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DATA RETENTION POLICY

 Updated: 4.17.2019

 

1. Introduction  

This  Policy  sets out  the obligations  of Turbo Holdings Inc. ,  a company registered  in the State of New Jersey, whose   registered office is at 2600 Main Street Extension, Sayreville, NJ 08872 USA (“ the Company ”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).


The GDPR defines “personal data” as any information relating to an identified or  identifiable natural person (a “ data subject ”). An identifiable natural person is one who  can be identified, directly or indirectly, in particular by reference to an identifier such  as  a name, an identification number, location data, an online identifier, or to one or  more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.


The   GDPR also addresses “special category” personal data  (also known as  “sensitive”  personal data).  Such data includes,  but is not necessarily limited to, data  concerning the data subject’s race, ethnicity, politics, religion, trade union  membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are  in the public interest, for scientific or historical research, or for statistical purposes  (subject to the implementation of the appropriate technical and organizational  measures required by the GDPR to protect that data). 

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data  subjects have the right to have their personal data erased (and to prevent the  processing of that personal data) in the following circumstances:

  1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
  2. When the data subject withdraws their consent;
  3. When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
  4. When the personal data is processed unlawfully (i.e. in breach of the GDPR);
  5. When the personal data has to be erased to comply with a legal obligation; or
  6. Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the types of personal data held by the Company, the duration of its retention, the criteria for establishing and reviewing the length of such duration and when and how it is to be deleted or otherwise disposed of. For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Privacy Policy.

To contact the Company’s Data Protection officer (the “DPO”), please email info@triplefatgoose.com

 

2. Aims and Objectives

2.1 The primary aim of this Policy is to set out limits for the retention of  personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.

2.2 In addition to safeguarding the rights of data subjects under the  GDPR,  by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

 

3.Scope

3.1 This Policy applies to all personal data held by the Company and by select  third-party data processors processing personal data on the Company’s behalf for the sole purpose of processing and fulfilling requests made by data subjects.


3.2 Personal data, as held by the Company is stored in the following ways  and in the following locations:

    1. The Company’s computers, servers and back-up drives permanently located in the Company’s main place of business at 2600 Main Street Extension, Sayreville, NJ 08872 USA .
    2. Third-party servers, operated by our service providers and located in a number of different locations globally including USA, Denmark, Canada, and Australia.
    3. Laptop computers, tablets, smartphones and any other mobile devices used by the Company’s employees to conduct business for the Company.
    4. Physical records stored in the offices of the Company’s main place of business at 2600 Main Street Extension, Sayreville, NJ 08872 USA .

4. Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of  the GDPR and data subjects’ rights thereunder, as set out in the Company’s Privacy Policy.

4.1 Data subjects are kept fully informed of their rights, of what personal data the  Company holds about them, how that personal data is used as set out in the Company’s Privacy Policy, and how long the Company will hold that personal data (or, if no fixed retention period can  be determined, the criteria by which the retention of the data will be determined).

4.2 Data subjects are entitled to Data Subject Access Request in accordance  with GDPR. The data subject access request entitles the data subject to obtain confirmation that the Company processes their personal data; receive certain information about what we do with that personal data; and receive a copy of the personal data we process.

4.3 Data subjects are given control over their personal data held by the Company  including the right to have incorrect data rectified, the right to request that their personal  data be deleted or otherwise disposed of (notwithstanding  the retention periods otherwise set by this Data Retention Policy), the right  to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision making and profiling, as set out in the Company’s Privacy Policy.

 

5. Technical and Organizational Data Security Measures

5.1 The following technical measures are in place within the Company to p rotect the security of personal data.

    1. All emails containing personal data must be encrypted;
    2. All emails containing personal data must be marked “confidential”;
    3. Personal data may only be transmitted over secure networks;
    4. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
    5. Where personal data is to be sent by facsimile transmission the Recipient should be informed in advance and should be waiting to receive it;
    6. Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure signed for postal or courier service
    7. All personal data transferred physically should be transferred in a suitable container marked “confidential”.
    8. No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Controller.
    9. All hard copies of personal data, along with any electronic copies stored  on physical media should be stored securely;
    10. No personal data may be transferred to any employees, agents,  Contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorization;
    11. Personal data must be handled with care at all times and should  not be left unattended or on view;
    12. Computers used to view personal data must always be locked before being left unattended.
    13. All personal data stored electronically should be backed up routinely with backups stored both on and off site. All backups should be encrypted;
    14. All electronic copies of personal data should be stored securely using passwords and encryption;
    15. All passwords used to protect personal data should be changed regularly and must be secure.
    16. Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords.
    17. All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
    18. No software may be installed on any Company-owned computer or device without approval; and
    19. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Data Protection Officer to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service.

5.2 The following organizational measures are in place within the Company to  protect the security of personal data.

    1. All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Privacy Policy;
    2. Only employees and other parties working on behalf of the Company that needs access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company.
    3. All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
    4. All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised.
    5. All employees and other parties working on behalf of the Company handling personal  data should exercise care  and caution when discussing any work relating to personal data at all times;
    6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
    7. The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
    8. All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Privacy Policy;
    9. All agents, contractors, or other parties working on behalf of  the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Privacy Policy;
    10. Where any agent, contractor or other party working on behalf of the Company handling  personal data fails  in their obligations under the GDPR and/or the Company’s Privacy Policy, that party shall  indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6. Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or  when a data subject exercises their right to have their personal data erased, personal  data shall be deleted, destroyed, or otherwise disposed of as follows:

  1. Personal data stored electronically (including any and all backups thereof) shall be deleted securely and permanently;
  2. Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely and permanently;
  3. Personal data stored in hard copy form shall be cross-cut shredded and properly disposed of.

7. Data Retention

 

7.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the  purpose(s) for which that data is collected, held, and processed.

7.2 Different types of personal data, used for different purposes, will n ecessarily be retained for different periods (and its retention periodically  reviewed), as set out below.

7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

    1. The objectives and requirements of the Company;
    2. The type of personal data in question;
    3. The purpose(s) for which the data in question is collected, held, and processed;
    4. The Company’s legal basis for collecting, holding, and processing that data;
    5. The category or categories of data subject to whom the data relates;

7.4 If a precise retention period cannot be fixed for a particular type of data,  criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

7.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

7.6 In limited circumstances, it may also be necessary to retain personal data for  longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organizational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

 

Appendix – Data Retention Schedule

Data Category

Default Retention Period

Personal Data

Retained whilst organization/individual remains a customer or deleted by user. Once an organization/individual requests all records to be deleted, data will be removed from the back-ups within 9 months.

HR Personal Data

Retained for 7 years; As Required by Law.

Operational Personal Data

Retained whilst organization/individual remains a customer or deleted by user. Once an organization/individual requests all records to be deleted, data will be removed from the back-ups within 9 months.

Metric Personal Data

Retained whilst organization/individual remains a customer or deleted by user. Once an organization/individual requests all records to be deleted, data will be removed from the back-ups within 9 months.

Marketing Personal Data

Retained whilst organization/individual remains a customer or deleted by user. Once an organization/individual requests all records to be deleted, data will be removed from the back-ups within 9 months.

 

 

Additional Terms Related to Retention

The  Company will delete or anonymize data in accordance with the above retention periods, unless:

  1. The Company must keep it to comply with applicable laws or evidence compliance with such applicable laws;
  2. There is an outstanding issue, claim, or dispute requiring the Company to keep such data until the issue, claim or dispute is resolved; or
  3. The data must be kept for the Company’s legitimate business interests, including but not limited to: order fulfillment, fraud prevention and enhancing user’s safety and security.

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