Data Retention Schedule

Schedule 1 – Record Retention Schedule Guideline Retention Periods

The retention periods below are guidelines based on the type of record. This Data Retention Matrix should be read in conjunction with the Group’s Data Retention and Destruction Policy, which explains how this matrix should be used in order to assist the Group to comply with its data retention obligations under data protection laws. The retention periods should be aligned to/with the respective periods listed in the various data set inventories (also referred to as “Records of Processing Activities”).

The following is an excerpt of our internal Data Retention and Destruction Policy

Section A

Players Data Retention Periods - iGaming:

Data Category	Purpose	Legal Ground	Duration	Start of the Period	Where are these stored?	Data Owner
Transaction Data	Tax & Accounting	Legal Obligation	10 years 7 years for NL 7 years for ON	Last Transaction	Sensei, backoffice, Sisense, hive, redshift, s3, mysql(bdp- staging)	Tech
Account Registration Data (Including SVJ & RGIAJ calls, player or staff decisions impacting player accounts or payment methods)	AML	Legal Obligation	5 years 10 years for ES 7 years for ON *NB:* If includes tax relevant data, then 10 years for DE	After closure of account or the time of reporting of unusual transaction	Sensei, backoffice, Sisense, hive, redshift, s3, mysql(bdp- staging)	Tech
Identification & verification data (KYC, AML) (Other documentation and information obtained from trustworthy independent sources)	AML	Legal Obligation	5 years 10 years for ES 7 years for ON *NB:* If includes tax relevant data, then 10 years for DE.	After closure of account or the time of reporting of unusual transaction	Sensei, backoffice, Jumio, hive, redshift, s3, mysql(bdp- staging), Sisense	Tech
Notes on player’s account	AML	Legal Obligation	5 years 10 years for ES 6 years for DE 7 years for ON	After closure of account or the time of reporting of unusual transaction	Sensei, backoffice, mysql(bdp- staging)	Tech
Gaming history	AML & Player Protection Directive	Legal Obligation	5 years 10 years for ES 10 years beginning with the expiry of each year → A rolling 10 years period for DE 7 years for ON	After closure of account	Sensei, backoffice, Sisense, hive, redshift, s3, mysql(bdp- staging)	Tech
Contracts	To comply with contractual obligation	Contractual Obligation	5 years 10 years for ES and DE *NB:* For ON - do not generally need to be retained except to the extent they pertain to the listed categories of information that must be retained in Section 20.2 of iGO’s AML Operational Guidance.	After closure of account	Confluence, Sugarsync	Legal and Casino Operations
Business correspondence & Player interaction	AML	Legal Obligation	5 years 10 years for ES 6 years for DE *NB:* For ON - do not generally need to be retained except to the extent they pertain to the listed categories of information that must be retained in Section 20.2 of iGO’s AML Operational Guidance.	After closure of account	Intercom, Google Mailboxes	Tech
Self- Exclusion data (Defined period) (including NSE & SE)	Protection against gambling addiction	Legal obligation	6 months 6 years for ES and DE	From expiry of self- exclusion period	Sensei, backoffice, hive, redshift, s3, Sisense	Tech
Self- Exclusion data (Indefinite period) (including NSE & SE)	Protection against gambling addiction	Legal obligation	Indefinite 6 years after the expiry of the self- or third party exclusion for DE	Immediate	Sensei, backoffice, hive, redshift, s3, Sisense	Tech
Data regarding responsible gaming	RG, AML	Legal obligation	2 years from last interaction or 5 years 10 years for ES 5 or 6 years for DE, depending on whether only KYC/CDD data is concerned or also business letters to be stored according to the German Commercial Code and the German Tax Act 5 years for Sweden 5 years for UK 3 years for NL	From the moment of termination	Sensei, backoffice, hive, redshift, s3, Sisense	Tech

Other Data Retention Periods:

Data Category	Purpose	Legal Ground	Duration	Start of the Period	Where are these stored?	Data Owner
CCTV footage	Office Security	Legal Obligation	7 days	From the data of the footage	Internal IT	Internal IT
Information, including logs, related to compliance with the law, the AGCO Standards and Requirements and/or adherence with control activities	Licensing in Ontario	Legal Obligation	3 years	Immediate at creation of record	Confluence	Compliance & Legal

Financial Records Retention Periods:

