Data Retention and Deletion Policy

This document is provided in English and Georgian. In case of discrepancy, the English version shall prevail.

Document: Data Retention & Deletion Policy
Version: 1.1
Effective Date: 15 October 2026
Last Updated: 15 October 2026
Operated by: Nixyum LLC · Reg. No. 400458045
Address: Tbilisi, 13 Nikoloz Janashia Street, Georgia
Governing Law: Georgia

1. Introduction and Purpose

This Data Retention & Deletion Policy ("Policy") sets out the legal framework governing how long Nixyum retains Personal Data, how data is deleted or anonymised when it is no longer required, and the rights of Data Subjects in relation to the retention and deletion of their Personal Data.

This Policy gives effect to the storage limitation, data minimisation, and integrity and confidentiality principles of the Georgian Data Protection Law and, by harmonisation, the GDPR. Nixyum retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Capitalised terms used in this Policy have the meanings assigned in the Master Definitions.

This Policy operates in conjunction with:

The Data Retention Schedule — which sets out the specific retention periods, legal bases, deletion methods, and extension triggers for each category of Personal Data. The Schedule is the authoritative reference for all specific retention periods and is incorporated by reference into this Policy.
The Privacy Policy — which sets out the purposes and legal bases for processing.
The Master Definitions — which defines all capitalised terms used herein.

2. Scope

This Policy applies to all Personal Data processed by Nixyum as Data Controller in connection with the Platform, including data relating to Users and to other individuals whose Personal Data Nixyum processes, such as people who contact Nixyum or report Content. It applies during the Beta Period and remains in full force following general availability.

3. Data Protection Principles Governing Retention

The following principles govern all retention and deletion decisions made by Nixyum:

Storage Limitation: Personal Data is kept in a form that permits identification of Data Subjects for no longer than is necessary for the purposes for which the data is processed. Once those purposes have been fulfilled and no exception applies, the data shall be deleted or irreversibly anonymised.
Purpose Limitation: Personal Data collected for a specific purpose shall not be retained and used for a different, incompatible purpose. Where a new purpose arises, it must be assessed for compatibility or a new legal basis established.
Data Minimisation: Nixyum shall not retain more Personal Data than is necessary for the stated purpose. As data ages beyond its immediate operational need, it shall be progressively anonymised or deleted.
Integrity and Confidentiality: Personal Data that is retained shall be protected by appropriate technical and organisational measures throughout the retention period. Security of retained data is not diminished as data approaches its deletion date.
Accountability: Nixyum maintains the Data Retention Schedule as its documented record of retention periods and the legal bases for extended retention, enabling demonstration of compliance with the Georgian Data Protection Law on request.

4. Retention Periods

The specific retention period applicable to each category of Personal Data processed by Nixyum — including account data, User Content, technical logs, moderation records, commercial data, and legal compliance records — is set out in the Data Retention Schedule.

All retention periods in the Data Retention Schedule represent the maximum period for which Personal Data is held in identifiable form for the stated purpose. Personal Data that is no longer required for its stated purpose shall be deleted or irreversibly anonymised at the end of the applicable retention period, unless an extended retention trigger applies under Section 8 of this Policy.

Retention periods are reviewed when Nixyum introduces a new processing activity, when the purpose for an existing activity changes, or when there is a change in applicable law. Any material change to a retention period will be reflected in an updated Data Retention Schedule and communicated to Users in accordance with Section 15.

5. Deletion and Anonymisation Standards

5.1 Definition of Deletion

"Deletion" means the permanent and irreversible removal of Personal Data from all systems operated or controlled by Nixyum, effected through the following steps:

Step 1: the data is immediately made inaccessible to other Users and to Platform functions.
Step 2: the data is permanently erased from the active databases and storage within thirty (30) days of the deletion. Data that is under review or needed for a legal claim is erased when that ends (Section 8); Content a Moderator removed is kept as evidence, as the Data Retention Schedule sets out. For a photo, video or voice message, the file itself is erased, and a short technical record that it existed is kept (which Persona uploaded it, when, its type and size, where it was stored, and a fingerprint of the file).
Step 3: copies in encrypted backups are overwritten as the backups rotate, within ninety (90) days at most (Section 9).
Step 4: copies of media held on content delivery network (CDN) servers are removed when the file itself is erased (Step 2); until then, a deleted file may remain reachable by anyone who already has its direct address.

