Skip to main content

Cloud Policy and Personal Data Retention

Purpose​

This documentation outlines our Cloud usage, Personal Data Retention, and Data Breach response to ensure compliance with GDPR and other applicable regulations.

It is designed as a living document to be expanded as modules are completed.


Cloud Usage Policy​

Cloud Providers and Data Locations​

Cloud ServicePurposeData Location
Firebase FirestoreApplication data storage and backupFrankfurt, Germany
StripePayment processing and subscriptionsEU Data Region

Data Types Stored​

  • Personal Identifiable Information (PII)
  • Payment and billing information
  • Usage data, logs, and metadata
  • Media uploads (if applicable)
  • Device data (if necessary for the service)

Access Management​

  • Role-Based Access Control (RBAC)
  • Mandatory Multi-Factor Authentication (MFA) for administrative access
  • Access logs monitored and stored securely

Data Retention Policy​

Retention Matrix​

Data CategoryRetention PeriodNotes
User Account Data5 years post inactivityAnonymization applies after the period
Payment Records (Stripe)10 yearsCompliance with tax obligations
Communication Logs3 yearsIncludes emails, support chats
Analytics & Usage Data2 yearsAggregated beyond this period
Backups (Firestore)30 daysAuto-deletion configured
Media ContentUntil account deletion or requestUser-controlled deletion possible

Deletion and Anonymization Process​

  • Soft deletion with recovery window where applicable
  • Hard deletion from production and backup systems
  • Data anonymization after the expiration of retention periods

Data Breach Procedure​

Based on the approved Data Breach Management Policy.

Key Steps:​

  1. Identify and analyze the breach
  2. Contain the breach and mitigate risks
  3. Notify the Supervisory Authority within 72 hours if required
  4. Notify affected users if the breach presents a high risk
  5. Document all breaches, including false positives
  6. Review and improve security controls

Reporting​

All potential incidents must be reported immediately to the Privacy Officer at: privacy@tomorrowtech.it.


User Rights​

  • Access: Users can request their data in a portable format
  • Deletion (Right to be Forgotten): Data can be erased upon verified request
  • Correction: Users can update or correct their personal information

Security Measures​

  • Data encrypted in transit (TLS 1.3) and at rest (AES-256)
  • Regular vulnerability assessments and penetration tests
  • Strict vendor agreements (DPA) in place with Firebase and Stripe
  • Backups stored securely and tested periodically

Third-Party Processors​

ProcessorPurposeCompliance
StripePayment processingPCI-DSS Level 1, EU Storage
FirebaseCloud database, storageGDPR Compliant, Frankfurt server location

Data Location​

ServiceHosting CountryOwnership
FirebaseGermany (Frankfurt)Google-owned infrastructure
StripeEuropean UnionStripe EU infrastructure

Review and Updates​

ResponsibilityCompliance / Legal Officer
Review CycleAnnual
Next Review Date26/03/2026
Last Reviewed26/03/2025

This documentation is subject to updates as processes and technologies evolve. For questions or updates, contact privacy@tomorrowtech.it.