Data Retention and Deletion Policy

1.1 Purpose. This Policy sets out the principles we apply to the retention and deletion of personal data, the periods for which we ordinarily keep it, and the process by which a data subject may request its deletion.

1.2 Scope. This Policy applies both to the personal data for which Tarra Agility Africa is the data controller (for example, the account data of our users and website visitors) and to the records we process on behalf of a client as a data processor (for example, accounting records uploaded to the Platform for analysis).

1.3 Precedence. Where we process records on behalf of a client, the retention and deletion arrangements in the engagement letter or order form agreed with that client prevail over the default periods in this Policy to the extent of any inconsistency.

In accordance with the principle of storage limitation under the Act, we retain personal data only for as long as is necessary for the purpose for which it was collected, together with any further period required to meet a legal, tax, accounting or regulatory obligation or to establish, exercise or defend a legal claim. While we hold personal data, we keep it secure; when it is no longer required, we delete it or irreversibly anonymise it.

The following table sets out the periods for which we ordinarily retain the principal categories of personal data. Actual periods may be shorter or longer where a specific legal obligation, engagement or dispute requires it.

At the end of the applicable period, the data is securely deleted or anonymised in accordance with clause 6.

When a subscription ends or an account is closed, access to the Platform is withdrawn. Records processed on behalf of a client are returned to the client or deleted in accordance with the engagement, and any copies we are not required to keep are removed from our live systems within ninety (90) days, subject to the exceptions in clause 7. Data we are required by law to retain is kept only for the minimum period required and is then deleted.

5.1 Your right. You may ask us to delete personal data we hold about you where we no longer have a lawful basis to keep it. You may make a request using the contact details in clause 9.

5.2 How we handle a request. We will acknowledge your request, verify your identity, and respond within the period prescribed by the Act. Where your request concerns records we hold as a processor on behalf of a client, we will refer it to that client, who is the data controller of those records, and act on the client's instructions.

5.3 When we may decline. We may be unable to delete personal data where we are required to keep it by law, where it is needed for the establishment, exercise or defence of a legal claim, or on other grounds permitted by the Act. Where that is the case, we will explain our reasons and, where appropriate, restrict further processing of the data instead of deleting it.

We delete personal data using methods designed to make it irrecoverable from our live systems. Copies held in routine backups are not immediately overwritten; they are retained in secure, access-controlled backup media and are deleted as those backups cycle out of use in the ordinary course. During that interim period the data is isolated and is not used for any other purpose. Where a third party processes personal data on our behalf, we instruct it to delete the data in accordance with our contract with it.

We may retain personal data beyond the periods set out above where we are required or permitted to do so by law – for example, to comply with tax or anti-money-laundering obligations, to respond to a lawful request from a competent authority, or where the data is subject to a legal hold in connection with actual or anticipated proceedings. In each case we retain only the data necessary for that purpose and delete it once the obligation or hold comes to an end.

The Platform is hosted on the secure cloud infrastructure of Amazon Web Services in its Cape Town (South Africa) region. Deletion carried out under this Policy extends to data held by our hosting provider and other processors, each of which is bound by contract to delete personal data on our instructions and to the standard required by the Act.