Data Retention & Deletion Policy

1. Purpose & Scope

Friendium is a real-identity social network built on trust, accountability, and transparency. This policy governs how long different categories of data are retained, the conditions under which data is deleted or anonymized, and how users can exercise their rights over personal information.

This policy applies to all users, visitors, business accounts, and legacy accounts using Friendium services, websites, applications, APIs, and related features.

2. Legal & Regulatory Framework

Friendium’s data retention practices are designed to comply with applicable global privacy and data protection laws, including but not limited to:

• EU General Data Protection Regulation (GDPR)
• UK GDPR & Data Protection Act
• California Consumer Privacy Act (CCPA) & CPRA
• Other applicable national and regional privacy laws

3. Categories of Data Collected

Friendium may collect and process the following categories of data:

• Account information (name, email, date of birth)
• Profile data (photos, bio, relationships, interests)
• Content data (posts, comments, reactions, messages)
• Connection data (friends, followers, interactions)
• Device and technical data (IP address, logs, identifiers)
• Security and integrity data (reports, enforcement actions)
• Payment and transaction data (if applicable)

4. Data Retention Principles

Friendium adheres to strict data minimization and purpose limitation principles. Data is retained only for as long as necessary to:

• Provide core platform functionality
• Maintain account security and integrity
• Comply with legal obligations
• Resolve disputes and enforce policies
• Prevent fraud, abuse, and misuse

5. Standard Retention Periods

Retention periods vary depending on the type of data and legal requirements:

• Active account data: Retained while the account remains active
• Deactivated account data: Retained during the deactivation grace period
• Deleted account data: Scheduled for deletion or anonymization
• Logs and security records: Retained for limited periods for safety
• Financial records: Retained as required by law

6. Account Deactivation vs. Deletion

Deactivation temporarily disables account visibility and activity but does not immediately delete data. Deletion initiates a permanent removal process subject to legal retention requirements.

• Deactivated accounts may be reactivated
• Deleted accounts cannot be restored
• Some data may remain in backups for a limited time

7. Data Deletion Process

When data is eligible for deletion, Friendium follows secure deletion procedures designed to prevent unauthorized recovery:

• Logical deletion from active systems
• Scheduled removal from backups
• Anonymization where deletion is not feasible
• Verification and audit logging

8. Anonymization & Aggregation

In some cases, Friendium may retain anonymized or aggregated data for analytics, research, and platform improvement. Such data cannot be linked back to individual users.

9. Legal Holds & Exceptions

Data deletion may be delayed where retention is required to:

• Comply with legal obligations or court orders
• Respond to law enforcement requests
• Investigate abuse, fraud, or safety incidents
• Resolve disputes or enforce agreements

10. User Rights & Requests

Users have the right to request access, correction, deletion, or restriction of their personal data, subject to verification and legal limitations.

• Right to access and portability
• Right to rectification
• Right to erasure (“right to be forgotten”)
• Right to restriction of processing

11. Identity Verification

To protect user privacy and prevent abuse, Friendium may require identity verification before processing sensitive data requests.

12. Security Safeguards

Friendium implements administrative, technical, and organizational measures to protect retained data against loss, misuse, unauthorized access, or disclosure.

13. Third-Party Data Processors

Where data is processed by trusted third-party service providers, Friendium ensures contractual safeguards and deletion obligations are in place.

14. Transparency & Accountability

Friendium documents retention schedules, audits compliance, and publishes transparency reports where required.

15. Policy Updates

This policy may be updated to reflect legal, technical, or operational changes. Material updates will be communicated to users.

16. Contact

Privacy Office: privacy@friendium.com
Data Protection Officer: dpo@nexa-group.org
Legal: legal@nexa-group.org