1Purpose and Scope

This policy sets out the data retention and destruction practices of Tapnet Solutions (Pty) Ltd, trading as TradeJournal. It defines how long we retain different categories of personal information and how that information is securely destroyed when it is no longer required.

This policy applies to tradejournal.co.za and all other websites, applications, and digital services operated by Tapnet Solutions (Pty) Ltd.

This policy is implemented in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA), which requires that personal information must not be retained for longer than is necessary to achieve the purpose for which it was collected, unless retention is authorised by law.

2Retention Schedule

The following table sets out the retention periods, legal basis, and destruction methods for each category of data we process:

Data Type	Retention Period	Legal Basis	Destruction Method
User account data	Duration of account + 30 days after deletion request	Contractual	Secure deletion from database
Trading journal entries	Duration of account	Contractual	Secure deletion from database
Financial/subscription records	5 years after last transaction	SA Income Tax Act 58 of 1962	Secure deletion after retention period
Tool disclaimer acceptances	7 years	POPIA compliance evidence	Secure deletion after retention period
Consent records	7 years	POPIA compliance evidence	Secure deletion after retention period
Email subscriber data	Until unsubscribe + 30 days	Consent	Secure deletion from database
Contact form submissions	1 year	Legitimate interest	Secure deletion
Server/application logs	90 days	Security and operational	Automated rotation/deletion
Cookie consent records	3 years	POPIA compliance	Secure deletion
Backup data	30 days rolling	Operational necessity	Automated overwrite

3Destruction Methods

When personal information reaches the end of its retention period or is no longer required, it is destroyed using the following methods:

Database records: Permanent deletion via SQL DELETE operations, with verification that records have been removed from all relevant tables and indexes
File storage: Secure overwrite of stored files, ensuring data cannot be recovered
Backups: Retained on a rolling schedule and automatically overwritten after the retention period. Point-in-time recovery windows do not extend beyond 30 days
Paper records (if any): Cross-cut shredding to a particle size that prevents reconstruction

4Exceptions

Data may be retained beyond the periods specified in the retention schedule in the following circumstances:

Legal hold: Where data is subject to a legal hold order or preservation notice, it will be retained for the duration of the hold regardless of the standard retention period
Regulatory investigation: Where data is relevant to an ongoing regulatory investigation or audit, it will be retained until the matter is concluded
Dispute resolution: Where data is relevant to an ongoing or reasonably anticipated dispute, it will be retained until the dispute is fully resolved, including any appeal periods

5Policy Review

This policy is reviewed annually by the Information Officer to ensure that retention periods remain appropriate and aligned with legal requirements, business needs, and best practices.

Any changes to this policy will be published on our website and, where appropriate, communicated to affected data subjects.

6Contact

For questions about this policy, data retention practices, or to request the deletion of your personal information, please contact:

Information Officer

Wynand de Beer

Email: wynand@tapnet.co.za

Phone: 079 174 8357

Address: 594 Bombani Street, Elarduspark, Gauteng, 0181, South Africa

Information Regulator (South Africa)

Email: enquiries@inforegulator.org.za

Phone: 012 406 4818

Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Website: https://inforegulator.org.za