Data Retention & Deletion Policy

1. Purpose

This Data Retention & Deletion Policy (“Policy”) establishes how Gupta Ji Marriage Bureau Pvt. Ltd. (“GMB”, “we”, “us” or “our”) retains, archives, reviews, deletes, anonymises, de-identifies and otherwise manages personal and business information.

GMB is a long-established matchmaking institution whose services may involve relationships with families across multiple generations.

Accordingly, GMB may maintain a long-term institutional and family relationship history so that, where appropriate and lawful, GMB can understand prior family relationships, previous introductions, historical matchmaking work and relevant family connections when the same family or a connected generation approaches GMB in the future.

This Policy is therefore designed around two principles:

• Preservation of legitimate generational relationship history
• Protection against unnecessary indefinite retention of detailed personal information

The fact that GMB is a generational matchmaking business does not mean that every document or every item of personal information must remain identifiable forever.

This Policy operates together with the GMB Privacy Policy / Privacy Notice, GMB Membership & Service Terms and Conditions, and GMB Grievance & Complaint Procedure.

2. Scope

This Policy applies to information held by or on behalf of GMB, including information stored:

• physically;
• electronically;
• in CRM/client-management systems;
• in cloud systems;
• in email;
• in authorised messaging systems;
• in accounting systems;
• in physical files;
• in photographs and videos;
• in archived records;
• in complaint/grievance records;
• in verification records;
• in backups or recovery systems;

It applies to information concerning:

• prospective clients
• members
• former members
• parents and family representatives
• prospective matches and families
• persons introduced through GMB
• website users
• employees and representatives, to the extent relevant
• vendors/service providers
• other persons whose information GMB lawfully receives or processes

3. The GMB Generational Relationship Archive

4. Minimum Necessary Archival Record

Where a family/service relationship has genuine long-term historical value, GMB should prefer retaining the minimum information reasonably necessary to preserve that relationship history.

For example, a long-term archive may reasonably record:

“Family A previously engaged GMB; introduction facilitated between Family A and Family B; alliance subsequently confirmed; relationship date/period recorded.”

It does not automatically require the permanent retention of every piece of information originally supplied during the matchmaking process.

Where reasonably practicable, the following should be moved out of the long-term archival record once no longer necessary for an active purpose:

• identity-document copies;
• Aadhaar or equivalent identification documents;
• passport copies;
• detailed financial documents;
• bank information;
• medical documents;
• detailed health information;
• private correspondence;
• unnecessary telephone history;
• unnecessary residential-address history;
• old passwords or authentication information;
• obsolete payment information;
• other highly sensitive operational material;

5. Data Lifecycle

GMB shall manage information through the following general lifecycle:

1. Collection↓
2. Active Matchmaking / Service Use↓
3. Review / Updating↓
4. Service Closure / Inactivity↓
5. Archive Classification↓
6. Generational Archive / Temporary Retention / Anonymisation / Deletion↓
7. Periodic Review

The ending of a membership does not automatically require destruction of all associated records.

Instead, each category should be assessed according to its continuing purpose.

6. GMB Retention Categories

For operational purposes, GMB shall classify information into the following categories:

7. Retention Schedule

The following is GMB's internal baseline. A different period may apply where required by law, an active contractual obligation, a legal dispute, a legitimate business requirement or the nature of the information.

These periods are GMB policy baselines, not statements that Indian law universally requires or permits each period.

Where applicable law requires a longer period, the legally required period shall prevail.

Where a purpose ends earlier and no lawful or legitimate reason for retention remains, GMB should not retain personal data merely because a maximum internal period has not expired.

8. Generational Archive Versus Active Personal Data

GMB should distinguish between:

The first may have legitimate long-term value.

The second may not.

For example, if GMB assisted a family with a marriage in 2005, GMB may reasonably preserve a historical record of the family relationship and successful introduction for future generations.

That does not necessarily mean GMB needs to preserve the 2005 passport copy, old bank statement, medical document or every historical telephone number.

Where possible:

Historical relationship → preserved.

Unnecessary sensitive detail → removed.

This distinction should be the foundation of GMB's generational archive.

