01Principles
- Storage limitation. Data is kept only as long as the purpose requires or the law obliges (Art. 6(4) FADP; Art. 5(1)(e) GDPR).
- Registry continuity. Because third parties rely on records, lifecycle events (status changes, disputes, expiry, withdrawal) are appended to the record rather than deleting it, so that the audit trail stays coherent.
- Evidence confidentiality. Evidence is retained privately and never published, whatever its retention period.
- Documented deletion. Deletions are performed under a schedule, logged, and extended to backups within the backup rotation period.
02Retention schedule
| Category | Retention period | Basis |
|---|---|---|
| Public registry records | For as long as the record serves the registry’s verification function. Withdrawn records are reduced to an audit stub (registry ID, dates, status history) rather than erased. | Legitimate interest of SWLEF and verifiers; Art. 17(3)(e) GDPR (legal claims) |
| Private review notes | Life of the record + 10 years | Defence of legal claims; Art. 127 Swiss Code of Obligations (10-year limitation) |
| Submitted evidence documents | Life of the record + up to 10 years, unless earlier deletion is requested and no legal obligation or open dispute requires retention | Contract; defence of legal claims |
| Company and representative data | While the company account exists + 10 years for data forming part of a reviewed record | Contract; accounting law |
| Account data (users) | While the account exists; deleted or anonymised within 90 days of closure | Contract |
| Platform connection tokens | Until the connection is removed or lapses; deleted immediately thereafter | Contract; consent |
| Platform connection history | Connection identifier, method and verification dates: life of the record (printed on certificates) | Legitimate interest in certificate integrity |
| Certificates issued | Issue log (registry ID, timestamp, requesting account, signature) for the life of the record + 10 years; rendered files are cached briefly and regenerated on demand | Verification function; defence of legal claims |
| Payment and accounting records | 10 years from the end of the financial year | Art. 958f Swiss Code of Obligations; VAT Act |
| Rights and takedown desk correspondence | 5 years after the case is closed | Defence of legal claims; dispute history |
| Support correspondence | 2 years after the last message | Legitimate interest |
| Operational logs (IP, user agent, pages, security events) | Maximum 30 days, unless preserved for a specific security investigation | Legitimate interest in security |
| Presence signal (live visitors) | Real time; aggregated counts only thereafter | Legitimate interest |
| Newsletter subscriptions | Until unsubscribed; a hashed suppression entry is kept to honour the opt-out | Consent; legal obligation to honour opt-outs |
| Backups | Encrypted daily backups rotated within 35 days; deletions propagate at the end of the rotation | Legitimate interest in resilience |
03Deletion requests
Requests for access, correction or deletion are addressed to dmca@swlef.com (subject “Data protection”) and answered within 30 days. Deletion is carried out unless a retention period in the schedule, an open dispute, a legal obligation or the establishment, exercise or defence of legal claims requires otherwise; in that case we tell you what is retained and why.
Where a public record was relied upon by third parties, SWLEF retains a minimal audit stub — registry ID, dates, status history and the fact of withdrawal — so that a certificate presented later can be identified as withdrawn. The stub contains no personal data beyond what is strictly necessary for that purpose.
04Legal holds
When SWLEF receives a court order, a substantiated notice, or becomes aware of litigation or an investigation concerning a record, the affected data is placed on legal hold and excluded from scheduled deletion until the matter is closed. Legal holds are logged with their reason and reviewed every six months.
05Review of this policy
The schedule is reviewed annually and whenever a new category of data is introduced. Changes are listed in the change log below.
Change log
| Version | Date | Change |
|---|---|---|
| 2.0 | 2026-10-06 | Aligned with Swiss law (CO Art. 958f, Art. 127; FADP): full retention schedule with basis per category, platform tokens, certificates, legal holds, backup rotation. |
| 1.0 | 2026-07-07 | Initial schedule referencing German commercial law. |
How to cite this document. SWLEF, “Data Retention Policy”, SWLEF-LGL-08 v2.0, effective 2026-10-06, https://swlef.com. The authoritative version is the one published at the URL in your browser’s address bar at the time of access; archived versions are available on request from dmca@swlef.com.
Language. This document is drafted in English. Courtesy translations may be provided; in case of divergence the English text prevails.