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
TeknoParrot software, trademarks, and intellectual property are owned by Nico Mario Giansanti (the "IP Owner"), who resides in the United Arab Emirates.
The IP Owner has granted separate licenses to:
- Boss Level Oy Limited (Finland) - Legacy Platform operations
- Boss Level FZE (UAE) - New Platform operations
Boss Level Oy (Finland) - Legacy Platform 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.