1. Introduction

This Data Retention & Secure Disposal Policy explains how PROCEKA TechSol Private Limited (“PROCEKA”, “we”, “us”) manages information throughout its lifecycle — from collection through to secure disposal. It is a governance policy, consistent with our Privacy Policy, Information Security Policy, AI Usage & Responsible AI Policy, Service Engagement Terms & Conditions, and Website Terms & Conditions.

2. Purpose

This Policy establishes governance for how long different categories of information are retained, and how information is securely disposed of once retention is no longer necessary, in order to support legal compliance, protect confidential information, and avoid unnecessary retention.

3. Scope

This Policy applies to information PROCEKA holds in connection with the Website, client engagements, internal operations, and any future digital platform we introduce, whether held in physical or digital form.

4. Definitions

“Retention” means the period during which information is kept. “Secure Disposal” means the permanent deletion, destruction, or anonymisation of information such that it can no longer reasonably be reconstructed or attributed to an individual or matter. “Legal Hold” means a temporary suspension of scheduled disposal due to actual or reasonably anticipated legal proceedings or investigation.

5. Data Lifecycle

Information at PROCEKA generally moves through the following stages: collection, active use, storage while still relevant, review for continued necessity, and, eventually, secure disposal or, where required, long-term archival for legal or regulatory purposes.

6. Information Categories

Retention considerations vary by category of information, including client information, financial and accounting records, tax records, consultation and enquiry records, email communications, payment information, uploaded documents, and system-generated records, each addressed in the sections below.

7. Client Information

Client information collected in connection with an engagement is retained for as long as necessary to deliver the engagement, meet applicable professional and regulatory recordkeeping obligations relevant to that service, resolve any dispute, and support legitimate follow-on business needs.

8. Employee Information

Where applicable, information relating to PROCEKA personnel is retained in accordance with applicable Indian labour, tax, and social security recordkeeping requirements, and our own legitimate HR administration needs.

9. Financial Records

PROCEKA’s own financial records, including invoicing and payment records, are retained in accordance with applicable Indian accounting and tax recordkeeping requirements, which generally require retention for a defined number of years after the relevant financial year.

10. Accounting Records

Accounting records prepared for clients as part of an engagement are retained for the period required by the applicable professional and statutory obligations relevant to that specific service, as set out in the Engagement Documentation where specified.

11. Tax Records

Tax-related records, both our own and those prepared for clients, are retained in accordance with the retention periods prescribed under applicable Indian tax law, which vary depending on the specific tax and type of record involved.

12. Consultation Records

Records of consultation bookings, including the information submitted through our Book Consultation form, are retained for a period reasonably necessary to support the resulting engagement (if any), our own business records, and service improvement, and are reviewed periodically for continued relevance.

13. Website Enquiries

General enquiries submitted through the Website are retained for a reasonable period to allow us to respond and follow up, after which they are reviewed and retained only if reasonably necessary for an ongoing matter or legitimate business record.

14. Email Communications

Email correspondence relating to a client engagement is retained consistent with the retention applicable to that engagement under Section 7. General business email is retained for a reasonable period based on operational need and is periodically reviewed.

15. Payment Information

As described in our Privacy Policy, PROCEKA does not directly store full card or banking credentials, which are processed by PayU. We retain transaction reference and payment confirmation information for the period required by applicable accounting and tax recordkeeping obligations.

16. AI-Generated Records

Where AI-assisted tools are used, as described in our AI Usage & Responsible AI Policy, any resulting draft or output that is incorporated into a final client deliverable is retained consistent with the retention applicable to that deliverable. Intermediate AI-generated drafts not incorporated into final work product are not retained for longer than reasonably necessary for the immediate task.

17. Uploaded Documents

Documents you share with us are retained for as long as necessary to deliver the relevant service and meet applicable recordkeeping obligations, after which they are securely disposed of in accordance with Section 24, subject to any applicable legal hold.

18. Download Records

Records of resources downloaded from the Website (where tracked) are retained only for a limited period for aggregate analytics purposes, consistent with our Cookie Policy, and are not used to build detailed individual download profiles beyond that purpose.

19. System Logs

Technical system logs, including security-related logs generated by tools such as Wordfence, are retained for a period reasonably necessary to support security monitoring and incident investigation, after which they are rotated or deleted in the ordinary course.

20. Backup Data

Website backups, maintained via UpdraftPlus, are retained on a rolling basis to support disaster recovery, with older backups periodically overwritten as part of normal backup rotation, consistent with Section 10 of our Information Security Policy.

21. Archived Information

Where information must be retained long-term for legal, regulatory, or significant business reasons, it may be moved to archival storage with more limited access than actively used information, while remaining subject to the same security principles described in our Information Security Policy.

22. Legal Hold

Where information is relevant to actual or reasonably anticipated legal proceedings, a regulatory inquiry, or a dispute, scheduled disposal of that information is suspended until the matter is resolved, notwithstanding the general retention considerations described elsewhere in this Policy.

23. Secure Storage

Information is stored using reasonable technical and organisational measures appropriate to its sensitivity, consistent with our Information Security Policy, for as long as it is retained.

24. Secure Disposal

When information is no longer required to be retained, we take reasonable steps to securely delete, destroy, or anonymise it using methods appropriate to its format and sensitivity, such that it cannot reasonably be reconstructed or attributed to an individual or matter.

25. Electronic Disposal

Electronic information is disposed of through secure deletion appropriate to the system involved, recognising that some residual data may persist temporarily in backups until the ordinary backup rotation cycle described in Section 20 removes it.

26. Physical Disposal

Where PROCEKA holds physical documents containing confidential or personal information, disposal is carried out using methods that prevent reconstruction of the information, such as secure shredding, appropriate to the sensitivity of the material.

27. Third-Party Service Providers

Where third-party service providers hold information on our behalf (such as our hosting or payment gateway provider), their retention and disposal practices are governed by their own policies in addition to the instructions we provide, consistent with Section 17 of our Privacy Policy.

28. Record Retention Reviews

We periodically review categories of information we hold to assess whether continued retention remains necessary, and to identify information that should be disposed of or archived.

29. Exceptions

Exceptions to standard retention practice — such as extended retention for a specific legal or business reason, or accelerated disposal at a client’s reasonable request, subject to our own legal obligations — are considered on a case-by-case basis by company management.

30. Responsibilities

PROCEKA personnel handling client or confidential information are responsible for following this Policy in their day-to-day work, avoiding both excessive retention and premature disposal, and escalating uncertain cases to management for guidance.

31. Policy Monitoring

We monitor adherence to this Policy as part of our broader information governance practices, and address any identified gaps, such as accidental over-retention or premature disposal, as they are found.

32. Policy Review

This Policy is reviewed periodically and updated as necessary to reflect changes in our business, the categories of information we hold, applicable law, and evolving best practice, particularly as we introduce future digital platforms such as a client portal, professional portal, marketplace, AI platform, or document management system.

33. Contact Information

PROCEKA TechSol Private Limited
Rajabandha, Ghatgaon, Keonjhar, Odisha, India
Email: info@proceka.com
Phone: +91 91785 66135

34. Effective Date

This Data Retention & Secure Disposal Policy is effective as of 24 July 2026.