๐Ÿ“‹ Legal Documentation

Data Retention Policy

This policy outlines how CloudNexus collects, stores, retains, and securely deletes your data. We are committed to transparency, compliance, and responsible data management practices.

๐Ÿ“… Last Updated: January 15, 2025
๐Ÿ”„ Effective Date: February 1, 2025
๐Ÿ“„ Version: 3.2
๐Ÿ”’ Compliance: GDPR, CCPA, SOC 2

๐Ÿ“‹ 01 โ€” Overview

CloudNexus is committed to protecting your data privacy and managing your information responsibly. This Data Retention Policy describes the principles, practices, and procedures we follow regarding the collection, use, storage, and deletion of data across our cloud infrastructure platform.

We retain data only for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Our approach balances operational needs with your right to privacy and data minimization.

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Scope of This Policy

This policy applies to all data collected through CloudNexus's cloud hosting services, managed infrastructure, CDN, databases, APIs, customer portals, and related systems. It covers both personally identifiable information (PII) and operational data.

๐ŸŽฏ 02 โ€” Scope & Definitions

Understanding the key terms and scope is essential to this policy.

Key Definitions

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Data Retention

The period during which data is actively stored and accessible by CloudNexus systems before deletion or archival.

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Data Archival

Transferring data to long-term, lower-cost storage systems where it is preserved but not actively accessed.

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Data Deletion

Secure erasure of data from all active, backup, and archival systems so it can no longer be retrieved or reconstructed.

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Legal Hold

A preservation directive that suspends normal deletion processes when data is required for litigation or investigation.

What This Policy Covers

  • โ–ธ Customer account data and authentication credentials
  • โ–ธ Infrastructure usage logs and monitoring data
  • โ–ธ Backups, snapshots, and disaster recovery data
  • โ–ธ Network traffic and CDN cache data
  • โ–ธ Support ticket and communication records
  • โ–ธ Billing, invoicing, and financial transaction data
  • โ–ธ Application data hosted on CloudNexus infrastructure (user-managed)
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What This Policy Does Not Cover

CloudNexus acts as a data processor for application data hosted on our infrastructure. The retention of your customers' data hosted on our servers is governed by your own policies and the agreements you have with your end users. We do not access, audit, or control that data.

โฑ๏ธ 03 โ€” Retention Periods

The following table outlines the retention periods for each data category we manage. These periods are measured from the date of data collection or the last activity, whichever is later.

Data Category Retention Period Format Legal Basis
Account & Profile Data Lifetime of Account Encrypted DB Contract fulfillment
Billing & Invoicing 7 Years Encrypted DB + Archive Tax & financial regulations
Authentication Logs 12 Months Encrypted Logs Security & compliance
System Access Logs 12 Months Encrypted Logs SOC 2 compliance
Network & CDN Logs 90 Days Streaming โ†’ Object Store Operational optimization
Performance Metrics 18 Months Time-series DB Service monitoring
Support Tickets 36 Months Encrypted DB Service improvement
Email Communications 36 Months Encrypted DB Service documentation
Backups & Snapshots Up to 90 Days Encrypted Storage Disaster recovery
API Request Logs 30 Days Streaming Logs Debugging & analytics
Temporary Cache Data 1โ€“72 Hours RAM / Redis Performance optimization
Cookie & Tracking Data Up to 13 Months Browser Storage User consent / Legitimate interest
Deleted Account Data 30-Day Grace Period Quarantined Storage Accidental recovery window
Incident & Breach Records 7 Years Encrypted Archive Regulatory & legal obligations
Compliance Audit Records 7 Years Encrypted Archive SOC 2, ISO 27001 requirements
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Data Minimization Principle

Where possible, we employ data aggregation, anonymization, and pseudonymization techniques to reduce the amount of personally identifiable information stored. Raw logs are often reduced to aggregated metrics within their retention window.

๐Ÿท๏ธ 04 โ€” Data Classification

All data processed by CloudNexus is classified into categories that determine retention handling, security controls, and access restrictions.

Data Classification Levels

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Confidential โ€” Customer Data

Application data, database contents, file storage, and encrypted payloads hosted on our infrastructure. Retention is controlled by the customer. CloudNexus has no independent retention rights over this data.

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Restricted โ€” Account Data

PII, billing information, API keys, authentication tokens, and profile data. Retained per the periods defined in this policy with encryption at rest and in transit.

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Internal โ€” Operational Data

System logs, performance metrics, network traffic data, and internal analytics. Retained for operational purposes and deleted according to the schedule above.

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Public โ€” Published Data

Status page information, documentation, API references, and service descriptions. No retention constraints apply to publicly published content.