Data Category	Purpose	Legal Ground	Duration	Start of the Period	Where are these stored?	Data Owner
Tax and National Insurance Records	Financial record keeping	Legal obligation	20 years, after which they are to be destroyed 6 years for ES 10 years for DE	Immediate at creation of record	Bamboohr and Dakar	HR & Payroll
Supplier and Consultants personal data (Name, Surname and IBAN number)	Financial record keeping	Legal obligation	2.5 years, after which they are to be destroyed 6 years for ES and DE	After termination of contract	Financial systems: SUN, ERP - Unit4	Finance
Payroll Calculation	Financial record keeping	Legal obligation	10 years in order to fulfil obligations under the Companies Act 4 years for ES	Immediate at creation of record	Dakar, Google Drive, Emails	Finance & Payroll
Procurement Records (includes supplier IBAN, supplier address, supplier details, supplier invoices, supplier agreements)	Financial record keeping	Legal obligation	10 years, after which they are to be destroyed 5 years for GIB 6 years for ES 6 years for DE	Immediate at creation of record	Soft copies are saved on V: and hard copies are stored in cabinets in our office Agreements on Confluence	Finance & Legal
Accounting Records	Financial record keeping	Legal obligation	10 years, after which they are to be destroyed 5 years for GIB 6 years for ES	Immediate at creation of record	Soft copies are saved on V: and hard copies are stored in cabinets in our office	Finance
Inventory Records	Financial record keeping	Legal obligation	10 years, after which they are to be destroyed 5 years for GIB	Immediate at creation of record	We don't store this
Yearly Financial Statements	Financial record keeping	Legal obligation	10 years, after which they are to be destroyed 5 years for GIB 6 years for ES	Immediate at creation of record	Soft copies are saved on V: and hard copies are stored in cabinets in our office.	Finance

HR Data Retention Periods:

