Data Retention & Deletion Policy

1. Introduction

This Data Retention & Deletion Policy explains how Mentor to Marry, operated by Love, Dating and Marriage Ministries, retains, reviews, deletes, anonymises and preserves personal information and platform records.

Mentor to Marry is a global interdenominational Christian relationship, dating, marriage education, community and matching platform for Christians aged 25 and over.

This Policy supports the responsible handling of information connected with account registration, member profiles, matching features, messaging features, community participation, course access, live sessions, safeguarding concerns, reports and complaints, moderation, payments and subscriptions, verification, platform security, legal compliance and platform administration.

This Policy should be read alongside the Privacy Policy, Terms of Use, Membership & Subscription Terms, Refund & Cancellation Policy, Safeguarding & Community Safety Policy, Profile Standards Policy, Matching Platform Terms, Messaging & Communications Policy, Reporting & Complaints Policy, Account Suspension & Enforcement Policy and any internal data protection, safeguarding or moderation procedures adopted by Mentor to Marry.

2. Purpose of This Policy

The purpose of this Policy is to explain how long information may be kept, support privacy and data protection compliance, reduce unnecessary retention of personal information, support safe deletion or anonymisation, preserve records where needed for safety, safeguarding or legal purposes, support consistent handling of account deletion requests, protect members and the platform from fraud, abuse and misuse, support complaint handling and moderation, support responsible evidence preservation and provide a framework for future internal retention schedules.

Mentor to Marry aims to retain information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer period is required or justified by law, safety, safeguarding, fraud prevention, dispute resolution, enforcement, accounting, tax, platform security or legitimate operational needs.

3. Storage Limitation Principle

Mentor to Marry recognises that personal information should not be kept indefinitely without a proper reason.

Where personal information is no longer reasonably needed, Mentor to Marry may delete it, anonymise it, restrict access to it, archive it securely, aggregate it so that individuals are no longer identifiable or retain it only where a lawful or legitimate reason remains.

Retention decisions may take account of the purpose for which the data was collected, the type of information, member expectations, legal obligations, safety and safeguarding concerns, fraud prevention needs, complaint or dispute history, moderation history, payment and accounting requirements, technical limitations and platform integrity.

4. Information Covered by This Policy

This Policy may apply to account information, registration information, login and security information, profile information, profile photographs, sex at birth, marital status, church or regular place of Christian fellowship, location information, matching preferences, likes and matches, recommendation information, messaging data, message metadata, community posts, course progress, live session participation, membership and subscription information, payment and transaction records, refund and cancellation records, verification information, reports and complaints, safeguarding records, moderation notes, enforcement decisions, appeals, technical logs, cookie and analytics information, support correspondence and legal or administrative records.

This list is not exhaustive.

5. Retention Principles

Mentor to Marry will seek to apply the principles of necessity, purpose, proportionality, safety, accountability, security, review, deletion and anonymisation.

Information should be retained only for as long as reasonably necessary and retention should be linked to the purpose for which information is used. Retention should be proportionate to the sensitivity and risk of the information. Information may be retained where necessary to protect users, investigate concerns or prevent harm. Retention decisions should be capable of explanation and review. Retained information should be protected by reasonable technical and organisational measures. Information should be reviewed periodically where appropriate. Information no longer needed should be deleted, anonymised or otherwise handled appropriately.

6. Data Retention Schedule

Mentor to Marry may maintain a separate internal Data Retention Schedule.

The Data Retention Schedule may set out categories of information, reasons for retention, standard retention periods, review points, deletion methods, anonymisation methods, exceptions, responsible persons and escalation requirements.

The Data Retention Schedule may be updated from time to time to reflect legal requirements, operational needs, safeguarding learning, complaints experience, platform growth, new features, payment provider requirements, verification systems, security needs and technical arrangements.

Where this Policy gives a general principle and the Data Retention Schedule gives more detailed operational guidance, the Data Retention Schedule may be used internally to guide practical retention decisions.

