Data Retention Policy

01Principle

Records are retained for as long as the transaction relationship requires, plus the period needed to meet legal, tax, anti-money-laundering and evidential obligations. Records are then deleted or irreversibly anonymised.

02Retention periods

• Onboarding and due diligence files (identity, corporate documents, proof of funds, proof of product): retained for the relationship and for 5 years after the last transaction or after the account is closed.
• Transaction records (references, parties, milestones, contracts, instructions, assay and refinery records): 7 years from completion or termination.
• Audit history and release approvals: 7 years. These records are append-only and cannot be edited or deleted while retained.
• Secure messages and document requests: retained with the transaction file they belong to.
• Draft applications never submitted: deleted by the applicant at any time, and cleared by the desk after 12 months of inactivity.
• Rejected or expired applications: 5 years, to evidence the decision taken.
• Website enquiry emails: 24 months.

03Storage and access

Uploaded files are held in private storage. They are never publicly addressable, are not attached to notification emails, and are released only to parties whose approved role requires them.

04Deletion and requests

You may ask us to delete personal data. Where a record is subject to a legal or anti-money-laundering retention obligation, or is required as evidence in a live or disputed transaction, we will retain it for the remaining period and restrict its use instead of deleting it.

Deletion requests: commodities@newxearth.com.