Data Retention and Deletion Policy
1. Purpose & Governance
This Data Retention and Deletion Policy ("Retention Policy") establishes the mandatory schedules and cryptographic procedures for retaining, archiving, and securely deleting personal data, transaction records, and technical telemetry collected by [Paytali Technologies Ltd. / Operating Entity] ("Paytali").
This policy balances data minimization principles under the Egyptian PDPL (Law 151/2020) and Nigerian NDPA 2023 against mandatory record-keeping obligations enforced by anti-money laundering and counter-terrorist financing authorities.
2. Statutory Retention Schedule
The table below sets forth the designated retention periods for specific data categories:
| Data Category | Specific Records | Mandatory Retention | Legal Basis |
|---|---|---|---|
| KYC / KYB Due Diligence | National IDs, passports, Smile ID biometric audit trails, proof of address, CAC/commercial registers | 5 Years Post Account Closure | Egyptian AML Law 80/2002; Nigerian MLPPA 2022; FATF Rec. 11 |
| Financial & Ledger Entries | Append-only ledger entries, order receipts, bank transfer proofs, merchant collateral history | 5 Years From Transaction Date | Commercial Code & Statutory Tax/Audit Accounting Laws |
| Dispute & Fraud Files | Dispute filings, bank statement exhibits, mediator determinations, SAR/STR filings | 5 Years From Resolution | Financial Crimes Compliance & Litigation Defense |
| P2P Order Communications | In-app transaction coordination messages and order status updates | 90 Days Post Completion | Data Minimization Principle (Extended if Disputed) |
| Technical Telemetry & IP Logs | Access logs, authentication tokens, IP addresses, device user-agents | 12 Months | Platform Cybersecurity & Threat Detection |
3. Secure Storage & Segregation
During their retention period, records are protected through defense-in-depth security measures:
- Zero Plain-Text Identity Storage: Identity documents uploaded during Smile ID KYC are stored in private, non-public AWS/R2 object storage buckets encrypted with unique AES-256 keys;
- Append-Only Ledger Immutability: Historical transaction ledger entries are append-only. Past ledger records cannot be overwritten, deleted, or backdated;
- Restricted Archival Access: Inactive account files are transitioned to cold encrypted storage accessible only by senior compliance officers with dual-key approval.
4. Account Deletion & Cryptographic Erasure
Users may request account termination and personal data erasure by emailing privacy@paytali.com.
Upon verification of the request:
- Active account access is permanently disabled;
- Marketing contact lists and optional profile preferences are immediately erased;
- Non-statutory telemetry and ephemeral communications are purged using secure cryptographic deletion;
- Statutory financial records, AML identification dossiers, and dispute files are flagged as "Archived - Closed Account" and retained strictly until the mandatory 5-year statutory period expires, after which they are permanently destroyed.