Infra Technica Data Retention Policy

Revised and Published July 15, 2024
Purpose:

This Data Retention Policy establishes guidelines for the retention and disposal of data collected and processed by Infra Technica in Argentina. The purpose of this policy is to ensure compliance with Argentine legal requirements, safeguard sensitive information, and manage data efficiently.

Scope:

This policy applies to all data collected, processed, and stored by Infra Technica, including but not limited to customer information, financial records, employee data, and operational data. This policy applies to all Infra Technica locations within Argentine territory.

Data Categories and Retention Periods:

Below are the categories of data typically handled by Infra Technica, along with recommended retention periods. Retention periods may vary based on legal requirements, contractual obligations, and business needs, always respecting the minimum and maximum periods established by Argentine legislation.

Customer Data:
  • Active Customers: Data will be retained for as long as the customer relationship is active and for a period of five (5) years thereafter, in compliance with the general statute of limitations established in the Argentine Civil and Commercial Code for contractual claims.
  • Inactive Customers: Data will be retained for three (3) years after the termination of the business relationship for historical analysis or potential re-engagement purposes.
  • Prospective Customers: Data will be retained for one (1) year from its collection to support sales and marketing efforts unless the data subject requests its deletion earlier.
Financial Records:

Financial records, including invoices, receipts, and accounting documentation, will be retained for ten (10) years, as required by Argentine tax and regulatory authorities (AFIP) and the Civil and Commercial Code.

Employee Data:

Personnel records, including employment contracts, payroll information, and performance evaluations, will be retained for the duration of employment and for ten (10) years after the termination of employment, in accordance with Argentine labor and social security laws, and the statute of limitations of the Civil and Commercial Code. Employee files are kept for the same period.

Operational Data:

Operational data, such as transaction logs and system access records, will be retained for two (2) years for operational, security, troubleshooting purposes, and to comply with legal requirements.

Other Data Types:
  • Personal Details: Name, email, telephone number, company name, job title, will be retained for the duration of the commercial relationship and then for three (3) years, unless the data subject requests their deletion earlier.
  • Account Information: Username and password, will be retained for as long as the user maintains the account active.
  • Financial Information: Billing and payment information (credit card or ACH), will be retained for as long as necessary for payment processing and then for ten (10) years as required by AFIP.
  • Automatic and Device Information: IP address, browsing history, interactions with the website, applications, or advertisements. These will be retained for as long as necessary for the provision of the service and no longer than 2 years.
  • Views and Opinions: Feedback, survey responses, will be retained for as long as deemed relevant to the feedback, and for a maximum of 2 years.
  • Communications: Records of chats, phone calls, or video calls, will be retained for the duration of the communication, unless there is a contractual obligation that determines otherwise, and for a maximum of 2 years.
Data Storage and Security:
  • Data shall be stored securely using industry-standard encryption and access controls. Access to data shall be restricted to authorized personnel only, based on the principle of need-to-know.
  • Users are informed that Infra Technica uses Google Analytics to analyze website usage. You can learn more about Google’s privacy practices here: https://www.google.com/policies/privacy/.
Data Disposal:

Data that has reached the end of its retention period shall be securely disposed of using methods that prevent unauthorized access, such as shredding physical documents and securely deleting digital data by overwriting the space with random information. Disposal procedures shall be documented and regularly reviewed for compliance.

Data Subject Rights:

In accordance with the Personal Data Protection Law No. 25,326, data subjects have the right to:

  • Access: Request and obtain information about their personal data included in Infra Technica’s files, records, or databases.
  • Rectification: Request the correction of inaccurate or incomplete data.
  • Update: Request the update of outdated data.
  • Erasure: Request the deletion of their data when it is no longer necessary for the purposes for which it was collected, when the retention period has expired, or when the data subject has withdrawn their consent.
  • Confidentiality: Infra Technica will maintain the confidentiality of personal data, an obligation that will subsist even after the relationship with the data subject has ended.

To exercise these rights, data subjects can contact Infra Technica’s Legal Department via email at [email protected].

Review and Update:
  • This policy shall be reviewed annually and updated as necessary to reflect changes in legal requirements, business practices, or technological advancements.
Compliance:

All employees and contractors are responsible for complying with this Data Retention Policy and related procedures. Non-compliance may result in disciplinary action, up to and including termination of employment or contract.

Training and Awareness:

Employees shall receive training on data retention practices and their responsibilities under this policy. Regular awareness programs shall be conducted to reinforce the importance of data protection and compliance.

Document Control:

This policy shall be maintained and accessible to all employees via Infra Technica’s internal communication channels. Previous versions of this policy shall be archived for reference.

Contact Information:

For questions or concerns regarding this Data Retention Policy, please contact Infra Technica’s Legal Department, designated as the data protection officer, at [email protected].

Approval:

This Data Retention Policy has been approved and adopted by Infra Technica on July 15, 2024.