| Regulatory log | Chained log of the regulatory perimeter, registry consultations and deal events. | no time limit | Kept locked proof log: never emptied | Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Audit chain | Audit log of sensitive actions (identifiers, action, outcome, correlation), with no confidential content. | no time limit | Kept locked proof log: never emptied | Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Identity documents and identity checks (KYC) | Uploaded identity document, encrypted legal name, fingerprint, identity review decisions. | 5 years after the account is closed duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legal obligation and legitimate interest in transaction security. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| User accounts and identities | Email, phone, name, password hash, organisation and roles of an account. | 3 years after the account is closed duration to be validated by the lawyer | Anonymised erasable on request | Performance of the terms of use. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Sessions and one-time codes | Token fingerprint, device, address fingerprint, one-time login and verification codes. | 6 months after validity ends duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legitimate interest in security. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Request idempotency keys | Stored response of a replayed request. | 1 month after creation duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legitimate interest in service reliability. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Team invitations | Invited email address, proposed role, link fingerprint. | 6 months after validity ends duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the service requested by the organisation. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| In-app notifications | Notifications shown to a person, with their parameters. | 1 year after creation duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Email and SMS delivery traces | Provider reference and last delivery error of an alert. | 1 year after creation duration to be validated by the lawyer | Content emptied and dated erasable on request | Legitimate interest. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Assistant conversations | Title and messages of your discussions with the assistant, encrypted. | 3 months after the last activity duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Support requests | Subject and exchanges of a support ticket. | 3 years after the deal closes duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Performance of the support service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Abandoned deal drafts | In-progress entry of a deal not submitted (company name, registry number). | 6 months after the last activity duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Buyer profiles and applications | Proof of financial capacity, investment thesis, profile review decisions. | 3 years after the account is closed duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Performance of the service and legitimate interest in qualification. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Trade applications: abandoned drafts | Answers and documents of a trade application never submitted. | 6 months after the last activity duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Trade applications: withdrawn applications | Answers, documents, exchanges and checks of an application you withdrew. | 6 months after refusal or withdrawal duration to be validated by the lawyer | Content emptied and dated erasable on request | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Trade applications: refused applications | Answers, documents, exchanges, checks and compliance notes of a refused application. | 2 years after refusal or withdrawal duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legitimate interest in justifying a decision. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Trade applications: lapsed or revoked verified applications | Answers, documents, exchanges, checks and notes of an application that was verified and lost its validity. | 3 years after validity ends duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legitimate interest in proof. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Saved alerts and marketing consent proof | Criteria of a saved alert and date of consent to be notified. | 3 years after consent is withdrawn duration to be validated by the lawyer | Content emptied and dated erasable on request | Consent, withdrawable at any time. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Usage measurements | Deal views and probe samples. | 760 days after creation duration to be validated by the lawyer | Anonymised erasable on request | Legitimate interest in audience measurement. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Subscriptions, payments and receipts | Subscriptions, payment sessions, payment provider notifications, numbered receipts. | 10 years after creation duration to be validated by the lawyer | Anonymised kept until the end of the period | Legal accounting obligation (OHADA accounting law). AUDCIF (OHADA, 2017) : livres et pièces justificatives 10 ans. Source secondaire (vie-publique.sn), article non confirmé. |
| Subscription capability usage | Usage counters and consumption log (who consumed what). | 760 days after creation duration to be validated by the lawyer | Anonymised erasable on request | Performance of the subscription contract. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Messages between profiles | Messages exchanged between profiles about a deal. | 5 years after the deal closes duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legitimate interest in proof; AUDCG : prescription de 5 ans entre commerçants (article 18, ancien numérotage, cité par la jurisprudence ; texte non relu). |
| Data room documents | Uploaded files, extracted text, meeting fragments. | 3 months after the deal closes duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Data room audit metadata | Who viewed what, access grants, versions, marks, suspensions. | 10 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Legitimate interest in proof. AUDCG : prescription de 5 ans entre commerçants (article 18, ancien numérotage, cité par la jurisprudence ; texte non relu). |
| Confidentiality agreement and signature evidence | Executed agreements, instances, signature proofs, agreement preparations and uploads. | 10 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Legitimate interest in proof and performance of the contract. AUDCG : prescription de 5 ans entre commerçants (article 18, ancien numérotage, cité par la jurisprudence ; texte non relu). |
| Revenue-share calculation journals and revenue | Fee events, quarterly reports, revenue-share statements, revenue entries, deal completions. | 10 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Legal accounting obligation. AUDCIF (OHADA, 2017) : livres et pièces justificatives 10 ans. Source secondaire (vie-publique.sn), article non confirmé. |
| Sale files, documents and expressions of interest | Sale and acquisition files, declared facts, documents, valuations, interests, certifications, mandates and advisors. | 10 years after the deal closes duration to be validated by the lawyer | Kept kept until the end of the period | Performance of the contract and legitimate interest in proof. AUDCG : prescription de 5 ans entre commerçants (article 18, ancien numérotage, cité par la jurisprudence ; texte non relu). |
| Events, registrations and appointments | Events, registrations, reservations, diaspora appointments, agenda. | 3 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Performance of the requested service. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Provider profiles and service requests | Provider profiles, publications, service requests and their exchanges. | 5 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Performance of the service and legitimate interest in proof. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Operations and continuity logs | Probes, maintenance windows, incidents, signals, measures, backups. | 5 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Legitimate interest in operations. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Settings and content history | History of changes to settings, content, catalogue, trades, profile access and payment providers. | 10 years after creation duration to be validated by the lawyer | Kept kept until the end of the period | Legitimate interest in governance. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |
| Data subject requests, notice acknowledgements, retention register | Access, erasure, rectification and objection requests; notice acknowledgement proofs; retention rules and purge log. | 5 years after creation duration to be validated by the lawyer | Content emptied and dated kept until the end of the period | Legal obligation to respect rights and legitimate interest in proof. Togolese Law No. 2019-014 of 29 October 2019, arts. 16 and 53: data is kept no longer than needed for its purposes; the law sets no numeric period. |