Data Retention Schedule

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

Document: Data Retention Schedule
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
Related Policies: Data Retention & Deletion Policy; Privacy Policy; Cookies Policy; Content Moderation & Takedown Policy; Master Definitions

1. Purpose

This Data Retention Schedule sets out the specific retention periods applicable to each category of Personal Data processed by Nixyum on the Platform. It supplements the Data Retention & Deletion Policy and the Privacy Policy, which provide the broader legal framework and principles. Capitalised terms used in this Schedule have the meanings assigned in the Master Definitions.

Retention periods are the maximum periods for which Personal Data is held in identifiable form for the stated purpose. Data shall be deleted or irreversibly anonymised upon expiry of the applicable retention period, subject only to the extended retention triggers noted in each row, set out in Section 3 and described further in the Data Retention & Deletion Policy.

Where a row counts from the deletion of an Account, it counts from the moment the deletion takes effect: seven (7) days after the User asks for it, unless the User cancels it in the meantime (Data Retention & Deletion Policy §6.2).

This Schedule applies during the Beta Period and will be reviewed upon general availability.

2. Retention Schedule

The rows below set out every category of Personal Data processed by Nixyum, its retention period, legal basis, method of disposal, and any triggers that may extend retention beyond the standard period.

A — Account Identity Data

Account Registration Data

Email address, username, password hash, date of birth, and the dates, settings and policy acceptances recorded on the Account

Retention Period: Account life + 30 days
Legal Basis: Contract; Legal Obligation
Deletion / Disposal: Secure deletion or anonymisation within 30 days of the deletion taking effect; copies in backups overwritten within 90 days
Notes & Extended Retention Triggers: Only a one-way coded form of the email address is kept beyond 30 days, and only to enforce a permanent ban (row D4) or under a legal hold (Section 3). Nothing else recorded on the Account is kept.

Nex Profile

Display name, profile photo, biography, follower and following lists, profile settings

Retention Period: Account life + 30 days
Legal Basis: Contract; Consent
Deletion / Disposal: Removed from the Platform when the deletion takes effect; copies in backups overwritten within 90 days
Notes & Extended Retention Triggers: Copies of media on content delivery network (CDN) servers are removed when the files themselves are erased; until then, a deleted file may remain reachable by anyone who already has its direct address.

Nyx Profile

Display name, avatar, biography, follower and following lists, profile settings. The link between the Nyx and the Account is a separate record (row B3).

Retention Period: Account life + 30 days
Legal Basis: Contract; Legitimate Interest
Deletion / Disposal: Removed from the Platform when the deletion takes effect; copies in backups overwritten within 90 days
Notes & Extended Retention Triggers: Copies of media on content delivery network (CDN) servers are removed when the files themselves are erased; until then, a deleted file may remain reachable by anyone who already has its direct address.

B — Content & Communication Data

User Content — Posts, Comments and Stories

Text, images, videos, voice messages, comments and reactions posted as Nex or as Nyx

Retention Period: Until the User deletes it or the Account is deleted; then erased within 30 days
Legal Basis: Contract; Legitimate Interest
Deletion / Disposal: Removed from the Platform at once; erased from active systems within 30 days (Content under review or needed for a legal claim: when that ends); for a photo or video, a short technical record that it existed is kept (§4); copies in backups overwritten within 90 days; copies on CDN servers removed when the files themselves are erased
Notes & Extended Retention Triggers: Content that other Users reshared may remain in their posts; Nixyum will remove personal attribution on request. Content removed by Nixyum as an Enforcement Action is kept as evidence under row D1; it has no fixed period yet.

User Content — Direct Messages

Message text, photos, videos and voice messages, send and read times, recipients

Retention Period: While the conversation exists; a conversation every participant has deleted is erased within 30 days after the last of them deleted it
Legal Basis: Contract; Legitimate Interest
Deletion / Disposal: A message deleted for everyone disappears from the conversation at once. Its text, earlier versions and file name are wiped at once, and a photo, video or voice message attached to it is erased within 2 days, unless it is under review or a legal hold applies: then they are kept until that ends, and at most 12 months after the deletion unless a report is still open or the hold continues. When an Account is deleted, the messages it sent, including photos, videos and voice messages, stay with their recipients, shown as from a "Deleted user". A conversation every participant has deleted is erased within 30 days after the last of them deleted it; one that has been reported is kept until the report record is deleted (12 months after the report closes), and one with a message held or blocked by the automated checks, or under a legal hold, is kept while that lasts.
Notes & Extended Retention Triggers: Copies in backups are overwritten within 90 days.

