1. Introduction
This Data Retention and Deletion Policy (“Policy”) describes the manner in which LUNEXA collects, retains, archives, stores, restricts, deletes, anonymizes, and disposes of personal information, business information, transactional records, and other data collected through its Platform and Services. This Policy is intended to ensure responsible information lifecycle management, compliance with applicable laws, protection of Users’ privacy, maintenance of business continuity, and preservation of legal rights and obligations.
2. Purpose
The purpose of this Policy is to establish transparent and legally compliant procedures governing the retention, storage, preservation, archival, anonymization, and deletion of information processed by LUNEXA. LUNEXA seeks to retain information only for legitimate business, contractual, operational, legal, regulatory, accounting, taxation, dispute resolution, cyber security, fraud prevention, and compliance purposes.
3. Scope
This Policy applies to all personal information, business information, account information, communication records, contracts, payment records, intellectual property documents, project files, website usage information, technical logs, customer support records, and every other category of information processed by LUNEXA through its Platform or Services. This Policy applies to every User, Client, vendor, consultant, service provider, employee, contractor, business partner, and any other person whose information is processed by LUNEXA.
4. Applicable Laws
LUNEXA shall retain and delete information in accordance with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, applicable rules framed thereunder, tax laws, commercial laws, intellectual property laws, judicial directions, governmental notifications, and every other applicable law in force within the Republic of India. Where foreign laws become applicable due to cross-border engagements, LUNEXA may adopt additional safeguards to ensure lawful processing.
5. Principles of Data Retention
LUNEXA shall retain information only for lawful, necessary, proportionate, and legitimate purposes. Information shall not be retained indefinitely unless retention is required by law, judicial proceedings, contractual obligations, regulatory compliance, or the protection of legal rights and legitimate business interests.
6. Categories of Information Retained
LUNEXA may retain personal identification information, contact details, account registration data, business information, payment details, invoices, communication records, contracts, project documentation, branding materials, trademark-related documents, intellectual property records, photographs, design files, technical logs, website analytics, customer support records, and any other information reasonably necessary for providing its Services.
7. Account Information
Account registration details and profile information shall be retained for as long as the User maintains an active account or until such information is no longer required for legitimate business or legal purposes. Certain account records may continue to be retained after account closure where required by law or legitimate business necessity.
8. Service Records
Information relating to branding services, trademark facilitation, business consulting, marketing strategy, website development, catalogue design, photography, startup advisory services, and other professional engagements may be retained for contractual performance, future reference, regulatory compliance, dispute resolution, quality assurance, and maintenance of historical project records.
9. Communication Records
Emails, customer support requests, chat communications, consultation records, telephone discussions, feedback, notices, legal correspondence, and complaint records may be retained for operational management, customer service improvement, legal compliance, audit purposes, and dispute resolution.
10. Payment and Financial Records
Invoices, quotations, payment receipts, banking references, taxation documents, accounting records, refund information, and financial transaction records shall be retained for accounting, auditing, taxation, statutory reporting, fraud prevention, and legal compliance in accordance with applicable financial laws.
11. Intellectual Property Records
Trademark applications, copyright records, design registrations, legal notices, affidavits, evidence, correspondence, licensing documentation, assignment deeds, and other intellectual property-related documents may be retained for protecting legal rights, maintaining historical records, and defending or enforcing intellectual property claims.
12. Website Usage Information
LUNEXA may retain server logs, device identifiers, browser information, cookies, IP addresses, security logs, website analytics, technical diagnostics, and usage records for cyber security, fraud detection, website performance improvement, system administration, and legal compliance.
13. Security Logs
Information relating to login attempts, authentication records, access logs, suspicious activities, cyber security incidents, malware detection, unauthorized access attempts, and security monitoring may be retained for protecting the Platform, Users, and business operations from security threats and unlawful activities.
14. Backup Copies
Information may continue to exist in encrypted backup systems, disaster recovery infrastructure, archival storage, and business continuity systems for a reasonable period after deletion from active systems. Such backup information shall not ordinarily be restored except where necessary for disaster recovery, legal compliance, or system restoration.
