Data retention policy

1. Purpose

• This Policy sets out the periods for which that Personal Data processed by RandomCoffee is to be retained.

2. Scope

• This policy applies to Personal Data processed on behalf of its customers, excluding data about Random Team employees or other activities

3. Definitions

TermDefinitionConfidential Informationmeans non-public information that derives independent value from not being generally known to the public, but does not include any information that (i) was or subsequently becomes publicly available without breach of any confidentiality obligations, (ii) was known prior to the disclosure of such information, (iii) was or is subsequently obtained from another source without breach of any confidentiality obligation, or (iv) is independently developed without reference to any Sensitive and/or Confidential Information.Data Controllermeans the person or organization that determines the purpose and means of the Processing of Personal Data.Data Subjectmeans a living, identified or identifiable individual for whom Random Team holds Confidential Information. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.Employeesmeans who are employees of Random Team’ customers and for whom Random Team holds and processes Personal DataGDPRmeans the Regulation (EU) 2016/679 on the protection of natural persons with regard to Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).Personal Datameans any information relating to an identified or identifiable natural person (“Data Subject”)

4. Type of data processed

• Random Team processes information on behalf of its customers (the Data Controllers). The type of information generally processed by Random Team includes the following categories of data.
• Personal Data uploaded onto the platform containing nominative data such as first names, last names or emails
• Data generated following the use of the platform RandomCoffee

4.1 Personal Data

• Random Team processes Personal Data as defined by the EU GDPR on behalf of its customers. It includes:

Type of DataExampleFirst NameJohnLast NameDoeProfessional Emailjohn.doe@acme.comWork-related Information (e.g.: Team, floor, department or any work-related information that may be used to use the product.)Marketing, 3rd Floor

4.2 Data generated following the use of RandomCoffee

• The use of RandomCoffee by Random Team’s customers generates data that is processed by Random Team. It includes:

Type of DataExampleAcceptance Information, i.e.: employees who accepted to meet a colleagueJohn Doe accepted to meet a new colleague for Session #2History of the matches, i.e.: groups of employees matched together thanks to RandomCoffeeJohn Doe & Jane Doe matched for Session #2

4.3 Sensitive Personal Information

• Random Team does not process Sensitive Personal Information as defined by the EU GDPR.

5. Data retention

• Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
• In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

Type of Personal DataCategory of Data SubjectNature of Processing Carried OutPurpose(s) of ProcessingDuration of the ProcessingFirst Name, Last Name, Professional Email

Work-related Information (e.g.: Team, Department, Building)

IP Addresses

EmployeesStorage, Communication by emailCreating targeted connections between Employees & Communicating targeted connections to concerned employeesDuration of the Service Agreement + 30 DaysAcceptance information and history of the matchesAnalysis of connections createdEnable the Data Controller to have a deeper understanding of the connections created