Customer-Hosted Data

For data hosted by customers on CloudNexus infrastructure (virtual machines, object storage, managed databases, etc.), the following principles apply:

  • โ–ธ Customer-Controlled: Retention is entirely at the customer's discretion. CloudNexus does not delete, modify, or access application data without explicit customer authorization.
  • โ–ธ Deletion Window: Upon customer deletion request, data is removed from active storage within 30 days. The data may persist in backup systems for up to 90 days as part of disaster recovery procedures, after which it is cryptographically erased.
  • โ–ธ Data Residency: Customer data remains within the selected geographic region unless the customer initiates a migration. Cross-region replication is only performed with explicit consent.
  • โ–ธ Cryptographic Erasure: When customer data is scheduled for deletion, we perform cryptographically secure erasure using NIST 800-88 Rev. 1 guidelines for digital media sanitization.

๐Ÿ“ฅ 05 โ€” Data Collection Practices

We only collect data that is necessary for providing and improving our services. Here is what we collect:

Account-Related Data

  • โ–ธ Name, email address, and organization details โ€” retained for the lifetime of the account
  • โ–ธ Payment information (tokenized) โ€” retained per financial regulations (7 years for billing records)
  • โ–ธ API keys and access tokens โ€” rotated according to customer settings; revoked tokens are logged for 12 months
  • โ–ธ Two-factor authentication data โ€” securely hashed and stored indefinitely while account is active

Operational Data

  • โ–ธ Server and infrastructure usage metrics โ€” retained for 18 months for trend analysis
  • โ–ธ Network traffic metadata (not payload) โ€” retained for 90 days
  • โ–ธ DNS query logs โ€” retained for 90 days
  • โ–ธ SSL/TLS certificate data โ€” retained for the certificate validity period plus 1 year

Support & Communication Data

  • โ–ธ Support tickets and chat transcripts โ€” retained for 36 months
  • โ–ธ Email correspondence โ€” retained for 36 months
  • โ–ธ Video call recordings (if applicable) โ€” retained for 30 days unless customer requests longer storage

๐Ÿ” 06 โ€” Storage & Security

Data stored by CloudNexus is protected using multiple layers of security controls at rest and in transit.

Encryption Standards

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Encryption at Rest

AES-256 encryption for all stored data. Customer data is encrypted with per-tenant keys managed via AWS KMS or equivalent provider. Keys are rotated annually.

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Encryption in Transit

TLS 1.3 for all data transfers. HSTS enforced across all endpoints. Certificates from trusted CAs with automated renewal.

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Key Management

HSM-backed key management with FIPS 140-2 Level 3 validated modules. Separation of duties between key administration and data access.

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Network Security

Micro-segmentation, private VPCs, DDoS mitigation, and zero-trust architecture for internal network access.

Access Controls

  • โ–ธ Principle of Least Privilege: Access to data is granted on a need-to-know basis. All access is logged and audited.
  • โ–ธ Multi-Factor Authentication: Required for all employee access to production systems and customer data.
  • โ–ธ Regular Access Reviews: Quarterly review of all data access permissions with automatic revocation of unused accounts.
  • โ–ธ Privileged Access Management: All privileged access requires explicit approval and is time-bound with session recording.

๐Ÿ—‘๏ธ 07 โ€” Data Deletion Process

CloudNexus follows a structured, auditable process for data deletion that ensures no recoverable traces of data remain after the retention period expires.

Deletion Workflow

Step 1 โ€” Scheduling

Data approaching its retention limit is flagged by automated monitoring systems. The deletion is queued and scheduled during a maintenance window to minimize operational impact.

Step 2 โ€” Verification

Before deletion, the system verifies that the retention period has expired, that no legal holds apply, and that the deletion has been authorized by the appropriate workflow.

Step 3 โ€” Secure Deletion

Data is cryptographically erased using NIST 800-88 Rev. 1 standards. For SSD storage, ATA Secure Erase or NVMe Format NVM commands are executed. Encryption keys are destroyed, rendering any encrypted copies unrecoverable.

Step 4 โ€” Audit & Certification

A deletion audit record is generated with timestamp, data category, volume, method, and operator identity. This record is itself retained for 7 years for compliance verification. The deletion is logged in our immutable audit trail.

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Backup Retention Note

Deleted data may persist in backup systems for up to 90 days as part of disaster recovery procedures. After this period, backup data is overwritten or cryptographically erased. We do not maintain backups longer than necessary.

๐Ÿ‘ค 09 โ€” Your Data Rights

Under applicable data protection laws including GDPR, CCPA/CPRA, and other regional regulations, you have specific rights regarding your personal data.

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Right to Access

Request a copy of all personal data we hold about you, including the categories of data, purposes of processing, and retention periods.

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Right to Rectification

Request correction of inaccurate or incomplete personal data. We will correct the data within 30 days.

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Right to Erasure

Request deletion of your personal data where there is no legal basis for retention. Subject to exceptions outlined in Section 8.

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Right to Portability

Receive your data in a machine-readable format and transmit it to another service provider where technically feasible.

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Right to Restrict Processing

Request that we limit the processing of your personal data in certain circumstances, such as during a dispute over accuracy.

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Right to Object

Object to processing based on legitimate interests or direct marketing. We will cease processing unless we demonstrate compelling legitimate grounds.