9. Returning Families and Generational Continuity

Where a former client, parent, sibling, child, nephew, niece, cousin or other related family member approaches GMB in the future, authorised GMB personnel may consult the relevant historical archive to understand previous GMB-family relationships and service history.

Such access should be limited to information reasonably relevant to the new service interaction.

Historical information should not automatically be presented to a new family member merely because it exists in GMB's archive.

Where disclosure of historical personal information to another person is not necessary or authorised, it should remain restricted.

10. Family Relationship Data

GMB may maintain limited historical records concerning family relationships where reasonably necessary for the continued operation of its matchmaking services.

Examples may include:

• prior family association with GMB;
• historical introductions;
• previous marriages facilitated by GMB;
• family references;
• family preferences;
• historical relationship context;
• previous service history;
• other relevant matchmaking context;

The existence of a family relationship within GMB's historical records does not automatically authorise GMB to disclose detailed personal information belonging to an individual.

Disclosure shall remain subject to GMB's Privacy Policy, applicable consent and applicable law.

11. Contact Information in the Generational Archive

Current contact information should be maintained separately from historical relationship information wherever practicable.

An old telephone number, email address or residential address should not be preserved indefinitely merely because it once appeared in a client record.

Where GMB needs a current contact method for future service continuity, it should seek updated information when the family re-engages.

12. Research, Training and Institutional Knowledge

GMB may use historical information to improve:

• matchmaking methods;
• staff training;
• operational processes;
• family-service continuity;
• quality assurance;
• internal research;
• service development;
• institutional knowledge;

Where the purpose can reasonably be achieved using aggregated, anonymised or de-identified information, GMB should prefer that approach.

Research and training purposes shall not be used as a blanket justification for indefinite retention of fully identifiable matrimonial biodata.

13. Anonymised or De-Identified Data

GMB may retain appropriately anonymised, aggregated or de-identified information for legitimate research, statistics, service improvement and training.

Examples include:

• aggregate enquiry trends;
• general matchmaking patterns;
• geographical trends;
• broad age-range statistics;
• anonymous case patterns;
• service-performance statistics;
• operational lessons;

Where reasonably practicable, direct identifiers should be removed.

Information that can reasonably be linked back to an identifiable individual should continue to receive appropriate personal-data protections.

14. Marketing, Photographs and Testimonials

GMB may retain records necessary to establish the permission or authorisation obtained for marketing use.

This may include:

• marketing consent;
• media authorisation;
• testimonial approval;
• photograph/video permission;
• company/logo permission;
• records of withdrawal;

If marketing permission is withdrawn, GMB should stop new promotional use within a reasonable operational period, subject to technical limitations and applicable law.

GMB may retain the consent/authorisation record where reasonably necessary to establish the history and scope of the permission granted.

15. Complaints, Disputes and Legal Holds

When GMB receives a complaint, legal notice, demand, dispute, investigation request or other matter that may reasonably result in legal proceedings, relevant information may be placed under a Legal Hold.

A Legal Hold suspends ordinary deletion of information relevant to the matter until retention is no longer reasonably necessary.

A Legal Hold may apply to:

• emails;
• relevant messaging records;
• service records;
• payment records;
• invoices;
• profile information;
• Visit records;
• complaints;
• consent records;
• relevant photographs/videos;
• other reasonably relevant evidence;

A Legal Hold takes precedence over the ordinary deletion schedule to the extent necessary.

16. Restricted-Service / Do-Not-Serve Records

GMB may maintain a confidential restricted-service or do-not-serve record where reasonably necessary to prevent:

• fraud;
• impersonation;
• abuse;
• harassment;
• threats;
• misuse of confidential information;
• harm to staff or property;
• repeated serious misconduct;
• other significant safety, integrity or operational risks;

Because preventing repeated risk may require GMB to recognise an individual or family years later, such records may be retained for an extended period where reasonably necessary.

However, GMB should review such records periodically and remove information that is no longer reasonably necessary.

17. Financial, Tax and Business Records

GMB shall retain invoices, receipts, payment records, Membership Fee records, Visit Charges, Visit Expenses, Alliance/Service Fees and other financial documentation for the period required by applicable tax, accounting, corporate and other law.

Financial records should be maintained separately from the ordinary matrimonial-profile archive where practicable.

