DATA RETENTION POLICY

OVERVIEW

Information is retained only for as long as AIMM considers appropriate having regard to:

• applicable legal and regulatory requirements;

• contractual obligations;

• legitimate business purposes;

• protection of AIMM's legal rights and interests;

• operational requirements;

• dispute resolution;

• fraud prevention;

• information governance.

Retention periods may differ depending upon the nature of the information concerned.

Nothing in this Policy obliges AIMM to retain information for any minimum or maximum period except where required by applicable law or binding contractual obligations.

POLICY OBJECTIVES

This Policy is intended to support:

• responsible information governance;

• legal and regulatory compliance;

• operational efficiency;

• protection of confidential information;

• protection of proprietary Commercial Intelligence;

• effective records management;

• appropriate disposal of information when no longer required.

INFORMATION CATEGORIES

Information processed by AIMM may include:

• Commercial Intelligence Deliverables;

• Commercial Intelligence Riders;

• Master Agreements;

• contractual documentation;

• business correspondence;

• client communications;

• procurement research;

• source documentation;

• compliance records;

• accounting and financial records;

• personal information;

• website administration records;

• operational records.

The classification and retention of information remain at AIMM's discretion.

RETENTION PRINCIPLES

AIMM seeks to retain information only where it considers such retention appropriate.

• Information may be retained for purposes including:

• providing Commercial Intelligence Services;

• administering commercial relationships;

• protecting intellectual property;

• maintaining contractual records;

• compliance activities;

• responding to legal claims;

• dispute resolution;

• audit requirements;

• business continuity;

• internal governance.

Retention periods may be extended where AIMM reasonably considers continued retention to be appropriate.

COMMERCIAL INTELLIGENCE RECORDS

AIMM may retain records relating to Commercial Intelligence Deliverables, Commercial Intelligence Riders and Master Agreements for the purposes of:

• maintaining commercial records;

• protecting proprietary Commercial Intelligence;

• administering contractual relationships;

• supporting audit trails;

• enforcing contractual rights;

• protecting against non-circumvention;

• resolving disputes.

Retention of such records does not imply any continuing obligation to provide Commercial Intelligence Services.

CONTRACTUAL DOCUMENTATION

Executed contractual documentation may be retained for such period as AIMM considers appropriate for legal, commercial, regulatory or evidential purposes.

• This may include:

• Master Agreements;

• Commercial Intelligence Riders;

• confidentiality agreements;

• non-circumvention agreements;

• fee agreements;

• amendments;

• related correspondence.

ACCOUNTING & FINANCIAL RECORDS

Accounting and financial records may be retained for such periods as AIMM considers appropriate to comply with applicable accounting, taxation and legal obligations.

Where applicable, statutory record-keeping requirements may require information to be retained beyond the conclusion of a commercial relationship.

PERSONAL INFORMATION

Personal information may be retained only for so long as AIMM considers necessary for the purposes for which it was collected, subject to:

• applicable data protection legislation;

• legal obligations;

• contractual requirements;

• legitimate business interests;

• the protection of AIMM's legal rights.

Further information regarding the processing of personal information is available in AIMM's Privacy Policy.

LEGAL HOLDS & DISPUTES

Where AIMM considers that information may be relevant to:

• actual or anticipated legal proceedings;

• arbitration;

• regulatory investigations;

• contractual disputes;

• enforcement of contractual rights;

• fraud prevention; or

• compliance reviews

AIMM may retain the relevant information for such period as it considers appropriate, notwithstanding any general retention practices described in this Policy.

SECURE DISPOSAL

Where AIMM determines that information is no longer required, it may be securely deleted, destroyed, anonymised or otherwise disposed of using methods selected by AIMM.

The disposal method used will depend upon the nature of the information and AIMM's operational requirements.

POLICY REVIEW

AIMM may review, amend, replace or withdraw this Data Retention Policy at any time.

Retention practices may change to reflect developments in:

• business operations;

• technology;

• information governance;

• legal requirements;

• regulatory expectations;

• recognised good practice.

RELATIONSHIP WITH OTHER POLICIES

This Data Retention Policy should be read together with:

• Privacy Policy

• Information Security Policy

• AI Governance Framework

• Compliance

• Terms of Business

• Commercial Intelligence Framework

• Commercial Intelligence Licence

• Website Terms of Use

• Acceptable Use Policy

IMPORTANT NOTICE

This Data Retention Policy provides a general overview of AIMM's information retention principles.

It is provided for general information only and does not create any contractual commitment, warranty or representation regarding the retention or deletion of any particular record or category of information.

The rights and obligations of AIMM and its Clients are governed exclusively by the applicable written contractual documentation and any mandatory provisions of applicable law.