Notifications

In-app notifications and the queue that delivers notifications to devices

Retention Period: In-app notifications: 180 days. The delivery queue: 90 days.
Legal Basis: Contract; Legitimate Interest
Deletion / Disposal: Deleted automatically when the period ends, and with the Account
Notes & Extended Retention Triggers: None.

The Link Between an Account and its Nyx

The internal record that a Nyx belongs to an Account

Retention Period: Account life + 30 days
Legal Basis: Legitimate Interest; Legal Obligation
Deletion / Disposal: Removed 30 days after the deletion takes effect; never disclosed except in the circumstances in Privacy Policy §6.3
Notes & Extended Retention Triggers: Kept longer only under a pending legal request or a legal hold (Section 3).

C — Technical & Operational Data

Precise IP Addresses

The full IP address recorded with sign-ins, sessions, security events and error reports

Retention Period: 72 hours
Legal Basis: Legitimate Interest (platform security, subject to a balancing assessment); Legal Obligation
Deletion / Disposal: Removed automatically within 72 hours of collection
Notes & Extended Retention Triggers: Only the country is kept, with the record it belongs to (row C2). A coded form of the address, from which the address cannot be read back, may be kept with the record it belongs to, for that record's period. Longer only if the record is part of an open security investigation or a legal hold.

Security and Sign-in Records

Sign-in and sign-out times, sessions, failed sign-in attempts, rate-limit events, error reports, the country of a sign-in

Retention Period: 90 days
Legal Basis: Legitimate Interest; Legal Obligation
Deletion / Disposal: Deleted automatically at 90 days. A session ends when the User signs out, when it is revoked, or after 400 days without use; its records are deleted 90 days after it ends.
Notes & Extended Retention Triggers: The precise IP address in these records is removed at 72 hours (row C1). Longer only if a record is part of an open security investigation or a legal hold.

Identity Switch Counts

How many switches between Nex and Nyx happened each day, by platform and direction, and how many Users switched that day; no account, Persona or network identifier

Retention Period: 13 months
Legal Basis: Legitimate Interest (understanding how the two identities are used)
Deletion / Disposal: Deleted automatically after 13 months. The earlier per-switch records were folded into these counts and deleted
Notes & Extended Retention Triggers: The number of Users who switched on a day is counted without storing who they are.

Push Notification Tokens

The address the push notification service uses to reach a User's device

Retention Period: While the User is signed in on that device
Legal Basis: Contract
Deletion / Disposal: Deleted when the User signs out on that device, after 90 days without use, or with the Account
Notes & Extended Retention Triggers: What the push notification provider can see of a notification is set out in Privacy Policy §6.4.

Analytics and Performance Data

Device type, operating system, browser, app version, page-speed measurements and records of how features are used

Retention Period: 90 days
Legal Basis: Consent (the Analytics choice in the cookie settings)
Deletion / Disposal: Deleted automatically at 90 days; only counts with no User in them are kept after that
Notes & Extended Retention Triggers: Collected only with consent to Analytics (Cookies Policy). Nixyum uses no third-party analytics service.

Feed Signals

What a User views and for how long, reactions, comments, hidden posts and follows, used to arrange the feed

Retention Period: Views and viewing time: 31 days. Reactions, comments, hidden posts and follows: until the User undoes them or the Account is deleted.
Legal Basis: Contract (arranging the feed is part of the service); Legitimate Interest (Platform quality, subject to a balancing assessment)
Deletion / Disposal: Viewing records are deleted automatically at 31 days; after that only daily counts per post, with no viewer in them, are kept
Notes & Extended Retention Triggers: Never used to build advertising profiles or to infer Special Category Data (Privacy Policy §15).

Age Records

The result of the date-of-birth check at sign-up and, where an Account was blocked as possibly belonging to a Minor, the review and its outcome. Nixyum never asks for an identity document.

Retention Period: The sign-up result: Account life. A review: 30 days after its decision.
Legal Basis: Legal Obligation; Legitimate Interest (enforcing the minimum age and keeping Minors off the Platform)
Deletion / Disposal: A date of birth that shows the person is under 18 is not stored. A document sent anyway is used only for the decision and deleted within 30 days of it.
Notes & Extended Retention Triggers: See the Data Retention & Deletion Policy §7.3 and the Privacy Policy §12.

Direct Marketing Consent Records

Timestamp of opt-in consent, Policy version accepted, channel consented to, and timestamp of any withdrawal

Retention Period: 3 years from the later of withdrawal or end of consent relationship
Legal Basis: Legal Obligation (Georgian Data Protection Law — demonstrable consent); Legitimate Interest
Deletion / Disposal: Deleted or anonymised 3 years after withdrawal or after the consent relationship ends
Notes & Extended Retention Triggers: Retention on Legal Obligation basis: required to demonstrate valid basis for Direct Marketing communications and to defend against complaints. See Privacy Policy §5.6 and Advertising Policy §7.3.

