DATA RETENTION POLICY AND SCHEDULE

1. Wellence (the Organisation, we, our or us) is committed to adhering to the data protection and privacy rights of allindividuals whose Personal Data it Processes in the course of its activities. To do so, we are committed to meeting therequirements imposed by UK Data Protection Laws: particularly, requirements under the UK General Data ProtectionRegulation (UK GDPR) and the Data Protection Act 2018. This Data Retention Policy is implemented to this end,with a focus on the storage limitation principle.
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2. This Data Retention Policy is based on the UK Data Protection Laws. If this Policy is at any time inconsistent withthis body of law, Wellence will act (including by adjusting any relevant Retention Periods) to meet the requirementsimposed by up-to-date UK Data Protection Laws in priority to the requirements set out in this Policy.
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3. Any questions in relation to this Policy should be referred to gaurav katyal in the first instance, via email at team@wellence.me.

4. Within this Policy, the following terms hold the following meanings:‘Condition for Processing’ means the exceptions to the general prohibition on Processing Special CategoryPersonal Data, specified by UK Data Protection Laws, at least one of which must apply to Processing of SpecialCategory Personal Data for that Processing to be in compliance with UK Data Protection Laws;‘Data Protection Principles’ means the 7 core principles at the heart of the UK Data Protection Laws, which these laws are constructed to uphold;‘Data Subject’ means the individual to whom an item of Personal Data relates and who can be identified from this data;‘Lawful Bases’ means the 6 grounds set out in Article 6 of the UK GDPR, at least one of which must apply toProcessing of Personal Data for that Processing to be in compliance with UK Data Protection Laws;‘Personal Data’ means any information relating to an individual who can be identified (either directly or indirectly) by this information. References to Personal Data within this Policy refer to all Personal Data that theOrganisation Processes, including any Personal Data that the Organisation stores following use of this data in the course of its work with or via agents, consultants, sub-contractors, or similar;‘Processing’ means any use of Personal Data outside of private personal use, including obtaining, recording, managing, using, storing, or anonymising this data;‘Special Category Personal Data’ means the certain types of personal data that the UK Data Protection Laws identify as being more sensitive in nature than other Personal Data and, consequently, as requiring a higher level of protection; including information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and biometric data;‘UK Data Protection Laws’ means any law applicable in the UK relating to the Processing of Personal Data, including but not limited to the UK GDPR and the Data Protection Act 2018.
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5. The definitions above apply also to the singular or plural, other tense, or other form of such words when used withincthis Policy.

6. Wellence is committed to ensuring that all Processing of Personal Data carried out by us and/or our agents, subcontractors, consultants, employees, or others working on our behalf is carried out in compliance with UK DataProtection Laws. As such, we confirm that:All Personal Data is Processed in reliance on one or more of the Lawful Bases;All Special Category Personal Data is, additionally, Processed in reliance on a separate Condition for Processing; and All Processing is carried out in accordance with the Data Protection Principles.
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7. All necessary documentation and procedures are completed and in place to ensure that all Processing is carried out in accordance with UK Data Protection Laws and the Data Protection Principles (e.g. the transparency and accountability principles).Access to documentation can be requested from gaurav katyal by emailing team@wellence.me. Access will be granted where it is appropriate to do so (e.g. with regard to other individuals’ data privacy and to business confidentiality needs).

8. This Data Retention Policy deals primarily with how we will uphold the Data Protection Principle of storage limitation. The storage limitation principle requires that we do not keep (e.g. store) Personal Data for any longer thanwe need it, with ‘need’ determined by reference to the purposes and Lawful Bases for which given Personal Data isProcessed.
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9. Adhering to the storage limitation principle is vital for:Reducing the risks of data breaches and other security threats to data’s privacy and integrity;Reducing the risk of Personal Data becoming irrelevant, excessive, inaccurate, out-of-date; or being used incorrectly or by accident; andReducing the Organisation’s legal risk by ensuring that Personal Data is not retained once the applicable LawfulBases(s) no longer apply (i.e. once it can no longer be Processed in accordance with UK Data Protection Laws).
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10. To uphold the storage limitation principle, Wellence’s commitments include (but are not limited to):Adhering to the Retention Periods set out in the schedule to this Policy titled ‘Schedule - Retention Periods’;No longer storing Personal Data that, despite not yet having been held for the duration of the applicableRetention Period, is inappropriate to store with regard to UK Data Protection Laws and other laws (e.g. when there is no requirement that it is retained longer for purposes such as maintaining compliant tax and employmentrecords or dealing with legal claims);Properly handling any individuals’ data erasure requests and, where appropriate, complying with such requests;andDeleting or anonymising Personal Data that is no longer needed in accordance with this Policy.

