Last updated: June 2026
Xertilox Ltd (“Xertilox”, “we”, “us”, “our”) is committed to protecting the personal data we process and ensuring compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Digital Identity and Attributes Trust Framework (DIATF).
This policy defines how long personal data is retained when collected and processed through the Xertilox mobile application and associated systems. It ensures that:
This policy applies to all personal data processed via the Xertilox mobile app and supporting systems, including:
This policy covers all Xertilox staff, contractors, and authorised third-party processors who handle mobile app data.
This policy has been designed to comply with:
Key principles derived from these frameworks:
| Data category | Purpose | Retention period | Disposal method |
|---|---|---|---|
| Wallet holder personal data (name, email, phone, etc.) | Creation and maintenance of user identity. | Active account: retained for the duration of wallet use. Inactive or deleted account: retained for 12 months to meet regulatory obligations. | Secure deletion from all systems. |
| Document verification data (passport, driving licence, etc.) | Verify authenticity of identity. | Retained for 90 days post-verification, then securely deleted unless required for ongoing compliance investigations. | Encrypted purge from verification system. |
| Biometric data (facial recognition scans) | Liveness detection and identity matching. | Retained for 24 hours post-verification, then deleted. | Secure deletion and cache clearance. |
| Device and session data | Security monitoring and fraud prevention. | Retained for 12 months from collection. | Automatic log expiry and secure deletion. |
| Transactional data and audit logs | To evidence DIATF-compliant verification activities. | Retained for 7 years as required by DIATF audit requirements. | Encrypted archival; deletion after expiry. |
At the end of its retention period, personal data collected via the Xertilox mobile app will be securely disposed of in accordance with guidance from the UK National Cyber Security Centre (NCSC) and NIST SP 800-88 Rev.1 standards. Depending on the storage medium, one or more of the following techniques will be used:
Where data is processed by authorised third-party processors, they must provide written confirmation that secure deletion has been completed in line with NCSC guidance and DIATF compliance requirements.
Under the UK GDPR, users of the Xertilox mobile app have the following rights regarding data retention:
Requests should be submitted to privacy@xertilox.com.
This policy will be reviewed annually, or sooner if required by changes in:
If you have any questions about this Data Retention Policy, you can contact us at: