211 N Union St suite 100, Alexandria, VA 22314, USA

This Data Retention & Secure Disposal Policy (the “Policy”) explains how AllCalls Technologies, Inc. (d/b/a “AllCalls.io”) (“AllCalls,” “we,” “us,” or “our”) retains, returns, deletes, and securely disposes of information processed through our website, platform, APIs, communications features, call delivery and routing services, and related support operations (collectively, the “Services”).

This Policy supplements our Privacy Policy, Terms & Conditions, and any applicable customer agreement, data processing addendum, business associate agreement, order form, or statement of work.

The periods below are our standard retention periods. Applicable law, a valid legal or regulatory hold, or a signed customer agreement may require a different period or process. Where requirements differ, AllCalls applies the shortest period that satisfies all binding requirements.

1) Purpose and Scope

This Policy applies to Customer Data and the operational, security, commercial, and compliance records needed to provide and support the Services. It covers information maintained in active applications, databases, call recording systems, transcripts, analytics stores, logs, archives, backups, exports, and approved subprocessor systems.

“Customer Data” includes content supplied by or collected on behalf of a customer, such as call audio, transcripts, caller or lead information, messages, files, account and campaign configuration, billing information, service telemetry, analytics, and related metadata.

2) Retention Principles

• Purpose limitation. We retain information only for a documented service, customer, legal, regulatory, security, fraud-prevention, dispute, accounting, audit, or other legitimate business purpose.
• No indefinite default retention. Customer Data is assigned a retention period and a disposal process rather than being kept indefinitely by default.
• Customer direction. When we process Customer Data on a customer’s behalf, the signed customer agreement and approved retention settings govern to the extent permitted by law.
• Minimum necessary period. We use the shortest period that satisfies binding legal, regulatory, contractual, and documented business requirements.
• Consistent treatment of copies. Transcripts, summaries, indexes, cached copies, embeddings, exports, and other data derived from Customer Data generally follow the source data’s retention period unless they have been validly de-identified.
• Approved environments. Customer Data may be stored only in approved systems subject to controls appropriate to the sensitivity of the information. Synthetic or de-identified data is the default for development and testing.

3) Standard Retention Periods

The longer applicable period controls when a record belongs to more than one category or is needed to keep a regulated record complete, authentic, searchable, or producible.

Regulated Call and Consent Records

• Medicare Advantage and Part D marketing and sales calls: retained for at least six (6) years from the call date. Audio is retained for the first three (3) years. During years four (4) through six (6), the record may be retained as audio or as a complete and accurate transcript. Related metadata is retained as needed to locate, authenticate, and produce the record.
• Federally-facilitated Marketplace consent and application-review documentation: retained for at least ten (10) years from creation, including audio or other records used to document consumer consent and the consumer’s review and confirmation of application information.
• Records covered by the FTC Telemarketing Sales Rule: retained for five (5) years from creation unless a different trigger applies. Substantially different advertising, scripts, promotional materials, and unique prerecorded messages are retained for five (5) years after they are no longer used, and covered service-provider contracts are retained for five (5) years after expiration.
• Other regulated insurance call records: retained for the period required by applicable law, state insurance requirements, carrier requirements, or customer contract. Where no different period applies, AllCalls’ standard period is seven (7) years from the call or transaction date.

Other Customer, Call, and Business Records

• Other customer call recordings and transcripts: twenty-four (24) months from the call date by default. A different lawful period may be configured by customer, tenant, campaign, call type, or data category.
• Call detail, routing, transfer, pricing, disposition, quality, and fraud or risk metadata: five (5) years from the call date, or the longer period applicable to the related regulated record.
• Consent, recording notice, opt-out, Do-Not-Call, revocation, lead-source, and provenance evidence: five (5) years from the last relevant interaction, use, or revocation. Marketplace documentation follows the ten-year period described above.
• Customer accounts, tenant configuration, users, roles, API configuration, agency information, and license verification: for the customer relationship plus seven (7) years. Access is disabled promptly at offboarding, and active credentials, tokens, and secrets are deleted or rotated unless needed as evidence of a security incident.
• Customer support matters, complaints, billing disputes, call disputes, and chargebacks: five (5) years after closure. Supporting regulated records follow the longer applicable period.
• Customer and vendor contracts, data protection terms, security exhibits, invoices, tax records, and accounting records: generally seven (7) years after expiration, termination, or the end of the relevant fiscal year.
• Authentication, administrative, API, user-access, system, network, and security event logs: three (3) years from the event. Records related to a material security incident or investigation are generally retained for seven (7) years after closure.
• Website analytics and non-essential tracking identifiers: thirteen (13) months from collection unless a shorter consent or vendor setting applies.
• Marketing prospect records: twenty-four (24) months after the last meaningful engagement. Records are deleted or suppressed sooner when required, while the minimum information needed to honor an opt-out may be retained for five (5) years.
• Customer exports and temporary transfer files: deleted within thirty (30) days after confirmed delivery, or sooner when the transfer is complete and verified.
• De-identified and aggregated data: retained only while a documented purpose remains and subject to controls that prohibit re-identification.

