Data Retention Policy

Status: Enforced•Effective Date: December 31, 2025

Section 1

Legal Status of Published Passports

Published Digital Product Passports are acknowledged as legal and regulatory records. These records are immutable; they are never deleted or modified. Retention is justified under GDPR Article 17(3) (legal obligation exemption).

Section 2

Tenant / Organization Deletion

A tenant or organization may be deleted from the system at any time upon request (GDPR Right to Erasure).

Deleted Data

User Accounts
Personally Identifiable Information (PII)
API Access Keys
UI Dashboard Access
Shopify Connections

Retained Data

Published passports (Immutable)
Cryptographic proofs

Section 3

Orphan Passport Policy

It is an intentional design choice that passports remain verifiable and cryptographically valid even if the issuing tenant is deleted. This ensures long-term regulatory compliance beyond the lifespan of the issuing entity.

Verification Logic

Integrity:Refers to cryptographic authenticity and immutable proof.
Commercial Validity:Refers to the authorization for commercial use.

Section 4

Commercial Validity (Lease Model)

At Publish Time

The passport is issued as an immutable record. The field commercial_valid_until is set to the end of the first billing period. This field is explicitly excluded from all hash calculations.

Recurring Extension

While the tenant is active and paid, the validity period is extended. This operation does not alter the legal record; it serves only to extend commercial usage rights.

Expiration

When payment stops or the tenant is deleted, commercial validity expires. Verification will return:

Integrity: VERIFIED

Commercial use: EXPIRED

Issuer status: INACTIVE / DELETED

Section 5

Demo / Free Tenant Rules

Demo and Free tenants may create drafts, preview data, and generate runtime projections; however, publishing and issuance are not permitted. This policy is enforced to prevent abuse of the platform.

Section 6

Binding Policy Summary

Published Digital Product Passports are immutable legal records and are never deleted.
Retention is justified under GDPR Article 17(3).
Tenant deletion is permitted; PII and access keys are deleted/anonymized.
Orphaned passports remain cryptographically verifiable.
Verification distinguishes between Integrity and Commercial Validity.
The validity date is not hashed and extends only with active payment.
Expired commercial validity does not invalidate cryptographic integrity.
Demo tenants cannot publish.

This section is binding.