Data Retention & Protection Policy

Purpose

This policy defines how Close-Rate classifies, stores, protects, and retains customer data. Our goal is to minimize data exposure, comply with customer expectations, and ensure that data is available when needed and deleted when it is not.

Data Classification

We classify data into the following categories:

• Highly Sensitive: OAuth tokens, API credentials, encryption keys. OAuth tokens are encrypted with app-level Fernet (AES-128-CBC + HMAC-SHA256), with the key stored in AWS Secrets Manager separately from the database. Never logged. Access restricted to the application runtime.

• Sensitive: Transcripts and conversation content. Close-Rate never persists recording audio: it is streamed to an ephemeral temp file for transcription only and deleted immediately after. For transcription, the audio is uploaded to AssemblyAI. For calls transcribed since October 15, 2026, AssemblyAI begins deleting its copy of the audio and transcript one day after each request (see Retention Schedules). Transcripts are stored in encrypted S3 (SSE-S3, AES-256), with RDS holding only a pointer key. Accessible to authorized users within the owning organization, and to Close-Rate staff when they support that workspace.

• Internal: User profiles, organization metadata, report configurations. Stored in encrypted RDS. Accessible to organization members based on role.

• Public: Landing page content, published policy documents. No access controls required.

Retention Schedules

• Call Recordings (audio files): Close-Rate never persists call audio to durable storage. It is streamed to an ephemeral local temp file for transcription only, deleted immediately after, and never written to S3. AssemblyAI's copy is covered in the next item.

• Audio and Transcripts at AssemblyAI (transcription provider): To transcribe a call, we upload its audio to AssemblyAI, which returns the transcript. Since October 15, 2026, our AssemblyAI account has been set so that AssemblyAI begins deleting each call's audio and transcript one day after the request. Deletion can take longer to finish, and AssemblyAI keeps certain metadata for logging and billing. We never read a transcript back from AssemblyAI later; the copy we keep is the one in S3. The same account is opted out of AssemblyAI's model improvement program, which AssemblyAI says means it does not use the call audio we send it to train its models or for benchmarking. AssemblyAI's terms still let it keep de-identified data made from the audio and use it for purposes other than training its models, such as testing and benchmarking.

• Transcripts & Conversation Data: Transcripts are stored in Amazon S3 (SSE-S3, AES-256) with RDS holding a pointer key, and indexed for search (text chunks and embeddings) in the same Amazon Aurora PostgreSQL database, for the duration of the customer's active subscription. Deleted upon conversation or organization deletion — removing the RDS rows (including the search index entries) and the S3 transcript/embedding objects.

• Coaching Reports & Objection Reports: Retained for the duration of the subscription. Downloadable as PDFs. Deleted upon organization deletion.

• OAuth Tokens: Zoom refresh tokens expire after 90 days of inactivity. Tokens are automatically refreshed during active use (with refresh-token rotation). Deleted from our systems when a user disconnects the integration, ending our access — this removes the stored token rather than calling Zoom's revoke endpoint.

• Audit / Application Logs: Retained for 90 days in AWS CloudWatch. Logs do not contain sensitive user data, credentials, or conversation content.

• Analytics Data (PostHog): Usage events (page views, clicks, scrolls) are retained for 12 months. Session replays of how pages are used are kept for no longer than 12 months. On signed-in screens, replays and click events mask all text and typed input, so no conversation content, report text, or rep or customer names are sent to PostHog. Activity while signed in is linked to the user's account (name, email address and workspace).

Data Deletion

We support data deletion at multiple levels:

• Individual Conversation: Coaches can delete individual conversations. This removes the RDS records (including the conversation's search index entries) and the S3 transcript and embedding objects.

• Integration Disconnect: Disconnecting a Zoom integration deletes the stored OAuth token from our systems, ending our access, and keeps the calls already imported. It does not call Zoom's revoke endpoint, because revoking makes Zoom send an uninstall notice, which deletes those calls.

• Integration Uninstall: Uninstalling the Close-Rate app in Zoom while Zoom is still connected in Close-Rate permanently deletes the calls imported from that Zoom account. If you already disconnected, email client-services@close-rate.com and we will delete your Zoom calls.

• Organization Deletion: Deleting an organization removes all associated users, conversations, reports, integration tokens, and search index data.

• Account Deletion: Coaches can delete their whole organization (and all of its data) directly. Individual (non-coach) users can request account and data deletion via brian@pathfinderventures.net or their organization admin. We will remove all user data within 30 days.

Backup & Recovery

• Amazon RDS automated daily backups with 7-day retention

• Point-in-time recovery available for the database within the retention window

• S3 objects stored with high durability (99.999999999% — 11 nines)

• Transcript search indexes are part of the database (covered by the backups above) and can also be rebuilt from the transcripts stored in S3 if needed

Regulatory Considerations

• GDPR: Users can exercise their right to access, rectification, and erasure. Data processing is based on legitimate business interest and user consent. Data is stored in AWS US-East-1 (Virginia).

• CCPA: We do not sell personal information. Users can request disclosure of collected data and deletion.

• Data Portability: Coaching reports are available as downloadable PDFs. Customers can request a full data export by contacting support.