Deleted data cannot be recovered through normal operational means once these steps are complete. If a system ever has to be restored from a backup, every Account deletion carried out after that backup was taken is carried out again, using a record of deletions that Nixyum keeps separately from the data itself.

5.2 Definition of Anonymisation

"Anonymisation" means the irreversible transformation of Personal Data such that the Data Subject can no longer be identified, directly or indirectly, by any means reasonably available to Nixyum or to any third party. Anonymised data is no longer Personal Data under the Georgian Data Protection Law and is not subject to data protection obligations or the retention limits in this Policy.

Before Nixyum treats any data as anonymised for the purpose of indefinite retention, the following conditions must be satisfied:

All direct identifiers (name, email, username, account ID, device ID) have been removed or replaced with non-reversible randomised values.
All quasi-identifiers that could, in combination, identify an individual have been generalised, suppressed, or aggregated.
The anonymisation process has been verified to be irreversible by means of a documented technical assessment. If there is any reasonable prospect of re-identification, the data is treated as pseudonymous Personal Data and remains subject to this Policy.

6. Account Deletion — User-Initiated

6.1 How to Delete an Account

Users may initiate account deletion at any time through the account settings within the Platform, or by submitting a written deletion request to [email protected]. Nixyum will verify the request to confirm the identity of the requesting User before proceeding.

6.2 What Happens on Account Deletion

When a User asks to delete their Account, the deletion is scheduled for seven (7) days later. Until then the User can cancel it in Settings or with the link in the email Nixyum sends to confirm the request; that email also lists the data Nixyum must keep and why (Section 6.3). The User stays signed in during the seven days. When they have passed, Nixyum carries out the following:

Account Registration Data (email, username, password hash, date of birth): deleted or anonymised.
Nex and Nyx profiles (display names, profile photos, biographies, follower lists): removed from the Platform; copies in backups overwritten within 90 days.
The internal link between the Account and its Nyx: removed thirty (30) days after the deletion, unless a pending legal request or a legal hold requires it to be kept for longer (Privacy Policy §6.3).
User Content (posts, comments, stories, media): removed from the Platform and erased; copies in backups overwritten within 90 days.
Direct Messages: messages the User sent stay with their recipients, shown as from a "Deleted user"; the recipients keep their copies. A conversation that every participant has deleted is erased within thirty (30) days after the last of them deleted it (unless it has been reported or is under review, or a legal hold applies), and from backups within 90 days.
Analytics identifiers: deleted or anonymised.
All sessions: ended, on every device.

Nixyum emails the User when the deletion is complete.

6.3 Data That May Be Retained After Account Deletion

The following categories of data may be retained after account deletion, subject to the grounds and periods set out in the Data Retention Schedule:

Moderation and abuse records: reports are deleted 12 months after the case closes, and the case file (Moderators' decisions, the Enforcement Actions taken and appeals) 2 years after the final decision, or later while an Enforcement Action from it is still in force, as set out in the Data Retention Schedule.
CSAM evidence: where child sexual abuse material (CSAM) was detected, the material itself, sealed and with strictly restricted access, is kept together with its detection record and the NCMEC report reference for the period set out in the Data Retention Schedule, whatever happens to the Account (see REPORT Act in the Master Definitions, and the Content Moderation & Takedown Policy §12.2).
Ban enforcement: a one-way coded form of the email address of a permanently banned Account, for the period set out in Section 8.4, on the basis of Legitimate Interest (platform safety). Deletion requests may be refused for this category on the same basis.
Transaction and payment records: retained for a minimum of 5 years in compliance with the Georgian Tax Code.
Data subject request records: retained for 5 years from closure to demonstrate compliance with statutory obligations under the Georgian Data Protection Law.
Legal compliance and court order records: retained until the relevant obligation is discharged plus the applicable limitation period.
Data breach records: retained for 5 years.
Consent records: the server-side record of each cookie choice is kept 3 years from that record, to show that consent was given, as set out in the Data Retention Schedule.

The email confirming a deletion request lists the categories of data Nixyum must keep, the reason, and how long each is kept.

6.4 Deletion Is Permanent

Once the seven-day cancellation period has passed, deletion is permanent: the Account cannot be restored, and its Content and data cannot be recovered. Nixyum does not offer a way to pause an Account. A User who wants a break can simply sign out; their Account and Content stay as they are.

