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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
August 2026 · Version 1.0 · Adopted by the Board · Last updated 28 October 2026 · The applicable version is always the current one · Board minutes No. 26.17-0803.1 of 3 August 2026

Data Retention Schedule

1. Purpose

This schedule sets out how long the Company keeps the categories of personal data it processes, in accordance with the storage-limitation principle of Article 5(1)(e) UK GDPR, EU GDPR and the Swiss revFADP. After the period ends, data is deleted or irreversibly anonymised.

2. Schedule

CategoryPeriodReason
Partnership, supplier and general enquiries (no relationship follows)24 months from the last contactLegitimate interests; follow-up of the enquiry
Press enquiries24 months from the last contactLegitimate interests
Contracts, NDAs and related correspondence6 years after the end of the contractLimitation Act 1980
Customer due diligence and sanctions screening records5 years after the end of the relationshipMoney Laundering Regulations 2017, reg. 40
Data protection requests and complaints, and the Company’s response6 yearsRecord of compliance; Limitation Act 1980
Whistleblowing disclosures6 years after the matter is closedLegitimate interests; legal claims
Job applicants (unsuccessful)6 months after the decisionEquality Act 2010 claims period
Speculative applications12 months from receiptLegitimate interests (considering the applicant for a future role)
Publication subscribers (email address and optional details)Until consent is withdrawnConsent
Publication subscribers: consent and withdrawal records2 years after withdrawalDemonstrating consent (UK GDPR Art. 7(1)); legal claims
Cookie choices and country selection (stored in the visitor’s browser only)13 months from the last choice; no copy is kept by the CompanyDemonstrating consent (UK GDPR Art. 7(1)); strictly necessary storage (PECR reg. 6(4))
Website security logs90 daysSecurity of the website
Published leadership profiles and consentsWhile the role is held; consent kept 6 years after removalConsent; legal claims

3. Legal holds

Where data is needed for actual or reasonably expected legal proceedings, or a regulator requires it to be kept, deletion is suspended until the matter is concluded.

4. Review

The Board reviews this schedule at least annually.

Related documents: Privacy and Cookie Policy · Business Continuity Statement

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