The closure of a matrimonial profile does not automatically require deletion of financial records that GMB is legally required to retain.

18. Data Correction and Erasure Requests

A person may submit a request concerning correction, updating or erasure of personal data through the contact mechanism stated in the GMB Privacy Policy.

GMB shall assess such requests against:

• the identity of the requester;
• the information concerned;
• the purpose for which the information is being processed;
• applicable consent;
• continuing service requirements;
• the continuing purpose of the Generational Relationship Archive;
• applicable law;
• legitimate legal/business requirements;
• complaints or disputes;
• any Legal Hold;

Where correction is appropriate, GMB should update the relevant information.

Where erasure is appropriate, GMB should initiate the applicable deletion process.

Where continued retention of limited historical information is necessary for the defined purpose of maintaining family/service continuity or is otherwise required or authorised by law, GMB may retain the relevant information to that extent, subject to applicable legal requirements.

19. Deletion and Archival Transfer

When a membership or service relationship ends, GMB should not automatically delete or automatically retain the entire file.

Instead, the file should be reviewed for possible transfer into:

• Generational Relationship Archive
• Temporary Historical Retention
• Research/Training Dataset
• Legal Hold
• Deletion

Where the relationship has long-term historical value, GMB may preserve the relevant historical information while removing unnecessary detailed documents.

20. Physical Records

Physical records containing personal or confidential information shall be stored in controlled-access locations.

When a physical record becomes eligible for deletion, it should be securely destroyed through shredding or another method reasonably designed to prevent reconstruction.

Confidential matrimonial records should not be disposed of through ordinary public/general waste.

Where the historical relationship record is retained, unnecessary supporting documents may be destroyed while the relevant core archival record is preserved.

21. Electronic Deletion

Where deletion is approved, GMB should identify reasonably accessible copies across:

• CRM/client systems
• email
• cloud storage
• local storage
• shared folders
• marketing repositories
• authorised messaging systems
• other authorised systems

Where historical archive status is selected, only the information reasonably required for that archive should be retained.

22. Backups

Backups are maintained primarily for business continuity, disaster recovery and security.

Deletion from an active system does not necessarily mean that every backup copy can be immediately destroyed.

GMB should maintain a defined backup-rotation process.

Where technically impracticable to delete a record immediately from a backup, it may remain until the normal backup lifecycle expires, provided that it is not restored or used for ordinary processing except where necessary for disaster recovery, security or legal purposes.

23. Access Control

The existence of a long-term archive does not give every employee access to it.

Access shall be based on business necessity and role.

Client-facing staff — information necessary for current service.

Management — broader information where reasonably required.

Finance — financial records required for financial functions.

Marketing — authorised promotional material, not unrestricted access to full matrimonial files.

Archive access — restricted to authorised personnel who require historical records for service continuity, management, legal or other approved purposes.

Access to particularly sensitive records should be more restricted.

24. Employee Responsibilities

Employees and representatives handling GMB information must:

• access information only for legitimate work purposes;
• not retain unnecessary client copies;
• not transfer client information to personal accounts without authorisation;
• not forward confidential biodata to unauthorised persons;
• maintain confidentiality;
• report suspected loss or unauthorised disclosure immediately;
• follow GMB's retention and deletion procedures;
• return or securely dispose of information when instructed;

Employee access should be reviewed when responsibilities change or employment ends.

25. Personal Devices and Unauthorised Copies

Employees should not permanently retain unnecessary matrimonial information on:

• personal phones;
• personal email accounts;
• personal cloud drives;
• USB devices;
• unauthorised messaging accounts;
• other unauthorised storage;

Where a personal device is authorised for work purposes, information should remain subject to GMB's confidentiality, security and deletion controls.

26. Security Incidents

Where personal information is lost, accidentally disclosed, accessed without authorisation, stolen or otherwise compromised, the incident should be reported immediately to the appropriate GMB management/data contact.

GMB should:

• contain the incident
• identify affected systems/data
• preserve relevant evidence
• assess potential impact
• take corrective measures
• make any notification required by applicable law

Relevant incident records should be preserved appropriately.

