Data Retention Policy
Draft template — pending counsel review.
ArtVault Inc. retains personal data, transaction records, and supporting documentation only for as long as required for the purposes for which it was collected and to comply with applicable legal, regulatory, tax, and audit obligations. This policy summarises the standard retention periods we apply.
KYC / KYB Records
Identity verification documents, beneficial-ownership records, sanctions and PEP screening results, and source-of-funds documentation: retained for seven (7) years after the end of the customer relationship, consistent with U.S. Bank Secrecy Act and FinCEN customer-due-diligence recordkeeping requirements.
Loan Files
Executed loan agreements, security agreements, UCC filings, collateral appraisals, condition reports, custody and insurance records, payment ledgers, and default and remedy correspondence: retained for seven (7) years after loan payoff, charge-off, or final disposition of collateral.
Investor Records
Subscription documents, accreditation evidence, side letters, capital-call and distribution records, and tax forms (e.g., W-9, W-8 series, K-1, 1099): retained for seven (7) years after the investor's exit, consistent with SEC Investment Advisers Act recordkeeping requirements (Rule 204-2) and U.S. federal tax recordkeeping rules.
Financial and Accounting Records
General ledger, bank statements, wire confirmations, audit work papers, and financial statements: retained for seven (7) years from the close of the relevant fiscal year.
Marketing and Website Data
Inquiry emails, marketing-list opt-ins, and analytics logs not tied to a customer or investor account: retained for twenty-four (24) months from collection, unless a shorter or longer period is required by applicable law.
Legal Holds
Records subject to litigation, regulatory inquiry, subpoena, or other legal hold are retained until the hold is lifted, regardless of the standard period above.
Deletion
At the end of an applicable retention period, records are deleted, anonymised, or destroyed using commercially reasonable methods. Backups are purged on the next scheduled rotation.
Contact
Questions about data retention: info@artvault.fund.