or Admin can trigger an instantaneous breach rotation.
- Effect: Active sessions, scoped tool tokens, and database encryption keys are invalidated immediately without awaiting scheduled retention windows, halting all running containers and blocking data exfiltration.
4. Policy Administration and Review
This Data Retention Schedule is administered by Platform Engineering and reviewed annually to ensure ongoing conformance with Swiss and European statutory retention developments.