7. Indicative Retention Table

The following table is an indicative operational guide only. It does not create fixed legal retention periods. Actual retention may vary depending on applicable law, user location, payment provider requirements, safeguarding requirements, legal obligations, operational needs and the circumstances of the record.

This table is intended to support consistent administration and should be read alongside the Privacy Policy, this Policy and any internal Data Retention Schedule.

8. Account Information

Account information may be retained while an account remains active. This may include name, email address, phone number, login credentials, account settings, membership status, subscription status, account creation date, communication preferences, security information and account activity.

After account closure or deletion, some account information may be retained where necessary for legal compliance, fraud prevention, safeguarding, complaint handling, moderation records, enforcement records, payment records, dispute resolution, security or legitimate operational purposes.

9. Profile Information

Profile information may be retained while a profile is active. This may include first name, age, sex at birth, marital status, country, city, church or regular place of Christian fellowship, profile photograph, biography content, relationship intentions, preferences and other profile fields.

Where a member updates or deletes profile information, Mentor to Marry may still retain previous versions where necessary for safety, safeguarding, fraud prevention, moderation, complaint handling, evidence preservation, dispute resolution or legal compliance.

For example, previous profile information may be retained where there are concerns about catfishing, marital status deception, fake profiles, harassment, safeguarding or fraud.

10. Profile Photographs and Identity-Related Information

Profile photographs and identity-related information may be retained while needed for profile display, verification, safety, moderation or fraud prevention.

Mentor to Marry may retain photographs or identity-related information where necessary to investigate impersonation, fake profiles, catfishing, use of another person’s image, misleading profile activity, verification misuse, safeguarding concerns or enforcement matters.

Where identity verification is introduced, verification-related records may be retained for as long as necessary for safety, fraud prevention, identity review, dispute handling, compliance or moderation purposes.

11. Matching and Recommendation Information

Matching and recommendation information may include likes, matches, profile views, preferences, visibility information, recommendation signals, blocked profiles, reported profiles, safety settings, membership tier, course completion status, verification status and interaction patterns.

This information may be retained for purposes including providing matching services, improving recommendations, enforcing platform rules, preventing misuse, investigating reports, managing safety risks and maintaining platform integrity.

Where information is no longer needed in identifiable form, Mentor to Marry may delete or anonymise it.

12. Messaging and Communication Records

Mentor to Marry may retain messages, message metadata, reports, moderation notes and communication records where necessary for service delivery, safety, safeguarding, fraud prevention, complaint handling, moderation, enforcement, dispute resolution, legal compliance, security or platform integrity.

Deleting a message, conversation or account may not immediately delete all communication records where retention is necessary and lawful.

Messages may be preserved where they relate to harassment, threats, abuse, fraud, financial requests, spiritual manipulation, safeguarding concerns, inappropriate content, repeated unwanted contact, account misuse or enforcement action.

13. Community, Course and Live Session Records

Mentor to Marry may retain information relating to community posts, course participation, course progress, lesson completion, live session attendance, event participation, comments, group discussions, moderation history and user contributions.

Such records may be retained for providing course access, confirming completion, issuing badges, managing community spaces, responding to complaints, safeguarding, moderation, platform improvement, legal or operational purposes.

Where a user deletes an account, some community content, comments, discussion records or replies may be retained, removed, anonymised or attributed differently depending on platform functionality, legal requirements, safety needs and moderation considerations.

Where appropriate, inactive or outdated community content may be archived, removed or anonymised.

14. Payment, Subscription and Refund Records

Mentor to Marry may retain payment, subscription, refund and cancellation records where necessary for billing, subscription management, accounting, tax, fraud prevention, chargebacks, payment disputes, refund assessment, legal compliance, financial records and audit purposes.

Payment card details may be handled by third-party payment providers and may not be stored by Mentor to Marry unless expressly stated.

Refund and cancellation records may be retained to support dispute resolution, fraud prevention, account administration, chargeback handling and compliance with the Refund & Cancellation Policy.

15. Reports, Complaints and Safeguarding Records

Reports, complaints and safeguarding records may be retained for longer than ordinary account information where necessary.

