Data processing and retention policy

LEGAL_PACKAGE_COMPLETE=YES · EXTERNAL_LEGAL_REVIEW=PENDING

PMGI PROJECT MANAGEMENT SERVICES L.L.C (One Person LLC) · Dubai, UAE · Commercial Licence No. 1471379 · info@pmgi.ae

Version: AITS_LEGAL_PACKAGE_20261002_V9_1_DATA_RETENTION
Published: 2026-10-02 UTC
Registration CLOSED · PAPER-only demonstration; owner actual observations separate.

Privacy and data inventory

Controller: PMGI, contact above. Necessary account fields are name, normalized email, generated immutable identifiers, language, verification/status and notice acceptance evidence. Authentication stores password hashes, hashed recovery/verification references and expiring session references; never plaintext passwords. PAPER records hold tenant-scoped simulation instructions, positions, marks and reports. Security records contain minimal event/time and rate-limit metadata. No marketing consent, identity document, biometrics or optional analytics is collected by the application. The owner read-only mapping is separate from future customer onboarding. Do not include financial records or credentials in a support message.

Proposed purposes and legal bases for counsel review

Account and simulation data: necessity to provide the requested demo service, subject to counsel confirming the applicable UAE and audience-specific basis and necessity of each name field. Authentication and security: access protection and abuse prevention, subject to the applicable lawful basis and proportionality assessment. Acceptance evidence: demonstrate the applicable service terms and notice version; counsel must confirm the lawful basis and retention. Support and privacy requests: handle the request and applicable obligations, with identity minimization. Marketing: not performed. No blanket processing consent is inferred from reading a notice. No automated decision with legal or similarly significant effects is made. These are proposed mappings, not asserted approved legal bases.

Retention proposal and actual current behavior

The following schedule is a concrete minimization proposal for final approval, NOT an activated purge or a representation that deletion already occurs. Unverified signup and unused invitation records: 7 days after expiry. Expired verification/reset token rows and expired sessions: 7 days after expiry, preserving only minimal linked security audit when justified. Active profile and simulated ledger: while active; close and revoke promptly on verified request; purge or irreversibly de-identify 30 days after verified closure unless a documented lawful hold applies. Security and access logs: rolling 90 days. Resolved support/privacy cases: 12 months after closure. Notice acceptance evidence: 12 months after closure, subject to counsel’s mandatory limitation-period assessment. Encrypted rolling operational backups: 30 days; restore must replay deletion tombstones before service resumes. Synthetic non-personal regression evidence: 12 months; sanitized source/release hashes: 24 months. Holds require a recorded basis, custodian, scope and 90-day review, never indefinite default retention. Actual current customer deletion intervals are not approved; automatic customer purge is not enabled. Link expiry (verification 24 hours, reset and authenticated session 30 minutes) is not row deletion.

Deletion and request handling procedure

Responsible operational role: PMGI service operator; accountable privacy/complaints role: PMGI management through info@pmgi.ae. Record a minimal case reference, received time, request type and due-date assessment. Verify control through the authenticated account or existing verified email; never ask for password, recovery token or unnecessary identity documents. Confirm scope and applicable legal deadline, search tenant-specific profile, ledger, consent, auth, audit, mail/log and backup references; produce an export or proposed deletion inventory for review. Disable access and revoke sessions/tokens on verified closure through existing authorized operations. Review legal holds, approve the exact inventory, execute only under separately approved policy, retain minimal completion/tombstone evidence and reconcile backups on restore. Prevent cross-tenant exports. Proposed service targets: acknowledge within 5 business days and assess/escalate within 10 business days; these internal proposed targets never override a shorter applicable statutory deadline. Counsel must confirm applicable deadlines and supervisory authority before onboarding.

Change history and integrity

Content SHA-256: 94d56677daaeed97726df956a89ccdb505ed01b095feabe65d9d4d542673f56d

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