Legal
Data Retention Policy
This policy sets out how long WREN TECHNOLOGIES LTD (“Wren”, “we”, “us”) keeps the main categories of personal and business information described in our Privacy and Fair Processing Notice. It is a plain-language summary drawn from our internal retention schedule, not a substitute for that notice — read them together.
1. Scope
This policy covers the categories of information described in our Privacy Notice: our business database and directory records, Marketplace and Pulse customer data, website and app usage data, customer accounts and billing records, and records generated when we communicate with people or handle their rights requests. It applies wherever Wren acts as controller of that information. Where Wren processes a customer’s data solely as a processor (for example, a Pulse upload), the applicable retention period is stated against that category below and may also be set out in our agreement with that customer.
2. Retention principles
We do not keep personal information for longer than necessary for the purpose it was collected or generated for. Most periods below run from a clear trigger event — an upload date, an order date, an account closure — so that deletion is predictable rather than open-ended. Where a period cannot sensibly be fixed in advance (our core business database, for example, is a live dataset that is continually corrected and updated), we apply a necessity test instead: information is kept only while it remains relevant, accurate and needed for an active purpose, and is otherwise corrected or removed.
Some information is kept for longer, in a reduced form, purely to honour an objection or opt-out and to prevent a removed record being reintroduced. This suppression information is described separately in each relevant row, since it is not the same as continuing to hold someone’s full contact details.
Legal, accounting and tax retention duties can require us to keep specific records for a set minimum period regardless of the general rule above; those are marked accordingly.
3. Retention by category
| Category | Retention period | Trigger / notes |
|---|---|---|
| Core business and contact database records | As long as necessary for an active purpose, subject to ongoing review, correction and objection handling | Not a fixed period. Historical personal information that is not needed for an active purpose is removed or reduced during review. Review may be triggered by a source update, failed validation, a stale or unverified business association, a correction, erasure or objection request, or the related business becoming ineligible or outside our scope |
| Former-contact details | 3 years, suppression and matching only | Name, email address and original business-contact details are kept in a separate former-contact database. Used only to match records, suppress the former contact, prevent re-acquisition and help customers identify that a contact in their own file is no longer at that business. Former-contact details are not supplied back to customers; where relevant, we provide only a flag or status. Runs from when the person is identified as having left the business |
| Dissolved-business records | Indefinite, suppression and matching only | Dissolved-business identifiers and associated historical company/contact state are kept to prevent reactivation and help customers identify records that should be removed or treated as inactive. Not supplied as active/current data |
| Email opt-out / suppression record (minimal identifiers) | Indefinite | Kept to continue honouring the objection and prevent the same record being reintroduced |
| Opt-out form submissions (IP address, optional name) | 90 days | From submission date |
| Pulse uploads, enrichment outputs and file metadata | 30 days | From initial upload date, including outputs generated later within that period |
| Wren Data email campaign lists, send records, delivery information, opens, clicks and campaign results | Up to 18 months | From the date the initial email list is created, unless the customer’s agreement with Wren specifies a different period. These campaigns use Wren Data, not customer-uploaded campaign lists |
| Purchased/exported record files | 30 days | From order date. Does not affect copies the customer has already downloaded. Customers’ own use of a purchased List is governed by the Data Licence and Customer Suppression Schedule |
| Order identifiers and customer association (suppression purposes) | 365 days | From order date |
| Disclosure and suppression record (minimal identifiers) | Indefinite | Kept to notify previous recipients of erasure, correction or restriction, prevent suppressed information being supplied again, and evidence compliance. Does not hold the removed personal information in readable form |
| Article 14 privacy-notification delivery logs | 30 days | From send date |
| Customer accounts (registration and general account records) | 6 years | From account closure. Billing and tax records are covered separately below |
| General support messages | 6 years | From case closure |
| Privacy complaints and rights-request records | 10 years | From case closure, to evidence how the request or complaint was handled and to manage any later regulatory or legal challenge |
| Invoice and accounting records | 10 years | From invoice date, for accounting, tax, audit and legal-defence purposes |
| Security and access logs | 1 year | Rolling |
| Call recordings (inbound receptionist) | 30 days | From call date |
| Verification-call transcripts (outbound) | 30 days | From call date. Outbound verification calls are not recorded; only a transcript is kept, then deleted. Verified details are written to the business record |
| Database backups | 2 years | Rolling. See “Backups” below for how deletion and opt-out apply to backup copies |
Where a customer’s own agreement with Wren sets a different period for data we process on that customer’s instructions, the agreement’s terms apply for that data instead of the general periods above.
4. Deletion and suppression
At the end of its retention period, information is deleted or irreversibly anonymised from our live systems. For personal contact rows in our database, this is enforced through contact-specific encryption: on a valid opt-out, we permanently destroy the encryption key for that contact’s row, so that copies of it — including in backups — cannot be recovered, even though the backup file itself is not immediately rewritten.
Deletion of the underlying record does not always mean every trace is removed instantly. A minimal set of suppression identifiers is deliberately kept, separately from a person’s name, email and other contact details, so that we can recognise and reject an attempt to reintroduce the same record from a public source in future. This is a narrower, longer-retained dataset than the personal information it protects, and exists only to make an opt-out durable.
5. Backups
Full database backups are retained for 2 years on a rolling basis and are used for disaster recovery, not day-to-day access. Because a backup is a point-in-time copy, it can briefly contain information that has since been deleted or corrected in the live database. Where a contact has opted out, the destruction of that contact’s encryption key (see “Deletion and suppression”) means an encrypted copy of their row in a backup cannot be decrypted or restored, even during the backup’s own retention window.
Backups of Pulse upload files, purchased export files and call recordings are not covered by the 2-year database backup schedule; those categories follow the shorter periods set out in the table above.
6. Contact
Questions about this policy, or requests relating to how long we hold your information, can be sent to dpo@wren-data.co.uk, by telephone on 0161 524 8524, or in writing to our registered office at 128 City Road, London, EC1V 2NX, marked “Data protection”. See our Privacy and Fair Processing Notice for your wider data-protection rights, including how to request erasure or correction.