15. Data Archival
Where active operational use has ceased but continued preservation is required by law or legitimate business interests, LUNEXA may archive information in secure storage environments with restricted access and appropriate technical and organizational safeguards.
16. Legal Preservation
Where information becomes relevant to pending or anticipated litigation, arbitration, investigation, governmental inquiry, regulatory inspection, law enforcement proceedings, or legal claims, LUNEXA may suspend deletion and preserve such information until the relevant matter has been fully resolved.
17. User Requests for Deletion
Users may request deletion of their personal information by submitting a written request through the designated communication channels. LUNEXA shall evaluate each request in accordance with applicable law, contractual obligations, legitimate interests, and statutory retention requirements before processing such request.
18. Circumstances Where Deletion May Be Refused
LUNEXA may decline or postpone deletion where retention is required for legal compliance, taxation, accounting, fraud prevention, cyber security, contractual enforcement, dispute resolution, judicial proceedings, regulatory obligations, protection of legal rights, or any other lawful purpose permitted under applicable law.
19. Data Deletion Process
Where deletion is legally permissible, LUNEXA shall take reasonable technical and organizational measures to permanently erase, anonymize, overwrite, destroy, or otherwise render the information irretrievable from its active operational systems within a reasonable period.
20. Anonymization
Where complete deletion is impracticable or unnecessary, LUNEXA may irreversibly anonymize information so that it can no longer identify any individual. Anonymous information may thereafter be retained for research, analytics, statistical reporting, service improvement, and business intelligence purposes.
21. Third-Party Service Providers
Where information has been shared with authorized vendors, cloud hosting providers, payment gateways, communication service providers, or other third parties for legitimate business purposes, LUNEXA shall make reasonable efforts to ensure that such third parties retain and delete information in accordance with contractual obligations and applicable laws.
22. Cross-Border Storage
Where information is stored, processed, or backed up outside India, LUNEXA shall implement reasonable safeguards to ensure an appropriate level of protection consistent with applicable legal requirements, contractual obligations, and internationally recognized security practices.
23. Secure Disposal
Information scheduled for permanent deletion shall be disposed of through secure technical and physical methods designed to prevent unauthorized recovery, reconstruction, disclosure, alteration, or misuse of such information.
24. User Responsibilities
Users are responsible for maintaining copies of documents, communications, certificates, reports, deliverables, and other information that they consider important. LUNEXA shall not be responsible for any loss resulting from lawful deletion carried out in accordance with this Policy and applicable law.
25. Data Accuracy
Users are encouraged to periodically review, update, and correct their personal and business information maintained by LUNEXA. Accurate information assists in reducing unnecessary retention, duplication, and processing errors.
26. Review of Retained Information
LUNEXA may periodically review retained information to determine whether continued retention remains necessary for lawful business purposes, contractual obligations, legal compliance, operational efficiency, or cybersecurity requirements. Information no longer required may be securely deleted or anonymized.
27. Limitation of Liability
LUNEXA shall not be liable for the retention or deletion of information carried out in good faith in accordance with applicable laws, judicial orders, regulatory requirements, contractual obligations, this Policy, or reasonable business practices.
28. Amendments
LUNEXA reserves the right to modify, update, replace, supplement, or withdraw this Policy at any time to reflect changes in applicable laws, technological developments, regulatory requirements, business operations, security practices, or organizational policies. Any revised Policy shall become effective upon publication on the Platform unless otherwise specified.
29. Governing Law and Jurisdiction
This Policy shall be governed by and interpreted in accordance with the laws of the Republic of India. Any dispute arising out of or relating to this Policy shall be subject to the jurisdiction specified in the Terms and Conditions of LUNEXA and the competent courts having jurisdiction.
30. Contact for Data Retention and Deletion Requests
Any request relating to data retention, access, correction, restriction, deletion, withdrawal of consent, or any other privacy-related matter may be submitted to the designated Data Protection Contact or Grievance Officer through the official contact details published on the LUNEXA Platform. LUNEXA shall process such requests in accordance with applicable law, internal procedures, and this Policy while balancing the rights of Users with its legal and legitimate business obligations.