How to Exercise Your Rights

  • โ–ธ Submit requests through the CloudNexus Customer Portal โ†’ Privacy Center
  • โ–ธ Email privacy@cloudnexus.com with "Data Rights Request" in the subject line
  • โ–ธ We will respond within 30 days of receiving a verifiable request
  • โ–ธ For complex or numerous requests, we may extend the response period by an additional 60 days with notification

๐ŸŒ 10 โ€” International Data Transfers

CloudNexus operates data centers across multiple geographic regions. Data transfers between regions are conducted in compliance with applicable data protection laws.

Data Residency Options

Customers can select their preferred data residency region at the time of provisioning. Our primary regions include:

  • โ–ธ Americas: US East (Virginia), US West (Oregon), Canada Central (Montreal), South America (Sรฃo Paulo)
  • โ–ธ Europe: EU West (Frankfurt), EU North (Stockholm), UK (London)
  • โ–ธ Asia-Pacific: AP Southeast (Singapore), AP Northeast (Tokyo), AP South (Mumbai), AP Australia (Sydney)

Transfer Safeguards

  • โ–ธ EU-US Data Privacy Framework: CloudNexus is certified under the EU-U.S. Data Privacy Framework and adheres to its principles.
  • โ–ธ Standard Contractual Clauses (SCCs): Where applicable, we use EU Commission-approved SCCs for cross-border data transfers.
  • โ–ธ Binding Corporate Rules (BCRs): For intra-group transfers within the CloudNexus organization.
  • โ–ธ Data Processing Addendum (DPA): Available for all customers and incorporated into service agreements.
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Cross-Region Replication

By default, data remains within the selected region. Cross-region replication is only enabled when explicitly configured by the customer or when required for high availability with customer consent. No cross-border transfers occur without your authorization.

๐Ÿšจ 11 โ€” Data Breach Response Protocol

In the event of a data breach, CloudNexus follows a structured incident response plan to contain, investigate, and notify affected parties.

Breach Notification Timelines

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Internal Detection โ†’ 1 Hour

Automated monitoring systems detect anomalies. The security operations center (SOC) responds within 1 hour with initial containment actions.

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Investigation โ†’ 72 Hours

The incident response team investigates the scope, impact, and root cause within 72 hours. Forensic analysis is conducted by certified professionals.

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Regulatory Notification โ†’ 72 Hours

Per GDPR and other regulations, supervisory authorities are notified within 72 hours of confirmed breach awareness.

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Customer Notification โ†’ As Required

Affected customers are notified without undue delay, typically within 72 hours, with clear information about the breach and recommended actions.

Breach Containment Procedures

  • โ–ธ Immediate isolation of affected systems and services
  • โ–ธ Preservation of evidence and forensic artifacts
  • โ–ธ Emergency key rotation and credential revocation
  • โ–ธ Deployment of additional monitoring and detection rules
  • โ–ธ Engagement of third-party forensics firm if needed
  • โ–ธ Post-incident review and remediation plan implementation

๐Ÿ“ 12 โ€” Policy Updates & Changes

This policy may be updated periodically to reflect changes in our practices, technology, or regulatory requirements.

  • โ–ธ Material Changes: Significant changes to data retention practices will be communicated via email at least 30 days before they take effect.
  • โ–ธ Minor Updates: Non-material clarifications or formatting updates may be published without prior notice. All updates are logged in the change history.
  • โ–ธ Notification Channels: Updates are posted on this page, published in the status dashboard, and communicated via customer portal notifications.
  • โ–ธ Version History:
Version Date Changes
3.2 Jan 15, 2025 Added CDN log retention schedule; clarified backup deletion procedures
3.1 Sep 1, 2024 Updated legal holds section; added APAC region data residency
3.0 Mar 15, 2024 Major revision: aligned with GDPR, CCPA, and SOC 2 Type II requirements
2.1 Nov 1, 2023 Added international data transfer safeguards section
2.0 Jun 1, 2023 Expanded data classification and added breach response protocol
1.0 Jan 1, 2023 Initial publication

We encourage customers to review this policy regularly. Continued use of CloudNexus services after policy updates constitutes acceptance of the revised terms.

๐Ÿ“ฌ 13 โ€” Contact & Inquiries

If you have questions, concerns, or requests regarding this Data Retention Policy or how we handle your data, please contact us through any of the channels below.

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Data Protection Officer

dpo@cloudnexus.com

For privacy and data protection inquiries

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General Inquiries

privacy@cloudnexus.com

For general privacy questions

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Postal Mail

CloudNexus DPO
200 Innovation Drive, Suite 400
San Francisco, CA 94105
United States

Supervisory Authorities

If you believe your data protection rights have been violated and are unsatisfied with our response, you have the right to lodge a complaint with your local supervisory authority:

  • โ–ธ EU: Your local Data Protection Authority (find at edpb.europa.eu)
  • โ–ธ UK: Information Commissioner's Office (ico.org.uk)
  • โ–ธ USA (California): California Privacy Protection Agency (oag.ca.gov/privacy)
  • โ–ธ Other regions: Refer to your local data protection regulator