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Data Retention Policy

The Developing Leaders Partnership/Gyre®: Data Retention Policy
Last Update: March 2024

1. Introduction

1.1 This Data Retention Policy ("Policy") outlines the principles and procedures governing the retention of data collected and processed by The Developing Leaders Partnership trading as - Gyre ("Company") a digital team development platform.


1.2 The Policy applies to all data pertaining to the Company's customers ("Customers") and their employees ("Users").

2. Definitions

2.1 Data:  Any information collected, processed, or stored by the Company in the course of its business operations. This includes personal data, activity data, and any other information associated with Customers and Users.


2.2 Personal Data: Data that can be used to identify a natural person, directly or indirectly, such as name, email address, and Job Title.

2.3 Activity Data: Data generated by a User's interaction with the platform, such as login times, sessions completed, and feedback provided.

3. Data Retention Principles

3.1 The Company is committed to retaining data only for as long as necessary for the purposes for which it was collected and processed, or as required by law.


3.2 The Company will regularly review its data retention periods to ensure compliance with this Policy and relevant legal obligations.


3.3 The Company implements appropriate measures to safeguard data against unauthorized access, disclosure, alteration, or destruction.


3.4 The Company will Adhere to relevant laws, regulations, and industry standards governing data retention and privacy.

4. Data Retention Periods

4.1 Customer Data:
Active Customers:  Customer data will be retained for the duration of the Customer's subscription with the Company.
Inactive Customers:  Customer data will be retained for a period of 5 years following account inactivity, after which it will be securely anonymized or deleted, unless longer retention is mandated by law.

4.2 User Data:
Active Users:  User data will be retained for the duration of their employment with the Customer and their active use of the platform.
Inactive Users:  User data will be retained for a period of 3 years following their last login, after which it will be securely anonymized or deleted, unless longer retention is mandated by law.

4.3 Exceptions:
The Company may retain data for longer periods than outlined above in the following circumstances:
4.3.1  To comply with a legal obligation, such as a court order or regulatory investigation.
4.3.2 To resolve disputes or enforce the Company's terms and conditions.
4.3.2 To preserve business records for legitimate business purposes, such as tax or accounting purposes.

5. Data Anonymization and Deletion

5.1 When data reaches the end of its retention period as outlined in this Policy, the Company will take steps to securely anonymize or delete the data.

5.2 Anonymization will involve irreversibly modifying the data to render it impossible to identify an individual.

5.3 Deletion will involve the permanent erasure of the data from the Company's systems.

6. User Access and Control

6.1 Users have the right to access and modify their personal data stored by the Company. This includes the ability to request the deletion of their data, subject to the restrictions outlined in Section 4.3.


6.2 Customers can manage User access and data within the platform administration settings.

7. Review and Updates

7.1 The Company reserves the right to review and update this Policy periodically. Any changes will be communicated to Customers and Users through the platform or by email.

8. Contact

8.1 If you have any questions about this Policy or the Company's data retention practices, please contact us at

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