7. Account Deletion — Nixyum-Initiated

7.1 Permanent Enforcement Termination

Where Nixyum permanently terminates an Account for a serious violation of the Terms of Service or the Community Guidelines, the Account and its Content are deleted as described in Section 6.2 once the thirty (30) days for appealing have passed and no appeal is still being considered; an appeal that succeeds cancels the deletion. The retention exceptions in Section 6.3 and the extended retention triggers in Section 8 apply. The one-way coded email address is kept to prevent re-registration (Section 8.4).

7.2 Inactivity-Based Deletion

An Account that has recorded no login, no Content submission, no interaction, and no verified communication with Nixyum for a continuous period of twenty-four (24) months is inactive, as defined in the Master Definitions (Inactivity Period). After the Inactivity Period, Nixyum will delete the Account as follows, unless the Account is suspended or must be kept under Section 8:

Step 1: Nixyum emails the User's registered address that it intends to delete the Account, and gives the User thirty (30) days to sign in or otherwise reply to prevent the deletion.
Step 2: if there is no response within those 30 days, the Account is deleted as described in Section 6.2.

Nixyum will make reasonable efforts to deliver the inactivity notice. If the User's registered email address is no longer active, Nixyum will proceed with deletion after the 30-day period without further notice. An Account whose email address was never confirmed cannot be sent the notice; it is deleted at the end of the Inactivity Period without one.

7.3 Deletion of Underage User Data

Where a User tells Nixyum that they are under 18 (a Minor), or a Moderator concludes from evidence that they are, Nixyum:

Blocks the Account at once: its sessions end and its Content is hidden from other Users, but nothing is deleted yet.
Emails the account holder to explain what happened.
If the account holder tells Nixyum within thirty (30) days that this is a mistake, has a member of staff weigh what they say against what led to the block, and decide. Nixyum never asks for an identity document; one sent anyway is used only for that decision and then deleted.
If there is no reply, or the review confirms the person is under 18, deletes the Account as described in Section 6.2, subject only to mandatory legal retention obligations.
Keeps no identifier beyond a one-way coded form of the email address, used only to prevent the same person registering again before they turn 18, and for at most 5 years.
Never deletes an Account on an automated signal alone.

8. Extended Retention — Triggers and Limits

The following circumstances may extend any standard retention period beyond the period specified in the Data Retention Schedule. All extensions must be documented, proportionate to the purpose, and reviewed regularly.

8.1 Legal Obligation

Where Georgian law, Georgian Tax Code, Georgian Electronic Communications Law, or any other applicable statute or binding regulatory direction mandates retention of specific data for a defined period, Nixyum will retain the data for the statutory period. The statutory period prevails over the standard retention period in the Data Retention Schedule.

8.2 Legal Hold

Where Nixyum receives a valid court order, law enforcement request, or regulatory direction requiring preservation of specific data, Nixyum will suspend deletion of that data with immediate effect, including any deletion the User starts in Settings. The legal hold will remain in place until formally lifted by the ordering authority. Nixyum documents all active legal holds internally. Data subject deletion requests will be refused for data subject to a legal hold, and the User will be told so, unless the authority requires confidentiality or telling them could harm an investigation.

8.3 Active Litigation or Dispute

Where Nixyum is aware of potential or active legal proceedings in which specific data is likely to be required as evidence, Nixyum may retain that data beyond its standard period until the proceedings are resolved and any applicable limitation period has expired. Nixyum will minimise the scope of data retained under this trigger to what is reasonably necessary for the specific proceedings.

8.4 Ban Enforcement and Platform Safety

When an Account is permanently banned, a one-way coded form of its email address and a code for the reason are kept after the Account is deleted, on the basis of Legitimate Interest (preventing re-registration and protecting the Platform). How long they are kept depends on how serious the violation was, as set out in the Data Retention Schedule; for an Account deleted under Section 7.3 because its holder is a Minor, only until they turn 18, and for at most 5 years. Data subject erasure requests may be refused on this basis. No Content is kept under this trigger, only the coded identifier.

