Data Retention and Deletion Policy
Version 1.0 · Last updated
Passages marked [POR DEFINIR] await the company details still to be confirmed.
English translation for convenience — the Spanish version is the governing text.
TITLE I. GENERAL PROVISIONS
Chapter 1. Purpose and Relationship with the Rest of the Legal Framework
1.1 Purpose
This Data Retention and Deletion Policy (hereinafter, the "Policy") is intended to consolidate, in a single reference instrument, the retention periods applicable to each category of information processed by Ancuria™ Inteligencia Inmobiliaria (hereinafter, "Ancuria", the "Platform" or the "Data Controller"), as well as to detail the technical and legal procedures through which such information is blocked, deleted or anonymized upon expiration of those periods.
1.2 Consolidating function
The retention periods and criteria developed here are already anticipated, in a scattered manner, in Chapter 21 (Personal Data Retention and Blocking Period) and Chapter 35.3 (Data Retention Following Cancellation) of the Full Privacy Notice and of the Terms and Conditions of Service, respectively, as well as in Chapter 15 (Backup and Information Retention) of the Information Security Policy and in Clause 9 (Return or Deletion of Data upon Termination of the Agreement) of the Data Processing Agreement. This Policy does not modify those periods; it consolidates them into a single calendar, for operational and audit clarity purposes.
1.3 Prevalence in case of numerical discrepancy
Should the master calendar contained in Title II of this Policy differ from a period mentioned in another document of the Legal Framework, the period stated in this Policy shall prevail, the Data Controller being obliged to promptly correct the discrepancy detected in the corresponding document, in order to maintain the integral coherence of the Legal Framework.
1.4 Consequences of non-compliance
Non-compliance with this Policy is governed by the same consequences provided in Chapter 25 of the Full Privacy Notice and in applicable Personal Data protection legislation.
Chapter 2. Definitions
2.1 "Retention"
The maintenance of information in the Data Controller's active databases or systems, available for processing in accordance with the informed purposes.
2.2 "Blocking"
The identification and safekeeping of information, with the sole purpose of preventing its processing other than attending to the Data Subject's own request, or its retention for compliance with a legally provided obligation, until expiration of the applicable statute-of-limitations period.
2.3 "Deletion"
The definitive elimination of information from the Data Controller's active and backup systems, such that it ceases to be available for any future processing.
2.4 "Anonymization"
The technical process through which information is transformed so that it no longer allows, directly or indirectly, identifying the individual to whom it originally corresponded.
2.5 "Legal Hold"
The exceptional suspension of the ordinary deletion periods provided in this Policy, motivated by the existence of litigation, an administrative proceeding, or a requirement from a competent authority demanding the retention of specific information.
2.6 "Grace period"
The additional period during which, where applicable, the Data Controller retains certain information after the conclusion of its primary purpose, before proceeding to block or delete it, for purposes of handling claims, internal audits, or recovery of the corresponding Account.
Chapter 3. Retention Principles
3.1 Principle of temporal minimization
The Data Controller retains information only for as long as necessary to fulfill the purposes informed in the Full Privacy Notice, or the legal, tax or accounting obligations applicable to it, avoiding indefinite or unjustified retention of information.
3.2 Principle of proportionality by category
The retention periods described in Title II are determined proportionally to the nature and sensitivity of each category of information, being longer for information subject to specific legal obligations (such as tax information) and shorter for that of a purely operational nature.
3.3 Principle of deletion by default
Once the retention period applicable to a category of information has elapsed, absent a Legal Hold exception pursuant to Chapter 14, the Data Controller will proceed to block and subsequently delete or anonymize it automatically or systematically, without requiring an express request from the Data Subject or the User.
3.4 Principle of traceability
The Data Controller maintains, to the extent technically reasonable, records of the blocking, deletion and anonymization actions it executes under this Policy, for internal audit purposes and to attend to authority requests.