4) Customer-Specific Retention

AllCalls may configure retention by customer, tenant, campaign, call type, or data category. A customer may request a shorter period where lawful. Any longer or non-standard period must be documented and implemented before the affected data is collected when reasonably practicable.

A signed customer agreement may establish different retention periods, export formats, post-termination access periods, deletion timelines, backup treatment, or certification requirements. Such terms control to the extent permitted by law.

5) Data Return and Export

Upon a valid customer request or termination of the applicable Services, AllCalls will make the customer’s data available in a mutually agreed, reasonably usable format, ordinarily within thirty (30) days unless the applicable agreement specifies another period.

Exports use approved secure transfer methods and are limited to authorized recipients. We may verify the requesting person’s identity, authority, and requested scope before releasing data. Temporary transfer copies are deleted as described in Section 3.

6) Deletion and Backup Handling

Active systems. Unless a customer agreement requires faster action, AllCalls generally completes deletion from active systems within thirty (30) days after the applicable retention period expires, an approved deletion request becomes effective, or an agreed post-termination access period ends.

Backups. Residual copies in disaster-recovery backups are protected from ordinary use and age out through the normal backup cycle, which does not exceed ninety (90) days by default. If expired data is restored for recovery purposes, the applicable deletion instruction is re-applied before the restored environment returns to ordinary service.

Subprocessors. AllCalls directs applicable subprocessors to return or delete the same data and obtains confirmation when required by contract or risk level.

Confirmation. When required by contract or reasonably requested, AllCalls will provide a certificate or written confirmation after active-system and applicable subprocessor deletion is complete, identifying any remaining backup aging period or lawful retention exception.

7) Legal and Regulatory Holds

A legal or regulatory hold suspends ordinary deletion for records within its scope. Held records remain access-controlled and may be used only for the hold purpose and other legally permitted purposes.

When the hold is released, the ordinary retention schedule resumes. Records already past their retention period are deleted through the next controlled deletion cycle.

8) Secure Disposal

AllCalls selects a disposal method based on the data’s sensitivity, the storage media, the intended reuse or disposal scenario, contractual requirements, and risk. Depending on the system or media, disposal may include:

• Logical deletion from applications, databases, search indexes, caches, replicas, queues, and user-accessible storage;
• Approved cryptographic erasure, secure erase, or purge techniques;
• Physical destruction of media that cannot be securely reused or sanitized; and
• Cross-cut shredding or a bonded destruction service for paper records.

Electronic and physical media sanitization is aligned with the current version of NIST SP 800-88, Guidelines for Media Sanitization, or a demonstrably equivalent standard approved by AllCalls.

9) Subprocessors and Third Parties

AllCalls requires subprocessors that store or process Customer Data to maintain confidentiality and security, limit use to the authorized service purpose, follow applicable retention and legal-hold instructions, assist with data return and deletion, and provide evidence of completion when required.

Subprocessors may not sell Customer Data, use it for cross-context behavioral advertising, combine it for an unauthorized secondary purpose, or attempt to re-identify de-identified data. At termination or upon valid instruction, applicable Customer Data must be returned or deleted unless retention is required by law.

10) Artificial Intelligence and Derived Data

• AllCalls will not use identifiable Customer Content to train, fine-tune, or improve a generalized or cross-customer artificial intelligence model without the customer’s express written authorization.
• AllCalls requires third-party AI providers not to use Customer Data to train their own or shared models unless the customer has expressly authorized that use.
• Customer-specific transcripts, summaries, embeddings, classifications, prompts, outputs, and similar derived records follow the source data’s retention period unless they have been validly de-identified.
• Deletion workflows are designed to address AI-related copies such as vector stores, embeddings, prompt logs, cached outputs, and evaluation datasets, not only the original recording or transcript.

11) Privacy Requests

When AllCalls processes personal information on behalf of a customer, we act on verified instructions from that customer and provide reasonable assistance with applicable access, correction, deletion, portability, opt-out, or restriction requests.

A request received directly from an individual concerning customer-controlled data will ordinarily be referred to the applicable customer unless AllCalls is legally required or independently authorized to respond. A deletion request does not override a valid legal hold or another binding legal, regulatory, security, fraud-prevention, dispute, or contractual requirement.

12) Exceptions and Policy Review

Any lawful retention exception is limited to the data and purpose that require it. The retained information remains access-restricted and is deleted when the exception ends.

AllCalls reviews this Policy at least annually and after material changes to applicable law, regulation, customer requirements, products, data flows, storage architecture, subprocessors, or risk. We may update this Policy by posting a revised version with a new “Last updated” date. Material changes will not reduce protections promised in a signed customer agreement without appropriate authorization.

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Questions about this Policy or a customer-specific retention requirement? Contact [email protected].