LeadFilter™ — Data Retention Policy

Last Updated: November 18, 2025

Website: leadfilter.ca

Legal Entity: VIGO ONLINE GROUP (Sole Proprietorship, BIN: 1000520463)

Merchant of Record: VIGO ONLINE GROUP

Address: 2 Robert Speck Pkwy Suite 750, Mississauga, ON L4Z 1H8

1. Introduction and Policy Aims

1.1. This Data Retention Policy (“Policy”) describes the periods, procedures, and bases for the retention, archiving, and deletion of personal data and operational information processed by VIGO ONLINE GROUP within the LeadFilter™ service (“Service” or “Platform”).

1.2. This Policy is designed in accordance with:

GDPR (EU) — regarding the storage limitation principle;
PIPEDA (Canada) — regarding reasonable retention;
CCPA / CPRA (California) — regarding data minimization;
Tax Laws of Canada and the Province of Ontario.

1.3. The aims of this Policy are to ensure lawful, transparent storage and to prevent the accumulation of unnecessary data.

2. Scope and Roles

To determine retention periods, we distinguish between two types of data based on our role:

2.1. VIGO as Data Controller (MoR Data).

Data required for the operation of the business, fraud prevention, and tax compliance. This includes Partner account details, billing logs, and transaction records where VIGO acted as the Merchant of Record.

2.2. VIGO as Data Processor (Partner Content).

Data collected by Partners through their Quizzes (Lead Data). For this category, the Partner acts as the Controller, and VIGO acts strictly as the storage provider.

3. General Principle of Storage Limitation

All data is stored strictly for the period necessary to fulfill the purposes for which it was collected. Once that purpose is fulfilled, data is either securely deleted or irreversibly anonymized.

4. Data Retention Schedule

4.1. Data Where VIGO is Controller (Business & Tax Records)

As the Merchant of Record, VIGO is legally required to retain certain financial records regardless of account status.

Data Type	Retention Period	Reason
Financial & Tax Records (Invoices, Transaction IDs, Tax calculations)	7 Years	Mandatory requirement by Canada Revenue Agency (CRA) and international tax laws for audit purposes.
Partner Account Data (Name, Email, Business Info)	Duration of Account + 1 Year	To handle post-termination inquiries or disputes.
Security & Access Logs (IPs, Login history)	12 Months	For security audits and fraud investigation.
Support Tickets	2 Years	To maintain a history of service issues.

4.2. Data Where VIGO is Processor (Quiz & Lead Data)

For data owned by the Partner, we adhere to the Partner’s lifecycle.

Data Type	Retention Period	Control Mechanism
Lead Data (Quiz answers, collected emails, results)	Active Account Only	Retained as long as the Partner’s account is active.
Quiz Content (Questions, images, logic)	Active Account Only	Retained as long as the Partner’s account is active.
Deleted Items	30 Days	If a Partner manually deletes a lead/quiz, it remains in the “Trash” for 30 days before permanent removal.

5. Data Deletion Procedures

5.1. Automatic Deletion.

Expired Accounts: If a Partner account is voluntarily closed or terminated for non-payment, all associated Lead Data (Processor Data) is permanently deleted after a 90-day grace period (to allow for accidental closure recovery).
Logs: System logs are automatically rotated and overwritten every 12-24 months.

5.2. Manual Deletion (Right to Erasure).

Partners: Can delete specific leads or quizzes instantly via the LeadFilter Dashboard.
Leads (End-Users):

Requesting deletion of Quiz Data: Request is forwarded to the Partner (Controller).
Requesting deletion of Billing Data: VIGO will anonymize the personal details but must retain the transaction record for 7 years (Tax Law overrides GDPR deletion requests for financial records).

5.3. Deletion Method.

Deletion involves the removal of records from live databases and the clearing of associated files from cloud storage.

6. Exceptions (Legal Holds)

Data normally scheduled for deletion may be retained for a longer period if:

Legal Obligation: A valid court order, subpoena, or warrant is received.
Dispute Resolution: The data is evidence in an active chargeback dispute or lawsuit.
Fraud Investigation: The account is flagged for suspicious activity (e.g., card testing), in which case data is kept indefinitely for blacklisting purposes.

7. Archiving and Backups

To ensure platform resilience:

7.1. VIGO performs daily encrypted backups of the entire database.

7.2. Backups are stored in a secure, geographically separate facility.

7.3. Backup Rotation: Backups are retained for a maximum of 90 days. Therefore, data deleted from the live system will be completely removed from all backup archives within 90 days.

8. Data Anonymization

After the retention period expires, VIGO reserves the right to anonymize data instead of deleting it. Anonymized data (e.g., “A user from Canada bought a Quiz for $10”) does not contain Personal Identifiable Information (PII) and may be kept indefinitely for statistical analysis and algorithm improvement.

9. Security of Data Storage

During the retention period, all data is protected according to our Security Statement, including:

AES-256 Encryption at rest;
Strict access controls for employees;
Regular vulnerability scanning.

10. Policy Updates

10.1. VIGO ONLINE GROUP may update this Policy to comply with changing tax laws or privacy regulations.

10.2. Updates will be posted on leadfilter.ca.

11. Contact Information

For questions regarding data retention or to initiate a deletion request:

VIGO ONLINE GROUP

Privacy Officer

Email: support@leadfilter.ca

Phone: +1 437 886 3152