11. A Retention Period is a set time period after which the applicable type of Personal Data should be considered no longer needed and should be deleted or anonymised, unless a situation applies that requires certain Personal Data to be stored for longer and which justifies its further Processing (including storing) under UK Data Protection Laws.Justifications and decisions on extended storage periods can be identified and implemented by the Staff Member responsible for the applicable Personal Data.a.b.
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12. Once Personal Data has reached the end of its Retention Period, if no justification for extension or other exception applies, this data should be deleted or anonymised in accordance with the section of this Policy titled ‘Dealing withPersonal Data that is No Longer Needed’.
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13. Wellence’s Retention Periods are set out in the schedule to this Policy titled ‘Schedule - Retention Periods’.
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14. The Retention Periods apply however the Personal Data is held by us (e.g. whatever its location or format).

15. All Personal Data that is no longer needed in any way must be either deleted (i.e. erased) or anonymised.
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16. Deletion of Personal Data held electronically entails this data being permanently deleted as far as is technologically possible. This means that the Staff Member carrying out the deletion must ensure that, after deletion, it is beyond use(i.e. they must ensure that, if any traces remain, these traces cannot identify the Data Subject). To destroy any electronically held Personal Data, a Staff Member should to delete personal data, a staff member will raise a ticket through the ticketing system, JIRA, and get an approval from the leadership team. The Staff Member carrying out the deletion should ensure that:Any offline copies of the Personal Data are deleted, as well as published/online versions;Any backup copies of the Personal Data are deleted, whether or not such copies are up-to-date.
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17. Deletion of Personal Data held in hard copy entails destruction of this data to the extent that it is beyond use (e.g. so that it cannot be reassembled or read).
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18. Anonymisation entails Personal Data being altered into a form that does not allow identification of the Data Subject in any way (i.e. so that the information no longer constitutes Personal Data and is no longer covered by UK DataProtection Laws). Anonymisation may be carried out as an alternative to deletion when useful for the Organisation and appropriate (e.g. for the purposes of carrying out statistical analysis with a large, anonymous dataset).19. If a Staff Member needs to delete or anonymise Personal Data and they are uncertain as to how to appropriately do so, they should contact cofounder via email at team@wellence.me for assistance.

20. Day-to-day responsibility for monitoring compliance with this Policy, for setting, evaluating, and adapting data retention practices and this Policy, and for setting, evaluating, and adapting Retention Periods, sits with cofounder.

21. All individuals working for or acting on behalf of Wellence at all levels, including senior managers, officers, employees, consultants, trainees, homeworkers, part-time and fixed-term workers, casual workers, agency workers, volunteers, and interns (collectively ‘Staff Members’) should follow this Policy in relation to any Personal Data that they Process. If they have any questions or concerns related to this Policy and their data storage obligations, they should contact cofounder via email at team@wellence.me.

22. This Policy does not form part of any contract of employment or similar and Wellence may amend it at any time a tour absolute discretion.
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23. Any changes to the Retention Periods will be made in compliance with the law and a new justification will be provided for each new Retention Period set. Any such changes will be communicated to relevant Staff Members in a timely manner to ensure that practices are adapted accordingly.
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24. Retention Periods will be reviewed by cofounder (or somebody who cofounder has assigned to review the RetentionPeriods on their behalf and subject to their approval) at least once every year, to ensure that these Retention Periods are still reasonable with regard to any changes to the Personal Data held and to any new laws or guidance relevant to a given Retention Period.