This may include records relating to harassment, bullying, fake profiles, catfishing, financial exploitation, romance scams, safeguarding concerns, suspected underage use, threats, abuse, coercion, misconduct, privacy breaches, moderator or volunteer misconduct, enforcement decisions, appeals and protective actions.

Retention may be necessary to protect members, prevent repeat harm, identify patterns of behaviour, respond to complaints, support investigations, preserve evidence, defend legal claims, comply with law and maintain platform integrity.

16. Moderation and Enforcement Records

Mentor to Marry may retain moderation and enforcement records, including warnings, restrictions, suspensions, terminations, appeal outcomes, internal notes, evidence, investigation records and risk assessments.

Such records may be retained where necessary to prevent repeat offences, identify evasion attempts, manage banned users, protect members, respond to appeals, support safeguarding, investigate fraud, maintain consistency and defend platform decisions.

Account deletion or data deletion requests do not automatically reverse moderation decisions, suspensions, restrictions, bans or enforcement outcomes.

Mentor to Marry may retain limited information about suspended, banned or removed users where necessary to prevent re-registration, evasion of enforcement or repeated harm.

17. Technical Logs, Security and Fraud Prevention

Mentor to Marry may retain technical and security information such as IP addresses, login records, device information, error logs, security logs, cookie identifiers, suspicious activity signals, blocked activity and platform usage records.

Such information may be retained for account security, fraud prevention, abuse detection, platform integrity, troubleshooting, cyber security, moderation, legal compliance and safeguarding.

Technical logs may be retained for shorter or longer periods depending on the type of log, security purpose and technical configuration.

18. Cookies and Analytics Information

Cookie and analytics information may be retained in accordance with the Cookie Policy, Privacy Policy, platform settings and applicable law.

Where cookie or analytics information identifies or may identify a user, it should be handled as personal information.

Where reasonably appropriate, analytics data may be aggregated or anonymised.

19. Account Deletion Requests

Users may request account deletion through available platform processes or by contacting Mentor to Marry.

Account deletion may result in loss of access to profile features, membership benefits, course progress, messages, matches, badges, community spaces, subscriptions and platform services.

However, account deletion does not necessarily delete all information immediately.

Mentor to Marry may retain information where necessary for legal compliance, payment records, fraud prevention, safeguarding, complaint handling, moderation records, enforcement records, dispute resolution, security, legitimate operational purposes or protection of another person’s rights.

Users should cancel any recurring subscription before deleting their account.

20. Deletion of Inactive Accounts

Mentor to Marry may introduce processes to review, restrict, archive or delete inactive accounts.

An account may be treated as inactive based on factors such as lack of login activity, expired membership, prolonged non-use, unverified status, incomplete registration, unpaid subscription or platform rules.

Before deleting inactive accounts, Mentor to Marry may provide notice where appropriate, unless immediate deletion, restriction or preservation is required for legal, safety, security or operational reasons.

21. Archived, Restricted and Suspended Accounts

Some accounts may be archived, restricted or suspended rather than immediately deleted.

This may occur where a member is under investigation, safeguarding concerns exist, fraud is suspected, payment disputes are active, moderation action is pending, legal issues exist, account recovery is possible or deletion would undermine safety or evidence preservation.

Archived or restricted accounts may have limited visibility or access.

22. Legal Holds and Evidence Preservation

Mentor to Marry may place information on legal hold or safety hold where deletion should be paused.

This may occur where information is relevant to safeguarding concerns, harassment, fraud, financial exploitation, catfishing, identity deception, disputes, chargebacks, investigations, complaints, enforcement, legal claims, regulatory requests or law enforcement requests.

Where a legal hold or safety hold applies, information may be retained until the matter is resolved or retention is no longer necessary.

23. Deletion, Anonymisation and Aggregation

Where information is no longer needed in identifiable form, Mentor to Marry may delete it, anonymise it, aggregate it, restrict access, archive it securely or remove identifying elements.

