Purpose of Data Retention Policy
This policy governs Personal Data processing for Boss Level Oy and Boss Level FZE, with clearly defined responsibilities:
TeknoParrot Licensing Structure
Exclusive License Arrangement
TeknoParrot software and trademarks are licensed exclusively to Boss Level Oy Limited for commercial distribution and operations.
Boss Level Oy (Finland) - Exclusive Licensee:
As exclusive licensee, responsible for:
- All legal compliance and representation
- All customer data, technical data, and operational data
- End-user license distribution and management
- Third-party license management (VMProtect, website hosting, and other operational licenses)
- User support and customer service
- Product analytics and performance data
- All customer communications and support records
Boss Level FZE (UAE) - Separate Independent Sales Entity:
Operating as separate entity:
- Sales transaction processing (operates independently, not under Boss Level Oy's direction)
- Website automatically generates license keys upon completed sales
- ONLY sales transaction data necessary for purchase processing
- NO customer support, technical, or operational data
- NO involvement in software development or emulator-related data
- NO licensing rights or intellectual property involvement
Guiding Data Retention Principles
- Fairness: Processing must be proportionate and compatible with collection purposes
- Necessity: Personal Data deleted when no longer needed
- Security: Appropriate security measures across all processing
- Minimal Processing: Boss Level FZE processes only sales-essential data
Entity-Specific Data Retention
Boss Level Oy Data Retention:
- Customer Support Records: 3 years after last interaction
- Technical Support Data: 2 years after resolution
- License Usage Analytics: 1 year (anonymized)
- Website Analytics: 12 months (anonymized)
- Customer Communications: 3 years after last contact
- Software Development Data: Per project lifecycle
- Security Logs: 12 months maximum
Boss Level FZE Data Retention:
- Sales Transaction Records: 7 years (tax compliance only)
- Customer Purchase History: 3 years maximum
- Financial Records: As required by UAE law
- NO retention of: Technical data, support communications, software usage data, or any emulator-related information
Paddle Data Retention:
- Processed according to Paddle's retention schedule
- Payment and billing data per their policies
Data Processing Responsibilities
Boss Level Oy Processes:
- All product development and technical data
- Customer support and communication records
- Software analytics and performance metrics
- User account and preference data
- Security and fraud prevention data
- All emulator-related operational data
Boss Level FZE Processes:
- ONLY data necessary for sales transactions
- Customer name and email for purchase completion
- Transaction history for financial compliance
- EXPLICITLY EXCLUDES: Any technical, support, or product-related data
Data Deletion Procedures
Data Deletion Process:
- Boss Level Oy handles data subject requests for customer and operational data
- Boss Level FZE (separate entity) manages deletion of its own sales transaction data
- Each entity independently processes requests for data under their control
- Regular 6-month reviews for data eligible for deletion
Deletion Timeline:
- Data Subject Requests: Within 30 days
- Routine Cleanup: Every 6 months
- Legal Hold: Suspended during litigation or regulatory inquiry
Legal Compliance
Boss Level Oy Compliance:
- Finnish data protection law
- EU GDPR requirements
- Software licensing regulations
- Customer support regulations
Boss Level FZE Compliance:
- UAE data protection requirements
- Financial record keeping laws
- Sales transaction regulations
- NO compliance burden for software or technical regulations
Data Subject Rights Coordination
Boss Level FZE Cannot:
- Independently handle data subject requests
- Provide technical or support-related data (doesn't possess it)
- Make decisions about data retention periods
- Handle customer communications about data protection
Security Measures
Boss Level Oy Security:
- Comprehensive data protection for all operational data
- Technical safeguards for software development data
- Customer communication encryption
- Regular security audits and updates
Boss Level FZE Security:
- Limited to sales transaction data only
- Financial data protection measures
- Secure data transfer to Boss Level Oy when needed
- No access to technical, support, or operational systems
Regular Review Process
Responsibility:
Boss Level Oy coordinates reviews
Documentation:
All deletion activities logged and documented
Scope:
- Boss Level Oy: All data categories
- Boss Level FZE: Sales transaction data only
Contact Information
Policy Updates
This policy may be updated to reflect changes in legal requirements or business operations. Updates posted at: teknoparrot.com/data-retention-policy
Policy Information
Effective Date: December 28, 2024
Last Updated: December 28, 2024
Governed by: Finnish law, EU GDPR, and applicable UAE regulations for sales activities only
Important: Boss Level FZE is a separate independent entity whose data processing is limited exclusively to sales transaction processing. Website automatically generates license keys upon sale completion. All other data processing conducted by Boss Level Oy.