Cookies and Consent Records

Cookies and similar browser storage, the cookie choice stored on the device, and the server-side records of consent

Retention Period: Each cookie: its lifetime in the Cookies Policy. The choice stored on the device: 12 months. Server-side consent records: 3 years from each record.
Legal Basis: Legitimate Interest; Consent
Deletion / Disposal: Cookies expire as the Cookies Policy lists; the choice is asked again after 12 months; server-side records are deleted 3 years after they were made
Notes & Extended Retention Triggers: Consent records are kept to show that consent was given, as the Data Protection Law requires. The current list of cookies is in the Cookies Policy.

Encrypted Backups

Full encrypted snapshots of all live databases and content storage

Retention Period: Maximum 90 days (rolling)
Legal Basis: Legitimate Interest
Deletion / Disposal: Overwritten or deleted automatically as backups rotate; used only to recover from a serious failure
Notes & Extended Retention Triggers: Deleted data stays in backups for up to 90 days before it is overwritten. If a system is restored from a backup, Account deletions made after the backup was taken are carried out again; for other data, see Data Retention & Deletion Policy §9. Backups are stored in data centres in the EU.

D — Moderation & Compliance Records

Abuse Reports & Moderation Records

Report content, reporter identity (internal), evidence reviewed, decisions taken, enforcement applied

Retention Period: Reports: 12 months after the case closes. The case file (Moderators' decisions, the Enforcement Actions taken and appeals): 2 years after the final decision, and in any case while an Enforcement Action from it, other than a warning, is still in force
Legal Basis: Legitimate Interest; Legal Obligation
Deletion / Disposal: Deleted automatically when its period ends, unless an extended retention trigger applies
Notes & Extended Retention Triggers: Serious violations (CSAM, credible threats, an ongoing law enforcement investigation): kept until the investigation closes, plus the applicable limitation period. The record of a member of staff reading a reported private message is kept 2 years, to protect Users from misuse. CSAM evidence is kept under row D2.

CSAM Evidence

Where child sexual abuse material was detected: the material itself, sealed and with strictly restricted access, its detection record and the NCMEC report reference

Retention Period: The material: 1 year from detection. The detection record and the report reference: at least 5 years from detection.
Legal Basis: Legal Obligation; Legitimate Interest
Deletion / Disposal: Kept in sealed storage that only specifically authorised staff can open; not subject to User deletion requests; the material is deleted when its year ends, unless a legal hold or an authority's request requires it to be kept longer
Notes & Extended Retention Triggers: These periods are not shorter than the minimum periods set by applicable law (see REPORT Act in the Master Definitions). Once the material is deleted, only a code identifying it is kept, so that the same material is blocked if it is uploaded again. See the Content Moderation & Takedown Policy §12.2.

Appeal Records

Appeal submissions, Moderator review notes, appeal outcomes, correspondence

Retention Period: 2 years after the appeal is decided, or longer while the case file it belongs to is kept (row D1)
Legal Basis: Legitimate Interest; Legal Obligation
Deletion / Disposal: Deleted automatically when that period ends
Notes & Extended Retention Triggers: Linked to Moderation Record; same extension triggers apply. Ensures due process audit trail.

Ban Enforcement Records

A one-way coded form of the email address of a permanently banned Account, and a code for the reason

Retention Period: By seriousness: 10 years for child sexual abuse material and other harm to children, terrorism, threats of or incitement to violence, and sharing intimate images without consent; 3 years for every other permanent ban; for an Account deleted under the Data Retention & Deletion Policy §7.3 because its holder is a Minor, until they turn 18 as best known, and at most 5 years
Legal Basis: Legitimate Interest (preventing re-registration and protecting the Platform)
Deletion / Disposal: Deleted automatically when its period ends
Notes & Extended Retention Triggers: No Content, username or device identifier is kept, only the coded email address and the reason code. Erasure requests may be refused for this category on the same basis (Data Retention & Deletion Policy §8.4).

Data Subject Request Records (DSARs)

Identity verification, request type, actions taken, correspondence, response timestamps

Retention Period: 5 years from closure
Legal Basis: Legal Obligation; Legitimate Interest
Deletion / Disposal: Securely archived; deleted at 5 years
Notes & Extended Retention Triggers: Kept to show that Nixyum met its obligations to Data Subjects under the Georgian Data Protection Law. A data export file is deleted 48 hours after it is ready. Response times are in the Master Definitions and the Privacy Policy.

