1. Purpose
This Data Retention Policy ("Policy") establishes how OktoRocket, operated by ShopRocket, LLC ("OktoRocket," "the Company," "we," or "us"), collects, retains, and disposes of data across its SaaS platform and VoIP communications services. This Policy exists to:
- Meet contractual commitments made to customers, including those referenced in OktoRocket's Fulfillment Policy, Subscription Agreement, Terms and Conditions, and Master Service Agreement (where applicable);
- Comply with applicable federal and state requirements;
- Limit unnecessary retention of personal and business data in order to reduce security and compliance risk; and
- Provide a consistent, auditable standard that OktoRocket's own systems and third-party subprocessors are held to.
2. Scope
This Policy applies to all data created, collected, processed, or stored by or on behalf of OktoRocket, regardless of format or location, including data held on production systems, backup systems, and by third-party subprocessors acting on OktoRocket's behalf. This Policy covers customer account data, platform and usage data, VoIP-specific records, billing and payment records, support communications, contracts, and legal records.
This Policy applies to all OktoRocket personnel, contractors, and third-party service providers with access to Company data.
3. Data Retention Schedule
The table below sets the retention period and disposal method for each category of data OktoRocket handles. Retention periods reflect the longer of (a) OktoRocket's operational need, (b) contractual commitments to customers, and (c) applicable legal minimums.
| Data Category | Retention Period | Disposal Method | Basis |
|---|---|---|---|
| Customer account data (including login credentials) | Duration of active service agreement | Secure deletion or anonymization from production systems | Contractual / operational |
| Platform and usage data (feature usage, application logs) | Duration of active service agreement | Secure deletion or anonymization from production systems | Operational |
| Call Recordings | 12 months by default client-configurable | Secure deletion | Contractual / operational |
| Call Detail Records (CDRs) | 18 months | Secure deletion | FCC preservation of records requirements |
| Customer Proprietary Network Information (CPNI) | Duration of active service agreement | Secure preservation during active service and secure deletion following termination of service | FCC preservation of records requirements |
| E911 / location data | Duration of active service agreement | Secure deletion | FCC E911 rules |
| Billing, invoicing, and payment records | Term of relationship plus 12 months | Secure deletion or archival per finance retention schedule | Tax and financial recordkeeping law |
| Support communications (tickets, email, chat) | Indefinite | Deletion or archival upon request | Operational |
| Contracts and legal records (MSAs, amendments, signed agreements) | Indefinite | Archived with deletion upon request | Operational |
4. Data Disposal Procedures
When a retention period expires, data must be disposed of using one of the following methods, as appropriate to the data category and storage medium:
- Secure deletion: Permanent removal from production systems and any associated caches, such that the data is not recoverable through ordinary means.
- Anonymization or aggregation: Removal of identifying elements such that the remaining data can no longer be associated with an individual or specific customer account.
- Archival: Transfer to a restricted, access-controlled archive for data subject to a longer legal or contractual retention requirement, with deletion scheduled at the end of that period.
- Physical destruction: For data held on physical media or hardware being decommissioned, destruction sufficient to render the data unrecoverable (e.g., shredding, degaussing, or certified wiping).
5. Account Closure, Cancellation, Number Porting, and Access
Upon account cancellation, data is disposed of on the schedule set out in Section 3, above following confirmed cancellation and, where applicable, confirmed port-out completion, as defined by OktoRocket’s Fulfillment Policy.
Number Ownership and Porting
Phone numbers associated with a Customer's account remain assigned to the Customer and they retain assignment following a cancellation, whether that number was originally ported into OktoRocket from another carrier via a Letter of Authorization (LOA) or was acquired directly through OktoRocket during the course of service. OktoRocket does not claim ownership of, or retain any right to withhold, a Customer's phone number on the basis of how that number was originally obtained.
Customers may port a number out to another provider at any time. Port-out requests are handled in accordance with the number porting provisions of the Fulfillment Policy, including the timing rules for billing-cycle cutoff and confirmation of port-out completion.
Access to Account Information and Configuration
Following a cancellation request, Customer access to profile information and configuration data (including CRM campaigns) remains available through the end of the billing period in effect at the time of cancellation, consistent with the full-month billing terms of the Fulfillment Policy. Access to this data and configuration is not shortened or accelerated based on the date within the billing cycle that the cancellation request is received.
At the end of the billing period, Customer accounts and access are removed. Once access is removed, OktoRocket has no interface through which to retrieve campaign information, configuration, or other account data on the Customer's behalf. Any request to access this data after that point requires OktoRocket to reprovision the Customer's organization and accounts before the request can be fulfilled.
6. Legal Holds
Where OktoRocket becomes aware of pending or reasonably anticipated litigation, a regulatory investigation, or a valid legal request (such as a subpoena) that may require preservation of specific data, normal deletion schedules for that data are suspended until OktoRocket confirms, or has been notified by appropriate authorities the hold has been lifted. Data subject to a legal hold must not be deleted, overwritten, or disposed of under the schedule in Section 3 until the hold is released, regardless of the retention period that would otherwise apply.
7. Third-Party Subprocessors
Any third-party vendor or subprocessor that stores or processes data on OktoRocket's behalf must be contractually bound to retention and deletion terms consistent with this Policy, including a defined process for confirming deletion upon contract termination or expiration of the applicable retention period. Where practical, OktoRocket obtains written confirmation of deletion or destruction from subprocessors upon offboarding.
8. Policy Review
This Policy is reviewed at least annually and upon any material change in applicable law, OktoRocket's service offerings, or the data categories OktoRocket collects.