TITLE II. MASTER RETENTION CALENDAR
Chapter 4. Account and Registration Data
4.1 Retention table
| Information category | Active retention period | Subsequent grace period | Basis |
|---|---|---|---|
| User identification and contact data | Life of the Account | 5 (five) years after cancellation | Section 35.3 of the Terms and Conditions of Service; Article 30 of the Federal Fiscal Code |
| Access credentials (password hash) | Life of the Account | Immediate deletion upon definitive cancellation | Chapter 11 of the Terms and Conditions of Service |
| Professional accreditation data (AMPI, licenses) | Life of the Account | 5 (five) years after cancellation | Section 8.4 of the Terms and Conditions of Service; Article 30 of the Federal Fiscal Code |
4.2 Justification of the grace period
The grace period following Account cancellation allows the User to reactivate their Account pursuant to section 35.4 of the Terms and Conditions of Service, and the Data Controller to handle claims or audits related to the cancelled Account. This period is set at 5 (five) years after Account cancellation, based on Article 30 of the Federal Fiscal Code, which imposes the obligation to keep accounting records and receipts related to the provision of the Service. During this period, the data remains blocked — that is, it is not used for commercial or operational purposes — pursuant to the blocking principle provided in the Federal Law on the Protection of Personal Data Held by Private Parties, and its sole purpose is to address possible tax or legal obligations or authority requests. After that period, the data is deleted securely and definitively, unless a different legal obligation requires a longer period for a specific data point.
Chapter 5. Invoicing and Tax Data
5.1 Retention table
| Information category | Retention period | Basis |
|---|---|---|
| Digital Tax Receipts over the Internet (CFDI) issued | As required by applicable Mexican tax legislation (generally 5 years under the Federal Fiscal Code, without prejudice to the Data Controller verifying the period in force at the time of deletion) | Federal tax legislation |
| Invoicing data (business name, RFC, tax domicile of the User) | Same period as the associated CFDI | Federal tax legislation |
| Complete payment-instrument data | Not applicable — the Data Controller does not store such data directly, pursuant to section 32.3 of the Terms and Conditions of Service | Section 32.3 of the Terms and Conditions of Service |
5.2 Consequences of non-compliance
Deleting tax receipts before expiration of the applicable legal period constitutes a breach of tax legislation, with the corresponding administrative consequences.
Chapter 6. CRM and Prospect Data (Data Controller's Personal Data under the Data Processing Agreement)
6.1 Retention table
| Information category | Retention period | Basis |
|---|---|---|
| Prospect and client data loaded into the CRM module | Duration of the contractual relationship between the Real-Estate Agent (Data Controller) and Ancuria (Data Processor), plus the grace period described in Chapter 4 | Clause 9 of the Data Processing Agreement |
| Data derived from end-client interactions with Artificial Intelligence Agents | [POR DEFINIR] months from the last interaction, unless the responsible Real-Estate Agent instructs otherwise | Clause 2 of the Data Processing Agreement |
6.2 Election of the Data Controller (Real-Estate Agent) upon termination
Pursuant to Clause 9 of the Data Processing Agreement, upon termination of their relationship with Ancuria, the Real-Estate Agent may choose between the return or the deletion of this data, deletion applying by default absent an express election.
Chapter 7. Interactions with Artificial Intelligence Agents
7.1 Retention table
| Information category | Retention period in identifiable form | Subsequent processing | Basis |
|---|---|---|---|
| History of conversations with Artificial Intelligence Agents (full content) | [POR DEFINIR] months, for quality control and human oversight purposes | Anonymization or deletion upon expiration of the period | Section 9.6 of the Full Privacy Notice and Chapter 9 of the Responsible Artificial Intelligence Policy |
| Aggregated and anonymized data derived from such interactions, used for model improvement | Indefinite, as long as it remains effectively anonymized and non-reidentifiable | Not applicable (no longer constitutes Personal Data) | Section 9.6 of the Full Privacy Notice |
| Artificial Intelligence Incident Reports (Chapter 14 of the Responsible Artificial Intelligence Policy) | [POR DEFINIR] years, for governance documentation and audit purposes | Retention in blocked form after that period | Section 3.6 (accountability) of the Responsible Artificial Intelligence Policy |
Chapter 8. Market Indicators and Aggregated Data
8.1 Retention table
| Information category | Retention period | Basis |
|---|---|---|
| Source market data (public sources and data uploaded by Users), in identifiable form | Duration necessary for generation of the corresponding Indicator, subject to the periods applicable to the source data category (Chapters 4 and 6) | Section 9.5 of the Full Privacy Notice |
| Already-generated Market Indicators, in aggregated, non-identifiable form | Indefinite, as they constitute the Platform's proprietary database pursuant to section 3.2 of the Intellectual Property Policy | Not applicable (does not constitute Personal Data) |
Chapter 9. Security, Audit and Consent-Evidence Records
9.1 Retention table
| Information category | Retention period | Basis |
|---|---|---|
| System access activity logs | [POR DEFINIR] months | Section 7.5 of the Information Security Policy |
| Documentation of confirmed Security Incidents | [POR DEFINIR] years, for audit and Due Diligence purposes | Section 13.6 of the Information Security Policy |
| Electronic evidence of acceptance of the Legal Framework (version accepted, date, mechanism) | Life of the Account, plus the statute-of-limitations period applicable to the defense of the Data Controller's rights | Chapter 4 of the Electronic Consent Formalization |
| General Platform backups | Pursuant to section 15.4 of the Information Security Policy, without exceeding the periods applicable to the backed-up information | Section 15.4 of the Information Security Policy |
TITLE III. DELETION PROCEDURES
Chapter 10. General Blocking, Deletion and Anonymization Procedure
10.1 Ordinary sequence
Once the active retention period applicable to a category of information under Title II has elapsed, such information will be, in the following order: (i) blocked, remaining inaccessible for ordinary processing; (ii) retained in blocked state during the statute-of-limitations period that, where applicable, applies; and (iii) definitively deleted or anonymized upon expiration of that period.
10.2 Automation of the procedure
The Data Controller seeks to implement, to the extent of its technical capabilities, automated or semi-automated mechanisms that execute the procedure described in the preceding section, minimizing reliance on manual actions subject to human error.
10.3 Scope over backup systems
The deletion procedure described in this Chapter extends, to the extent technically reasonable, to the Data Controller's backup systems, acknowledging that complete deletion of information from those systems may be deferred until the next backup rotation cycle pursuant to section 15.4 of the Information Security Policy.
10.4 Consequences of non-compliance
Retention of information beyond the periods established in Title II, absent a Legal Hold exception pursuant to Chapter 13, shall constitute a breach of this Policy and of the data-quality principle provided in the Federal Law on the Protection of Personal Data Held by Private Parties.
Chapter 11. Deletion at the Data Subject's Request
11.1 Reference to the ARCO Rights procedure
Deletion of Personal Data at the Data Subject's express request, prior to expiration of the ordinary periods of this calendar, is governed by the procedure for exercising the Right of Cancellation described in Chapter 15 of the Full Privacy Notice.
11.2 Interaction with third-party controllers' data
When the Data Subject's request concerns Personal Data that a Real-Estate Agent has loaded as Data Controller's Personal Data under the Data Processing Agreement, the Data Controller shall refer that request to the corresponding Real-Estate Agent, pursuant to Clause 5 of that Agreement, without proceeding to direct deletion except upon the latter's express instruction.
Chapter 12. Deletion upon Termination of the Contractual Relationship
12.1 Reference to the Terms and Conditions of Service
Deletion of information deriving from the cancellation or termination of a User's Account is governed by section 35.3 and by Chapter 45 (Effects of Termination) of the Terms and Conditions of Service, the specific periods consolidated in Title II of this Policy applying.
12.2 Export prior to deletion
The User may request export of their information before expiration of the grace period described in Chapter 4, pursuant to section 35.3 of the Terms and Conditions of Service.
Chapter 13. Exceptions for Legal Obligation or Legal Hold
13.1 Suspension of ordinary periods
The retention periods established in Title II shall be suspended with respect to the specific information relevant to: (i) ongoing or reasonably anticipated litigation or administrative proceedings in which the Data Controller is a party; (ii) a founded and motivated requirement from a competent authority; or (iii) a specific legal obligation requiring a retention period different from that established here.
13.2 Limited scope of the Legal Hold
The Legal Hold shall apply exclusively to the information specifically relevant to the corresponding litigation, proceeding or requirement, and not in a generalized manner to all the information of the Data Subject or User involved.
13.3 Lifting of the Legal Hold
Once the litigation or administrative proceeding has concluded, or the authority requirement that motivated the Legal Hold has been addressed, the Data Controller shall resume the ordinary blocking, deletion or anonymization procedure pursuant to Chapter 10.
13.4 Consequences of non-compliance
Deleting information subject to a current Legal Hold could constitute a breach of procedural or legal obligations other than Personal Data protection legislation, including, where applicable, liability for obstruction of a judicial or administrative proceeding.
TITLE IV. FINAL PROVISIONS
Chapter 14. Validity, Calendar Updates and Final Provisions
14.1 Entry into force
This Policy shall enter into force on the date stated on the cover page of this document.
14.2 Updating the master calendar
The Data Controller will review and update the master calendar contained in Title II as its technology infrastructure, applicable legal obligations, or the incorporation of new Platform modules evolve, without such update, when it does not materially modify the periods already informed to Data Subjects, requiring new acceptance under the Electronic Consent Formalization.
14.3 Severability
Should any provision of this Policy be declared null, illegal or unenforceable, such declaration shall not affect the validity of the remaining provisions.
14.4 Governing language
In the event of translation into another language, the Spanish (Mexico) version shall prevail for interpretation purposes in case of discrepancy.