# Data retention and deletion matrix

**Service Provider / Operator:** Brillnet Piotr Adamski, ul. Henryka Sienkiewicza 73/6, 90-057 Łódź, Polska, NIP 7321779060, REGON 101551294

**Service contact:** [kontakt@wm-admin.pl](mailto:kontakt@wm-admin.pl)

**Privacy and breach contact:** [privacy@brillnet-app.com](mailto:privacy@brillnet-app.com)

**Website:** [wm-admin.pl](https://wm-admin.pl/?lang=en)

**Version:** 2026-10-12-beta.2

This is an informational translation. The Polish version is binding.

## 1. Principles

1. For Customer Data, the Customer determines retention as controller. WM Administrator provides policies per category, legal preservation holds, reporting and deletion execution.
2. A default does not replace legal analysis or the Customer's documentation. The Customer approves periods before using real data.
3. Production deletion is logical and physical according to the architecture. Residual backup data expires within 90 days and does not return to normal use.
4. A legal hold preserves only the data and duration necessary for an obligation or dispute. It is documented, access-restricted and reviewed periodically.

## 2. Data for which Brillnet is controller

| Category | Rule |
|---|---|
| Terms/DPA acceptance event and authority | Agreement duration + 6 years, or longer while a claim remains active |
| account data | until account deletion/Agreement termination; necessary security traces remain according to log retention |
| invoices and tax documents | the period required by tax and accounting law, generally 5 years calculated under the applicable statute |
| Stripe subscription and transaction data | Agreement duration + the period for settlements, taxes and claims |
| security log and acceptance audit | at least 12 months; longer for an incident or claim |
| standard operational log | 90 days |
| support requests and complaints | 3 years after closure; longer for a dispute |
| prospective customer without marketing consent | 12 months from the last substantive contact |
| marketing and objections | until withdrawal/objection; evidence of consent and objection for the claims period |

## 3. Customer Data — configuration catalogue

| System category | Initial recommendation for Customer approval | End event |
|---|---|---|
| Ownership and legal titles | duration of the right to the unit + 10 years | disposal/termination of the right |
| Charges and balances | 6 years | accounting year end / settlement |
| Accounting and tax | tax/accounting period, usually 5 years under the applicable counting rule | year/period end |
| Payments and bank imports | 6 years | posting/year end |
| Resolutions and votes | Community lifetime + archival period set by the Customer | resolution closure |
| Meetings and minutes | Community lifetime or shorter if the document has no lasting significance | approval of minutes |
| Contracts and procurement | contract duration + 6 years | contract end |
| Technical and building records | asset/equipment service life + liability period | replacement/decommissioning |
| Cases and complaints | 3 years after closure; 6 years if linked to a claim | case closure |
| Communications | 3 years or less if the message loses its purpose; move important arrangements to the appropriate category | sending/thread closure |
| Authorisations and roles | authorisation duration + 6 years for evidence | revocation/expiry |
| Security and audit | at least 12 months | event |

Initial periods are a conservative working configuration, not universal statutory deadlines. A Community may need a different rule, especially for building records, disputes, resolutions and special categories of data.

## 4. Deletion process

1. The system identifies candidates by category and end event.
2. An authorised User receives a report and may apply a legal hold.
3. High-risk operations require confirmation and an audit log.
4. Deletion covers search indexes, document versions, attachments and derived data unless they have an independent basis for retention.
5. The final report identifies scope, time, actor, exceptions and backup expiry date.

## 5. Agreement termination

After termination: 90 days of read-only access/export, followed by production deletion and up to 90 days for backups to expire. Production deletion may occur earlier on the Customer's documented instruction.

## Scope of backup periods

D1/R2 windows concern application infrastructure. They are not universal retention statements for every email-provider or other recipient copy. Sending data, own billing and security require separate role, purpose, retention and basis mapping. Deletion requests are assessed accordingly; a supplier term alone does not replace a legal basis or customer instruction.

## Switching providers — Data Act

For a data processing service covered by Regulation (EU) 2023/2854, we apply switching and export rights. From 12 January 2027, we do not charge switching fees prohibited by Article 29. Separately commissioned work may be charged only where lawful; it cannot circumvent free switching or restrict required assistance. The relevant service terms set out export scope and timing.

Requests to switch provider, port to on-premises infrastructure or erase without switching may be sent to the service contact. For a service within the Data Act, notice does not exceed two months and the standard transitional period does not exceed 30 calendar days. We provide required assistance, security and continuity of contracted functions. If 30 days is technically unfeasible, within 14 working days of the request we give reasons and an alternative period of at most seven months. The customer may extend the transition once. Data remain retrievable for at least 30 days after it ends. Export exclusions cannot impede or delay switching. A preservation hold alone does not bar export; restrictions require a specific basis and scope. Contract termination and deletion are coordinated with this procedure and the customer’s instructions.

The agreement for the service subject to switching ends when switching succeeds, or after the notice period for erasure without switching. This procedure takes precedence over a conflicting general end-of-paid-period term. The 90-day window does not shorten the right to retrieve data for at least 30 days after transition. Export includes customer structured data, settings, documents and attachments. Proprietary code, secrets, internal safeguards and other customers’ data are excluded only without impeding portability. Extra work is quoted only beyond required assistance and where lawful.


> Contact details and domains in this presentation were updated on 2026-09-08. The original document and previous acceptances remain unchanged.