Closing your company? Don't forget the most overlooked asset – your data

For most people, closing a company is a long list of practical steps: end contracts, give up premises, pay debts, sell what can be sold. In the middle of all this, one asset is almost always forgotten – the company's data. Email archives, Slack or Teams channels, support tickets, CRM history and documents have long been seen as something to simply delete. But as AI labs buy workplace data to train AI agents, those archives can have real value. This guide covers what happens to the data in different types of wind-down, what GDPR requires and why timing is critical.

This guide is an overview, not legal advice. Procedures differ between countries – always check with the liquidator, insolvency administrator or a lawyer before making decisions.

Why data is an overlooked asset

In 2025–26, Fast Company, Gizmodo and Forbes reported on US startups that shut down and sold their Slack and email archives to AI companies. The reason is simple: AI agents are meant to learn to carry out real work tasks, and that shows best in the communication that arises when people work. A company that has operated for several years has built up exactly that kind of history.

For European companies, language adds to it. Nordic and other smaller European languages make up a small share of global training data – AI Sweden built GPT-SW3 on a Nordic corpus, and OpenEuroLLM has had to generate synthetic data because of the shortage. Authentic business communication in these languages is therefore rare.

At the same time, the data isn't free to sell just because the company is ending. Personal data, employee privacy and platform terms apply just as much in a wind-down as at any other time.

Three ways to close a company – and what happens to the data

How the data can be handled depends heavily on the type of wind-down. The details vary by jurisdiction, but the broad patterns are similar across Europe.

Voluntary liquidation

In a voluntary liquidation, the liquidator is responsible for winding up the business and dealing with the company's assets. The data is part of that. This is often where conditions are best for doing something well thought-out: there is time to map the archives, look into rights and personal data, and make decisions in an orderly way.

Licensing data that can be licensed may contribute to the liquidation. That requires the question to be raised early and the liquidator to be involved in the decisions.

Insolvency

In an insolvency or bankruptcy, an appointed administrator or trustee controls the company's assets. The board and owners cannot license or sell data on their own. If you think the company's data may have value, the administrator is the one who needs to know.

There is also a practical risk in insolvencies: systems are cancelled or shut down quickly when payments stop. An email archive or a Slack workspace can disappear before anyone has had time to consider whether its contents have value.

Asset sale

In an asset sale, the business or parts of it – such as customer contracts, the brand and equipment – are sold, while the company as a legal entity remains and can then be wound down. The data can either go with the buyer or stay in the company.

A clear agreement is essential here. If customer data and archives go to the buyer, the buyer has its own responsibilities under GDPR. If the data stays behind, you need to decide what happens to it. A non-exclusive, limited license for AI training can in some cases be negotiated in parallel, but it must not conflict with what the buyer has acquired.

GDPR when the company closes

The company being wound down doesn't change the basic rules. As long as the personal data exists, it is covered by GDPR, and a new use such as AI training is assessed just as it otherwise would be:

• Lawful basis – the European Data Protection Board (EDPB) made clear in Opinion 28/2024 that legitimate interest is not an automatic basis for AI training and that a documented balancing test is required.
• Compatible purpose – data protection authorities have stressed that reuse for AI training must be compatible with the original purpose.
• Synthetic data – generating synthetic data from personal data is itself processing, as authorities have pointed out. It is not a way around the rules.
• Sensitive data – we do not broker health data or other special categories under Article 9.
• Employees – emails and chats from staff can be covered by workplace privacy rules, and depending on your country, employee representatives or a works council may need to be informed or consulted. That applies even when the business is ending.

In practice, this means most of what could be relevant is data that has been de-identified, or content that contains no personal data at all. Read more in our overview of GDPR and anonymization.

Timing: before the archives are deleted

Perhaps the most important question when closing a company is when. The data often lives in cloud services paid for on an ongoing basis. When the subscriptions are cancelled, the contents are deleted after a while. Then there is nothing left to assess, and nothing to license.

At the same time, you mustn't hoard data without reason. GDPR requires that personal data is not kept longer than necessary. So it is about making a deliberate decision in the right order:

1. Map which systems contain data and when the subscriptions expire.
2. Make an initial assessment of whether any part may have value – this can be done without sending any files.
3. Look into export options. Salesforce has reportedly restricted bulk export and LLM training through Slack's API terms. How you can export your own archives requires legal review.
4. Decide whether the data is to be licensed, transferred or deleted – and document the decision.
5. Delete whatever won't be used, in line with your obligations.

Common mistakes in a wind-down

A few patterns recur when companies close, and most are about data being handled too late or too carelessly:

• Subscriptions are cancelled first. It is tempting to start by cutting costs. But when the email and chat services disappear, so does any chance of assessing their contents.
• Someone takes a copy. A former founder or employee who keeps an archive "just in case" can create problems both under GDPR and over who actually has rights to the data.
• The data goes with an asset sale without it being stated. If the agreement is unclear, disputes can arise later about who may use the archives.
• The personal data is forgotten. The company ceasing to exist doesn't mean the data subjects' rights do.
• Nobody documents the decisions. Whether the data is licensed or deleted, it is wise to be able to show what was done, why and by whom.

What all these mistakes have in common is that they can be avoided with a little planning at the start of the wind-down.

Data checklist when closing a company

• Which data sources exist: email, Slack or Teams, support systems, CRM, documents, call recordings, ERP exports?
• How long a history is there, and in which languages?
• Who makes the decisions: the board, the liquidator or the insolvency administrator?
• Are there customer agreements, confidentiality obligations or platform terms that limit use?
• What personal data is there, and are there any special categories?
• Do employees or employee representatives need to be informed or involved?
• What has the buyer acquired, if it is an asset sale?
• When will the data be deleted automatically if nothing is done?

How a license can work

With us, the process is the same whether the company continues or is being wound down. You describe the data in a short form that takes about two minutes, without sending files. We assess rights and personal data and get back to you within 48 hours on business days. If there is a possible deal, you get a concrete offer that you – or the liquidator or administrator – consider. Nothing is shared until there is a non-disclosure agreement and an approved offer, and delivery only takes place after de-identification.

The assessment is free, and we get paid through a share only when a deal goes through. If you wonder what the data might be worth, there is an overview of value factors in the guide how much is company data worth, and more on the wind-down situation specifically on closing a company and selling data.

Summary

When you close a company, it is easy to see the data as something that just needs to go. But email, chats and tickets can be an asset – if rights and personal data can be handled, and if the question is raised before the archives are deleted. The form of wind-down determines who decides: the liquidator, the insolvency administrator or the parties to an asset sale. GDPR applies in full all the way. Start with a mapping exercise, and do it in good time.