Data Retention Policy

This Data Retention Policy describes the retention periods for different types of personal data processed by MEGA PROMOTING S.R.L. within Kallina AI services. We comply with the data minimization principle of GDPR (Art. 5(1)(e)). Effective Date: January 1, 2025

We follow these principles: Minimization: We only keep necessary data Time limitation: No longer than necessary Security: Protection throughout retention Secure deletion: Complete removal upon expiration Documentation: Clear record of periods

Data Type Period Legal Basis Account data (name, email) Account duration + 30 days Contract Call recordings 90 days (or per client settings) Legitimate interest Call transcriptions 1 year Contract Billing data 10 years Tax obligation Security logs 1 year Legitimate interest Analytics data 26 months (anonymized) Consent Session cookies Browser session Contract Persistent cookies Max 13 months Consent Support data (tickets) 3 years from closure Legitimate interest Backups 30 days (rotating cycle) Contract

Voice recordings: Default period: 90 days Client configurable: 30-365 days Enterprise: per contract Transcriptions: Kept for functionality and analytics Anonymization after 1 year AI training data: We do not use your data for training without explicit consent Aggregated and anonymized data: indefinite retention

Automatic deletion: Automated processes after period expiration Monthly check for expired data Deletion on request: Processed within 30 days Email: contact@kallina.info (subject: "Data Deletion") We confirm deletion in writing Exceptions to deletion: Legal obligations (e.g., invoices - 10 years) Ongoing litigation Anonymized data (no longer personal)

Upon account closure: Immediate: Access is disabled 30 days: Grace period for recovery 90 days: Operational data deletion Retained: Tax data per law

Backup policy: Daily backup with 30-day retention Backups follow same security standards Deletion from backups in normal rotation cycle Upon deletion request, data is removed from backups within 30 days.

For data transferred outside EEA: Retention periods remain the same Protection through SCC and technical measures Sub-processors follow same periods

You have the right to: Request information about your data retention Request early deletion (with legal exceptions) Obtain a copy of data before deletion Contest retention periods

This policy may be updated. We notify you of significant changes via email and on the platform at least 30 days in advance.

MEGA PROMOTING S.R.L. IDNO: 1019600021765 Email: contact@kallina.info Phone: +373 61 066 888