Data Retention Policy
Lingly Limited
Last Updated: 29 May 2026 Version: 2.0
1. Purpose and scope
This policy defines how long Lingly retains personal data under UK GDPR. We retain data only as long as necessary for legitimate business purposes and delete it securely when no longer needed.
2. General principles
Lawful basis: we retain data only while we have a lawful basis for processing. Proportionality: retention periods are proportionate to the purpose. Regular review: we review stored data and delete when appropriate. Secure deletion: data is securely deleted or anonymised when retention expires.
3. Retention periods by data category
3.1 User account data
| Data Type | Retention Period | Justification |
|---|---|---|
| Core account info (name, email) | Account lifetime + 12 months after last login | Service provision + potential reactivation |
| Authentication data (password hashes, tokens) | Account lifetime only | Security — deleted immediately on account closure |
| Learning preferences (timezone, daily commitment) | Account lifetime + 6 months | Service personalisation |
3.2 Assessment and learning data
| Data Type | Retention Period | Justification |
|---|---|---|
| Module progress / completion | 3 years after completion | Skills development tracking |
| Learner speech audio | Deleted immediately after processing | Transient processing only; not stored |
| Practice session transcripts | 18 months after creation | Learning analytics + improvement |
3.3 Communication data
| Data Type | Retention Period | Justification |
|---|---|---|
| AI exercise logs (all AI-driven exercises and roleplay sessions) | 12 months after creation | Service improvement + support |
| Corrections and feedback | 18 months after creation | Learning analytics |
| Notification logs | 6 months after sending | Delivery tracking + debugging |
3.4 Analytics and system data
| Data Type | Retention Period | Justification |
|---|---|---|
| Usage analytics (aggregated) | 3 years | Business intelligence + product development |
| Application / error logs (BetterStack) | Logs 3 days; metrics 30 days | System maintenance + debugging |
| Error alerts (Slack) | 90 days | Operational alerting |
| Audit logs | 7 years | Legal compliance + security investigations |
3.5 Marketing and consent data
| Data Type | Retention Period | Justification |
|---|---|---|
| Marketing consent records | 3 years after consent withdrawn | Legal compliance + proof of consent |
| Email marketing data | Until consent withdrawn + 30 days | Compliance with marketing regulations |
3.6 Provider / admin data
| Data Type | Retention Period | Justification |
|---|---|---|
| Provider admin accounts | Contract lifetime + 6 years | Business relationship + tax/legal |
| Contract and billing data | 6 years after contract end | Tax compliance + dispute resolution |
4. Special circumstances
4.1 Early deletion triggers
Data may be deleted earlier if: the user exercises the right to erasure; the account is deleted voluntarily; data becomes inaccurate and cannot be corrected; or processing becomes unlawful.
4.2 Extended retention
Data may be retained longer for: legal proceedings (until resolution + 12 months); regulatory investigations (until resolution + statutory limitation period); safeguarding concerns (until the risk is assessed as resolved).
4.3 Anonymisation
Where possible, personal identifiers may be removed to create anonymous datasets for product-improvement research, academic partnerships, or statistical analysis. Anonymous data is not subject to retention limits.
5. Implementation
5.1 Automated deletion
Automated processes flag data approaching retention limits, delete expired data, and generate deletion reports for audit.
5.2 Manual review
A monthly review checks for data past retention, reviews anonymisation opportunities, and updates schedules where business needs change.
5.3 User rights
Users can request deletion before scheduled retention expires, data portability before account closure, and information about what data we hold and for how long.
6. Documentation and audit
We keep records of when data was deleted and by what process, extended-retention decisions and justifications, user deletion requests and responses, and policy reviews.
7. Roles and responsibilities
Data Protection Officer: policy oversight and compliance. Engineering: implementation of automated deletion. Customer Success: handling user deletion requests. Directors: reviewing retention periods against regulatory requirements.
8. Policy review
Reviewed annually, or when regulations change, business practices change, new data types are collected, or incidents occur.
Contact
support@lingly.ai, or the DPO at harry@lingly.ai.