Data Item	Duration (as per below except for ES as it should be 4 years)	Reason	Where are these stored?	Owner
Name & Surname (including preferred name)	Permanent Regularly 6 years in DE, however no longer than 10 years	Cap. 594 requires every employer to provide to Jobsplus a list of employees who were in his employ at any given time as required by the Corporation. No time limit specified by law. S.L. 452.83 states it shall be the duty of the employer to furnish the Director for Employment and Industrial Relations (DIER) with any information which the Director may request. No time limit specified by law.	BambooHR, Engagedly	Employee Experience
Residential Address	Permanent; Regularly 6 years in DE, however no longer than 10 years	Cap. 594 requires every employer to provide to Jobsplus a list of employees who were in his employ at any given time as required by the Corporation. No time limit specified by law. S.L. 452.83 states it shall be the duty of the employer to furnish the Director for Employment and Industrial Relations (DIER) with any information which the Director may request. No time limit specified by law.	BambooHR	Employee Experience
Email addresses (personal + work)	12 months after termination or resignation	Business Legitimate Interest	BambooHR, Engagedly	Employee Experience
Telephone (personal mobile + work mobile) (DO NOT RETAIN HOME NUMBER)	12 months after termination or resignation	Business Legitimate Interest	BambooHR	Employee Experience
D.O.B	Permanent Regularly 6 years in DE, however no longer than 10 years	Cap. 594 requires every employer to provide to Jobsplus a list of employees who were in his employ at any given time as required by the Corporation. No time limit specified by law. S.L. 452.83 states it shall be the duty of the employer to furnish the Director for Employment and Industrial Relations (DIER) with any information which the Director may request. No time limit specified by law.	BambooHR	Employee Experience
Nationality/ Citizenship	6 years after termination	Cap. 594 provides that offences under the Act are barred by prescription of six years. Since employing someone without a permit is an offence under the Act, proof of nationality (lack of need of permit) required for six years.	BambooHR	Employee Experience
Bank Account Details	12 months after termination or resignation	Business Legitimate Interest	BambooHR	Employee Experience
National Insurance and Social Security Number	16 years from termination or resignation Regularly 6 years in DE, however no longer than 10 years	CIR has eight years to raise assessment, and eight further years to claim payment.	BambooHR	Employee Experience
Tax Number	16 years from termination or resignation	CIR has eight years to raise assessment, and eight further years to claim payment.	BambooHR	Employee Experience
Health (accident & incident reports; maternity risk assessments; workstation assessments)	6 years after termination or resignation For DE between 12 months and maximum 5 years, depending on the duration of the sickness – see comment *NB:* If there are employees in DE, this should be regularly 6 years, however no longer than 10 years after the termination or resignation of the employees in DE	Cap 424 contains a prescriptive period of six years for health and safety offences.	BambooHR	Employee Experience
Images/ Employee Photos + photo/video consent	12 months after termination or resignation	Business Legitimate Interest	BambooHR	Employee Experience
ID Card Number (do not retain a scan of front and back in the documents)	Permanent Regularly 6 years in DE, however no longer than 10 years	Cap. 594 requires every employer to provide to Jobsplus a list of employees who were in his employ at any given time as required by the Corporation. No time limit specified by law. S.L. 452.83 states it shall be the duty of the employer to furnish the Director for Employment and Industrial Relations (DIER) with any information which the Director may request. No time limit specified by law.	BambooHR	Employee Experience
Passport	6 years after termination or resignation	Cap 594 provides that offences under the Act are barred by prescription of six years. Since employing someone without a permit is an offence under the Act, proof of nationality (lack of need of permit) required for six years.	BambooHR	Employee Experience
Education/Training	5 years after termination or resignation Regularly 6 years in DE	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR	Employee Experience
Signed Employment Contract	5 years after termination or resignation Regularly 6 years in DE	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR	Employee Experience
CVs of employee	5 years after termination or resignation	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR	Employee Experience
CVs of persons who were not employed (including any other applicant data)	6 months after non-selection	Claim can be brought by prospective employee until 4 months after being informed of non- selection. CVs to be discarded after 6 months unless consent to hold further is available.	BambooHR	Employee Experience
Reference details (Name, Surname, title, contact number, and email address)	5 years after termination	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR	Employee Experience
Annual Appraisals	5 years after termination or resignation	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR, Engagedly	Employee Experience
Employee Status	16 years from termination or resignation 6 years in DE	CIR has eight years to raise assessment, and eight further years to claim payment.	BambooHR	Employee Experience
Work Permit	6 years after termination or resignation 5 years in DE	Cap. 594 provides that offences under the Act are barred by prescription of six years. Since employing someone without a permit is an offence under the Act, work permit to be retained for six years.	BambooHR	Employee Experience
Injury on Duty Reports	6 years from injury Maximum 5 years for DE depending on the seriousness and consequences of the injury (length of the sickness absence)	Cap 424 contains a prescriptive period of six years for health and safety offences.	BambooHR	Employee Experience
Written Warnings	5 years after termination or resignation	Cap 16 provides that most civil suits must be filed within a maximum of five years. It may be necessary to prove the competence of an employee to defend a civil suit, and therefore keeping this information for five years is justified.	BambooHR	Employee Experience
Sick Leave Certificates	2 years from sick leave For DE depending on the duration of the sickness-leave between 12 months and max. 5 years. If the injury led to a sickness-absence of less than 6 weeks, then a deletion should take place after 12 months. A longer period is only permissible, if the injury led to a sickness-absence for more than 6 weeks.	Business Legitimate Interest Until the age of 75, after which they are to be destroyed - based on work- related long-term illness.	BambooHR	Employee Experience
Vacation Leave Cards/Data	4 years 3 years for DE	After which they are to be destroyed	BambooHR	Employee Experience
T-shirt/hoodie size	1 month from termination of employment		BambooHR	Employee Experience
Job Plus Employment and termination documents	5 years after termination of employment 6 years for DE		BambooHR	Employee Experience
FS3 financial statements and FS4 tax documents	16 years from termination/ resignation No longer than 10 years for DE	8+8 years from termination or resignation as CIR has eight years to raise assessment, and eight further years to claim payment.	BambooHR	Employee Experience
Compensation (Effective date, pay rate, pay type, pay schedule)	5 years in HR system 10 years in payroll system For DE 10 years in both systems.	Such records (in the HR system) should be kept for a period of 5 years in line with the prescriptive periods allowed under civil law in Malta. On the other hand, similar detailed data within the payroll system should be kept for a period of 10 years in order to fulfil obligations under the Companies Act.	BambooHR	Employee Experience
Allowances (Date, allowance type, amount, comment)	5 years in HR system 10 years in payroll system 6 years for DE	Such records (in the HR system) should be kept for a period of 5 years in line with the prescriptive periods allowed under civil law in Malta. On the other hand, similar detailed data within the payroll system should be kept for a period of 10 years in order to fulfil obligations under the Companies Act.	BambooHR	Employee Experience
Emergency contacts (name, relationship, phone, email, address)	1 month from termination of employment		BambooHR	Employee Experience
Time off balance	2.5 years after termination of employment 3 years for DE	Time taken for vacation, sick, study etc, then this data (in detail, dates, days etc) could be retained for a period of 2.5 years after termination of employment. However, the Company may then aggregate the data to retain as statistics (without being able to refer back to the individual) which may be kept indefinitely.	BambooHR	Employee Experience
Last Payslip or FS3 from previous employment	To be deleted after n+2 years	Payslips are required to calculate the tax for the first payment.	BambooHR	Employee Experience
Police conduct (To be retained only for selected employees)	Do not store this data except for legal, directors and key function holders until expired for due diligence purposes	To retain only for legal, directors and key function holders until expired in order to respond to DD requests.	BambooHR	Employee Experience

Version: 1.5
Last updated: 27/11/24

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Jocularis Ltd is licensed by the Government of Gibraltar (Remote Gaming Licences no 126 and 127) and regulated by the Gibraltar Gambling Commissioner. Jocularis Limited is registered in Gibraltar with company registration number 121395 and its operational office address is situated at Suite 5B, Watergardens 1, Gibraltar. Gambling can be addictive. Please play responsibly. Our products are solely intended for individuals over 18 years of age. If you need support in relation to your gambling habits you find more information at Gambling Therapy. Read more about Play Okay.