8.5 CSAM Compliance

Where CSAM is detected, Nixyum preserves the material as sealed evidence, to which access is strictly restricted, together with its detection record and the NCMEC CyberTipline report reference, for the period set out in the Data Retention Schedule. That period is not shorter than the minimum periods set by applicable law (see REPORT Act in the Master Definitions), as the Content Moderation & Takedown Policy §12.2 describes. Data subject erasure requests cannot shorten it.

8.6 Dispute Resolution at User Request

A User may request temporary preservation of their own data beyond the standard period — for example, where the User has initiated or anticipates initiating a legal claim and requires data for that purpose. Nixyum will accommodate reasonable preservation requests for up to ninety (90) days on written request to [email protected], subject to Nixyum's own legal position not being adversely affected.

9. Backup and Disaster Recovery

Nixyum maintains encrypted rolling backups of all live databases and Content storage for disaster recovery purposes. No backup or protected copy is kept for more than ninety (90) days. Backups are stored in data centres in the EU and are subject to the same access controls as live data.

Backups are used exclusively for disaster recovery. They are not used to restore deleted User data in normal operational circumstances. Deleted data that is present in a backup snapshot will be purged at the next backup rotation after the scheduled deletion date, or within 90 days of deletion at the latest.

If Nixyum ever restores a system from a backup, it carries out again every Account deletion made after that backup was taken, using the separate record of deletions described in Section 5.1. If Nixyum becomes aware that a restoration has brought back any other data that had been deleted, it will delete that data again and tell the affected Users within thirty (30) days.

10. User Content Deletion

Users may delete their own Content at any time through the Platform's interface, subject to any restrictions arising from an active Enforcement Action or legal hold. Content deleted by a User is:

Removed from the Platform and made inaccessible to other Users immediately upon deletion.
Erased within thirty (30) days, unless it is under review, a Moderator removed it, or it is needed for a legal claim (Section 8); for a photo or video, a short technical record that it existed is kept (Section 5.1).
Overwritten in backups within 90 days.
Copies on CDN servers are removed when the file itself is erased; until then, a deleted file may remain reachable by anyone who already has its direct address.

Where Content has been reshared, embedded, or quoted by another User, Nixyum will remove the original Content upon deletion. Derivative works by other Users that reference deleted Content — including quotations and text references — may persist in those Users' own posts and are governed by those Users' own data rights. Nixyum does not retroactively scan all User Content to remove textual references to a deleted User's username. Where such references constitute a privacy violation, they may be reported in accordance with the Community Guidelines.

Content removed by Nixyum pursuant to an Enforcement Action is retained internally for up to 12 months as evidence, as set out in the Data Retention Schedule. Users may not delete such content through normal Platform means while it is subject to Enforcement Action.

11. Post-Deletion Residuals

The following residual effects of deleted data are acknowledged:

Backup copies: Deleted data persists in encrypted backup snapshots for up to 90 days. It is inaccessible during this period and will be purged at the next rotation.
CDN caches: Media content may persist in CDN edge caches after deletion until the file itself is erased (Section 5.1), when those copies are removed too. It is not accessible through Nixyum interfaces during this period, but may remain reachable by anyone who already has its direct address.
Third-party caches: Public Content that was indexed by third-party search engines or cached by external services prior to deletion may continue to appear in those services until those caches are updated. Nixyum does not control third-party caches. Users may request removal from external caches directly through the relevant service's removal tools.
Recipients of direct messages: Messages a User sent, including photos, videos and voice messages, stay with their recipients after the sender deletes their Account, shown as from a "Deleted user". Nixyum does not delete message content from recipients' views as doing so would infringe the recipient's own data rights.
Aggregated data: Anonymised aggregates derived from a User's data (e.g., usage statistics) may persist indefinitely. As they are irreversibly anonymised, they are no longer Personal Data.
Anonymised contributions: Where Nixyum retains Content in anonymised form after account deletion (e.g., removing personal attribution while retaining the content in an anonymised form), the anonymised content does not constitute Personal Data and is not subject to further deletion.

12. Special Categories and Minors

12.1 Special Category Data

Nixyum does not proactively collect Special Category Data. Where Special Category Data is voluntarily disclosed by a User in their Content or profile, it is processed and retained under the same principles as other User Content. The retention period applicable to the Content category in which the Special Category Data appears governs its retention. Nixyum does not use Special Category Data for any purpose beyond displaying the Content in which it appears and moderating that Content in accordance with the Community Guidelines.