E — Commercial & Support Records

Transaction & Payment Records

Records of payments and donations to Nixyum, and of refunds (no full card data is stored)

Retention Period: Minimum 5 years
Legal Basis: Legal Obligation (Georgian Tax Code)
Deletion / Disposal: Retained for statutory period; securely archived; access restricted to finance and compliance personnel
Notes & Extended Retention Triggers: Georgian Tax Code requires retention of accounting records for a minimum of 5 years. Extended if subject to tax audit or litigation.

Customer Support Communications

Support ticket content, email correspondence, resolution notes, linked account data

Retention Period: 24 months post-resolution
Legal Basis: Legitimate Interest
Deletion / Disposal: Deleted 24 months after the ticket closes, together with its replies and attached files; tickets linked to an Account are deleted with the Account, attached files included
Notes & Extended Retention Triggers: Requests to take down intimate images made through the help centre are deleted 12 months after they are handled. Support records with no personal identifiers may be kept to improve the service.

Advertiser Account & Campaign Data

Not collected: Nixyum shows no advertising at present (Advertising Policy §2). This row will be completed before any advertising starts.

Retention Period: Not applicable
Legal Basis: Not applicable
Deletion / Disposal: Not applicable
Notes & Extended Retention Triggers: Not applicable.

F — Legal & Security Records

Data Breach Records

Incident log, affected data categories, discovery timestamp, containment actions, notifications sent

Retention Period: 5 years from incident date
Legal Basis: Legal Obligation (Georgian Data Protection Law)
Deletion / Disposal: Securely archived; restricted access; not subject to User deletion requests
Notes & Extended Retention Triggers: Georgian Data Protection Law requires documentation of all breaches. Notifications to the Supervisory Authority and affected Data Subjects are retained for the same period.

Legal Compliance & Court Order Records

Law enforcement requests, court orders, data preservation holds, legal correspondence

Retention Period: Until hold lifted + 5 years
Legal Basis: Legal Obligation
Deletion / Disposal: Retained until legal hold is lifted plus applicable limitation period; then deleted
Notes & Extended Retention Triggers: Nixyum complies with all valid legal orders. Existence of a legal hold may not be disclosed to the User if prohibited by the ordering authority.

Aggregated & Anonymised Data

Usage statistics, demographic trends, feature adoption metrics — all personal identifiers removed

Retention Period: Indefinite
Legal Basis: N/A (no longer Personal Data)
Deletion / Disposal: Not subject to deletion obligations — irreversibility of anonymisation verified before indefinite retention
Notes & Extended Retention Triggers: May be published in reports, shared with partners, or used for business analysis. Re-identification is prohibited.

3. Extended Retention — Triggers

The following circumstances may extend any retention period beyond the standard period shown in the Schedule above:

(a) Legal Hold — a court order, law enforcement request, or regulatory direction requiring preservation of specific data. Retention continues until the hold is formally lifted. Nixyum documents all legal holds and notifies affected Users where legally permitted.
(b) Active Litigation or Dispute — where Nixyum is aware of potential or active legal proceedings involving specific data. Retention continues until the matter is resolved and any applicable limitation period has expired.
(c) Regulatory Compliance — where Georgian law (including the Tax Code, Electronic Communications Law, or other applicable legislation) mandates a specific retention period. The statutory period prevails.
(d) Ban Enforcement — minimal identifiers of permanently banned Users are retained on the basis of Legitimate Interest (platform safety). Retention is tiered by seriousness (row D4). Data Subject deletion requests may be refused for this category on the same basis.
(e) Data Subject Request — a User may ask Nixyum to keep their own data beyond the standard period, for example for a legal claim. Nixyum will accommodate reasonable requests for up to ninety (90) days, on written request to [email protected] (Data Retention & Deletion Policy §8.6).

4. Deletion and Anonymisation Standards

"Deletion" means: (i) the data is made inaccessible to other Users and to Platform functions at once; (ii) it is permanently erased from active databases and storage within thirty (30) days; 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); (iii) copies in encrypted backups are overwritten as the backups rotate, within ninety (90) days at most; and (iv) copies of media on content delivery network (CDN) servers are removed when the files themselves are erased, and 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.

"Anonymisation" means: irreversible transformation of data such that the individual cannot be re-identified by any means reasonably available to Nixyum or any third party. Anonymised data is no longer Personal Data and is not subject to data protection obligations or retention limits.

5. Changes to This Schedule

This Schedule may be updated to reflect changes in law, Platform functionality, or operational practice. Material changes will be notified at least thirty (30) days in advance through 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 current version is always published on the Platform. Continued use after the effective date constitutes acceptance of the revised Schedule.

6. Contact

Privacy & Data Protection: [email protected]
Data Controller: Nixyum LLC · Tbilisi, 13 Nikoloz Janashia Street, Georgia
Supervisory Authority: State Audit Office of Georgia (SAO) · pdp.sao.ge