Tybugyo

Data Retention Policy

Last Updated: March 28, 2026

1. Purpose and Scope

This Data Retention Policy describes how Tybugyo collects, stores, and disposes of personal data and other information gathered through its platform and services. This policy applies to all users, participants, affiliates, and any other individuals whose data is processed in connection with the use of our services at tybugyo.com.

The purpose of this policy is to ensure that data is retained only for as long as necessary to fulfil the purposes for which it was collected, to comply with applicable legal obligations, and to protect the rights and interests of individuals whose data we hold.

2. Types of Data We Retain

2.1 Account and Registration Data

Information provided when creating an account or registering for a workshop or learning programme, including name, email address, contact details, and authentication credentials.

2.2 Learning and Activity Data

Records of participation in workshops, assignments, exercises, and assessments, including progress tracking, completion status, submitted work, and interaction logs within the platform.

2.3 Communication Data

Messages, support requests, feedback submissions, and any correspondence exchanged through our contact channels, including email, WhatsApp, Telegram, and Signal.

2.4 Payment and Transaction Data

Billing information, transaction records, invoices, and payment history associated with purchases of services or programme enrolments.

2.5 Technical and Usage Data

Log files, IP addresses, browser type, device identifiers, session data, and usage analytics collected automatically when you interact with our platform.

2.6 Affiliate and Cooperation Data

Information related to affiliate agreements, referral activity, commission records, and cooperation terms.

3. Retention Periods

We retain different categories of data for different periods depending on the nature of the data and the purpose for which it was collected. The table below sets out our standard retention periods.

Data Category Retention Period Basis for Retention
Account and registration data Duration of account plus 3 years after closure Contractual obligation, legitimate interest
Learning and activity data Duration of enrolment plus 5 years Service delivery, certification records
Communication data 3 years from last interaction Legitimate interest, dispute resolution
Payment and transaction data 7 years from transaction date Legal and financial compliance
Technical and usage data 13 months from collection Security, performance monitoring
Affiliate and cooperation data Duration of agreement plus 5 years Contractual obligation, legal compliance
Support and feedback records 3 years from date of submission Service improvement, dispute resolution

Where data is subject to a legal hold, ongoing dispute, regulatory investigation, or other exceptional circumstance, retention may be extended beyond the periods stated above until the matter is fully resolved.

4. Criteria for Determining Retention Periods

Where specific retention periods are not defined above, we determine appropriate retention durations based on the following criteria:

5. Data Storage and Security During Retention

All retained data is stored using appropriate technical and organisational security measures designed to protect against unauthorised access, accidental loss, destruction, or disclosure. Access to retained data is restricted to authorised personnel who require it for legitimate business purposes.

We review our storage practices periodically to ensure that data is not held beyond its required retention period and that security measures remain appropriate to the nature and volume of data retained.

6. Data Deletion and Anonymisation

6.1 Deletion Procedures

When data reaches the end of its applicable retention period and no exception applies, it is securely deleted or destroyed in a manner that prevents recovery or reconstruction. Deletion procedures are applied consistently across all systems and storage environments where the data resides.

6.2 Anonymisation

In certain circumstances, rather than deleting data entirely, we may anonymise it so that it can no longer be linked to any identifiable individual. Anonymised data may be retained indefinitely for statistical analysis, service improvement, and research purposes, as it no longer constitutes personal data.

6.3 Backups

Data contained in backup systems may persist for a limited period beyond the standard deletion schedule due to the nature of backup rotation cycles. Such data is subject to the same access controls as live data and is overwritten or deleted in accordance with our backup management procedures.

7. User Rights Regarding Retained Data

Individuals whose data we retain have the following rights, subject to applicable legal limitations:

To exercise any of these rights, please contact us at help@tybugyo.com. We will respond to all valid requests within a reasonable timeframe and in accordance with our obligations.

8. Third-Party Data Processors

We may share data with third-party service providers who process data on our behalf, including hosting providers, payment processors, communication tools, and analytics services. All such processors are required to handle data in accordance with our instructions and to apply appropriate retention and deletion practices consistent with this policy.

We do not sell personal data to third parties and do not permit processors to use data for their own independent purposes beyond what is necessary to deliver the agreed services.

9. Retention of Data Following Account Closure

When a user closes their account or requests deletion of their profile, we will deactivate the account and begin the deletion process for personal data that is no longer required. Certain categories of data, including transaction records, legal correspondence, and data subject to regulatory obligations, will be retained for the periods specified in Section 3 even after account closure.

Users will be notified of any data that must be retained following closure and the reason for its continued retention.

10. Policy Review and Updates

This policy is reviewed at least annually and updated whenever there are material changes to our data processing activities, applicable legal requirements, or organisational practices. The date at the top of this document reflects the most recent revision.

Continued use of our services following any update to this policy constitutes acceptance of the revised terms. Where changes are material, we will notify users through our platform or by email prior to the changes taking effect.

11. Contact Information

If you have any questions, concerns, or requests relating to this Data Retention Policy or the way in which your data is handled, please contact us using the details below: