Data Retention, Export and Deletion Policy

This policy explains how TrueValue Technologies Ltd handles retention, export and deletion across the service. It forms part of the Terms of Service and Schedule 4 of the DPA for Customer Personal Data. Company number 17462580; registered office 66 Paul Street, London, England, United Kingdom, EC2A 4NA. Contact privacy@truevalue.business.

Customer-controlled workspace content is processed according to the customer's lawful instructions. TrueValue separately controls certain account, billing, security and legal records for the purposes described in the Privacy Notice. These categories may have different retention requirements; a reason to keep an invoice is not a reason to keep an entire acquisition data room.

Stopping renewal normally leaves the paid workspace available until the end of its paid billing period. That is not the same as immediately closing the account or erasing its data. Effective termination is the date paid access ends, unless an earlier termination remedy or agreement applies.

A verified administrator may instruct deletion of customer-controlled content, subject to appropriate authority and applicable legal restrictions. An individual rights request is assessed separately: deleting a person's login does not necessarily remove their name from another controller's lawfully retained transaction record. We do not require closure of an entire organisation account merely to consider an individual's rights.

Use available export functions before termination where possible. You may request a standard export before termination or within seven calendar days afterwards. We will deliver it within seven calendar days of the verified request, subject to a lawful restriction or a different written arrangement. Following termination, restricted assistance or export access is for return of data, not continued use of paid functionality.

A standard export covers customer-controlled records and uploaded files within the service's agreed scope, together with relevant available output and signing evidence. Structured records are supplied in a commonly usable format such as CSV or JSON where appropriate; documents are returned in their available original or export format. We identify any material limitations rather than describing an incomplete extract as a full export.

The export does not include other customers' information, licensed third-party datasets beyond the permitted licence, TrueValue source code or confidential internal security materials. These exclusions do not remove a right to personal data or a copy of customer-owned content required by law or the DPA. We will explain a relevant restriction and provide a lawful alternative where possible.

A standard contractual export is included without an exit fee. Bespoke transformation or migration work outside the standard obligation may be separately quoted and accepted. A payment dispute does not permit us to withhold statutory assistance or an otherwise required export solely to obtain leverage.

Customer-controlled active content is deleted or irreversibly anonymised within 30 calendar days after effective termination or a verified earlier deletion instruction, except where law requires retention or the customer separately agrees a lawful, time-limited export extension. We will explain a relevant exception and restrict use accordingly.

Deletion must cover relevant database records, uploaded files, derived document text, search indexes, embeddings, generated content, caches and service copies, not merely removal of the user interface. We pass appropriate instructions to appointed subprocessors and manage their residual retention within their agreed terms.

Removing one item may leave a minimal record needed to show that it was deleted or to maintain security, without retaining the unnecessary original content. Irreversible anonymisation must prevent reasonable re-identification; replacing a name with a reversible identifier is not equivalent to erasure.

Residual copies in protected backups expire within the verified maximum periods in section 6. They are not available for ordinary customer access, analytics, AI use or marketing. They remain protected by the DPA and may be restored only for authorised recovery purposes, with deletion instructions reapplied before normal processing resumes.

Backup expiry is distinct from active deletion. We do not promise immediate removal from an immutable backup when that is not technically true, and do not use “backups” as an indefinite retention exception. A stricter existing contractual promise must be separately honoured or lawfully varied; this policy does not silently weaken it.

Each period must be supported by a documented purpose and implemented deletion process. A supplier's default retention does not automatically become an acceptable TrueValue retention period.

We may retain specified information where required by law, a binding order or a justified legal hold. We document the reason, scope, access restrictions and review or release trigger. Once the basis ends, the ordinary deletion process resumes. We notify the customer where lawful and appropriate.

We cannot erase documents already lawfully downloaded or copied into a recipient's separate systems merely by removing access in TrueValue. The customer or recipient must address those copies under its own obligations. TrueValue remains responsible for deletion instructions within its control and for its appointed subprocessors.

We may verify the identity and authority of a requester proportionately. A material export or deletion instruction should identify the workspace, scope and destination, and whether retention of any specific records is lawfully requested. No ordinary confirmation process extends a statutory deadline unlawfully.

On reasonable request we confirm completion of relevant deletion steps and explain any residual backup cycle or lawful hold. We review this policy and the underlying schedule when systems or legal requirements change. A new policy date alone does not authorise retention for a new incompatible purpose.