The 2025 DPDP Rules prescribe specified security safeguards, including access controls, logging/monitoring, backups and other organisational and technical measures, once the applicable provisions come into force.

27. Periodic Archive Review

The Generational Relationship Archive should be reviewed periodically.

The review should ask:

1. Does this record still have genuine family/service-history value?
2. Does GMB reasonably expect that it may be needed for future matchmaking continuity?
3. Are there details that no longer need to be retained?
4. Can sensitive supporting documents be deleted while preserving the historical relationship?
5. Can any part of the record be anonymised or de-identified?
6. Is there a legal hold or other mandatory retention reason?
7. Has the individual exercised an applicable privacy right requiring further review?

The purpose of the review is not to force GMB to destroy legitimate historical family records simply because they are old.

The purpose is to prevent unnecessary personal detail from accumulating indefinitely.

28. Data Retention Register

GMB should maintain an internal Data Retention Register containing:

• Data Category
• Purpose
• Storage Location
• Responsible Department
• Retention Approach
• Legal / Business Basis
• Archive Status
• Deletion Method
• Review Date

For the Generational Relationship Archive, the register should specifically record:

• why the family/service history remains relevant
• what minimum information is retained
• when the next review is due

29. Data Retention Requests and Legal Rights

GMB shall recognise and process applicable privacy rights in accordance with applicable law.

Under Section 12 of the DPDP Act, the right to erasure is subject to retention being necessary for the specified purpose or compliance with law.

Accordingly, a deletion request does not automatically mean that every historical relationship record must be destroyed.

GMB should determine:

• what information the request covers
• what purpose the information continues to serve
• whether the information remains necessary for the Generational Relationship Archive
• whether any law requires retention
• whether a Legal Hold applies
• whether the purpose can be satisfied by retaining less information or an anonymised/de-identified version

Any response should be documented.

30. Purpose-Specific Retention

GMB shall avoid the practice of using one blanket retention period for every category of personal information.

The applicable question is:

Why does GMB still need this information?

Examples:

Future family matchmaking continuity — may justify long-term retention of limited family/service history.

Current matchmaking service — justifies active profile information.

Tax/accounting — justifies required financial records.

Complaint or litigation — may justify Legal Hold.

Fraud prevention — may justify restricted-service records.

Research/training — preferably justifies anonymised or de-identified information.

This purpose-based system is intended to align GMB's retention practice with the principle that personal data should remain only while required for the relevant purpose or applicable legal requirement. The 2025 Rules similarly state that personal data should be retained until required for the relevant use or compliance with law.

31. Changes in Law

This Policy shall be reviewed whenever there is a material change to applicable privacy, data-protection, consumer, tax, corporate, technology or other relevant law.

The DPDP Rules, 2025 were notified with phased commencement: Rules 1, 2 and 17–21 took effect upon publication; Rule 4 takes effect after one year; and Rules 3, 5–16, 22 and 23 take effect 18 months after publication.

GMB shall update this Policy and its operational procedures as the applicable provisions become operative.

32. Responsibility for This Policy

GMB management shall designate appropriate persons responsible for implementing this Policy.

Operational responsibility may be distributed among:

Client / Operations Team — active client records and service files;

PR / Marketing Team — marketing and media records;

Finance / Accounts — financial and tax records;

Management — generational archive, complaints, legal holds and restricted-service records;

IT / authorised technical support — system access, backups, deletion support and technical security; and

Privacy/Data Contact — privacy requests, retention questions and data-protection coordination.

No employee should independently create a new retention category for personal data without management approval.

33. Annual Policy Review

At least annually, GMB should review:

• the Generational Relationship Archive;
• unnecessary sensitive information;
• old detailed biodata;
• employee access;
• restricted-service records;
• complaint/legal records;
• research datasets;
• marketing permissions;
• third-party data storage;
• changes in applicable law;

The annual review should focus on retaining the institutional value while reducing unnecessary personal-data exposure.

34. Document Control

Document Name

GMB Data Retention & Deletion Policy

Company

Gupta Ji Marriage Bureau Pvt. Ltd.

Version

[Version Number]

Effective Date

[Date]

Approved By

[Director / Authorised Officer]

Next Review Date

[Date]

35. Contact for Data-Related Requests