12.2 Data Relating to Minor Users

Minors (any individual under 18) are not permitted to register an Account or use the Platform. Nixyum does not knowingly process the Personal Data of Minors. Where a User is found to be a Minor, the Account is blocked and, unless a review finds it was a mistake, deleted as described in Section 7.3, subject only to the minimal retention needed to prevent re-registration or to comply with a legal obligation.

13. Data Subject Rights in Relation to Retention

13.1 Right to Erasure (Right to be Forgotten)

Data Subjects have the right under the Georgian Data Protection Law to request the erasure of their Personal Data. Nixyum will comply with a valid erasure request where:

The Personal Data is no longer necessary for the purpose for which it was collected.
The Data Subject withdraws consent on which processing is based and there is no other legal basis for processing.
The Data Subject objects to processing based on Legitimate Interest and Nixyum's legitimate grounds do not override the Data Subject's rights.
The Personal Data has been unlawfully processed.
The Personal Data must be erased to comply with a legal obligation.

Erasure requests may be refused, in whole or in part, where retention is necessary for: compliance with a legal obligation (including CSAM-related preservation under Section 8.5); the establishment, exercise, or defence of legal claims; or a legitimate interest that overrides the Data Subject's rights (specifically, ban enforcement as described in Section 8.4).

13.2 Right to Restriction

Where a Data Subject disputes the accuracy of Personal Data, objects to its erasure pending verification, or has objected to processing on Legitimate Interest grounds and the objection has not yet been resolved, the Data Subject may request that processing be restricted to storage only. Nixyum will comply with a valid restriction request and will notify the Data Subject before lifting any restriction.

13.3 How to Submit a Request

Requests relating to retention and deletion, including erasure, restriction and access requests, can be sent to [email protected]; an Account can also be deleted in Settings (Section 6.1). Nixyum will verify the identity of the requesting party before processing any request affecting Personal Data, and will respond within the timelines set out in the Master Definitions and the Privacy Policy.

13.4 Right to Lodge a Complaint with the Supervisory Authority

Data Subjects who believe that Nixyum has failed to comply with its data retention and deletion obligations under the Georgian Data Protection Law have the right to lodge a complaint with the State Audit Office of Georgia (SAO) — the supervisory authority for personal data protection in Georgia — through its dedicated portal at pdp.sao.ge. Nixyum requests that Data Subjects contact [email protected] in the first instance to allow Nixyum to address the concern directly.

14. Data Breach Notification

In the event of a Personal Data breach — meaning a security incident resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, Personal Data processed by or on behalf of Nixyum — Nixyum will:

Within 72 hours: Notify the Supervisory Authority of the breach where it is likely to result in a risk to the rights and freedoms of natural persons, in accordance with the Georgian Data Protection Law. The notification will include: the nature of the breach; the categories and approximate number of Data Subjects and Personal Data records affected; the likely consequences of the breach; and the measures taken or proposed to address the breach.
Without undue delay: Notify affected Data Subjects directly where the breach is likely to result in a high risk to their rights and freedoms, unless an exemption applies (for example, where subsequent protective measures have rendered the risk to Data Subjects unlikely to materialise).
Ongoing: Document all breaches in Nixyum's internal Data Breach Records, regardless of whether notification is required. Breach records are retained for 5 years in accordance with the Data Retention Schedule.

Breach notifications to Data Subjects will be communicated via the User's registered email address and, where appropriate, via in-Platform notification. Notifications will describe the nature of the breach, the categories of data affected, the likely consequences, and the steps Nixyum has taken to address and mitigate the breach.

15. Changes to This Policy

Nixyum may update this Policy and the Data Retention Schedule from time to time to reflect changes in law, processing activities, or operational practice. Material changes will be communicated to Users at least thirty (30) days before the change takes effect, via the Platform or by email, except where a shorter period is required by law or is necessary for reasons of security or regulatory compliance. The "Last Updated" date reflects the most recent revision. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

16. Contact

Privacy & Data Protection / Deletion Requests: [email protected]
Support: [email protected]
Legal: [email protected]
Data Controller: Nixyum LLC · Reg. No. 400458045 · Tbilisi, 13 Nikoloz Janashia Street, Georgia
Supervisory Authority: State Audit Office of Georgia (SAO) · pdp.sao.ge