Anonymised or aggregated information may be retained for statistical analysis, platform improvement, safety trend analysis, service development, reporting, governance or research-style internal learning.

Information is not treated as personal information if it has been properly anonymised so that individuals are no longer identifiable.

24. User Rights and Deletion Requests

Depending on applicable law, users may have rights to request deletion, access, correction, restriction, objection, portability or withdrawal of consent.

Requests may be subject to identity verification.

Mentor to Marry may refuse or limit deletion requests where retention remains necessary for legal compliance, fraud prevention, safeguarding, safety, complaint handling, dispute resolution, moderation records, enforcement records, security or protection of another person’s rights.

Further information is set out in the Privacy Policy.

25. Backups and Technical Limitations

Deleted information may remain temporarily in backups, logs or technical systems before being fully overwritten or removed.

Mentor to Marry may not be able to remove all copies immediately from backup systems.

Where information remains in backups, Mentor to Marry will seek to ensure that it is protected and not actively used except where restoration, security, legal, safeguarding or operational needs require it.

26. Third-Party Service Providers

Mentor to Marry may use third-party providers for hosting, payments, course delivery, email, analytics, verification, community tools, customer support, video hosting, mobile app services, security and other operational purposes.

Third-party providers may have their own retention practices, legal obligations and technical processes.

Mentor to Marry will seek to use providers that support responsible data handling, but some deletion, retention or backup processes may depend on the relevant provider’s systems and terms.

27. Security of Retained Information

Mentor to Marry will seek to protect retained information using reasonable technical and organisational measures. These may include access controls, password protection, role-based access, secure hosting, confidentiality expectations, restricted access to sensitive records, secure recordkeeping, incident response processes and review of access where appropriate.

Access to retained safeguarding, complaint, moderation and enforcement records should be limited to authorised persons who need access for safety, governance, legal, operational or platform-integrity purposes.

No system can guarantee absolute security.

28. Retention Reviews

Mentor to Marry may review retained information periodically to determine whether it remains necessary.

Reviews may consider whether the purpose still exists, whether legal obligations remain, whether safeguarding concerns remain, whether complaints or disputes are active, whether fraud prevention requires retention, whether data can be anonymised, whether records can be securely deleted and whether access should be restricted.

29. Responsibility for Retention Decisions

Responsibility for retention decisions may sit with authorised leadership, a privacy contact, a safeguarding lead, platform administrators, legal or governance advisers or other persons designated by Love, Dating and Marriage Ministries.

Where a decision involves safeguarding, serious complaints, enforcement or legal risk, the matter may be escalated to appropriate internal decision-makers.

30. International Users and Cross-Border Storage

Mentor to Marry serves users internationally.

Information may be stored, processed or accessed in different countries depending on hosting arrangements, service providers, payment systems, learning platforms, app services and operational needs.

Retention periods and deletion processes may vary depending on applicable law, user location, payment provider requirements, safeguarding requirements, legal obligations and operational needs.

Cross-border processing will be handled in accordance with the Privacy Policy and applicable data protection requirements.

31. Policy Conflicts

Where this Policy overlaps with another Mentor to Marry policy, Mentor to Marry may apply the policy or provision most relevant to the issue.

For example, safeguarding concerns may require longer retention than ordinary account records, fraud concerns may require retention of payment and technical records, account deletion requests may be limited by unresolved complaints or investigations and legal obligations may override standard deletion timeframes.

32. No Immediate Deletion Guarantee

Mentor to Marry will seek to handle deletion requests responsibly.

However, Mentor to Marry does not guarantee immediate deletion of all data where legal requirements apply, safeguarding records are required, complaints remain unresolved, moderation records are needed, fraud prevention requires retention, payment disputes remain active, backup systems are involved or technical limitations apply.

33. Changes to This Policy

Mentor to Marry may update this Data Retention & Deletion Policy from time to time.

Updates may be made to reflect legal developments, platform changes, safeguarding learning, new systems, retention schedule updates, service provider changes, data protection guidance or operational needs.

Updated versions may be published on the website or platform.

34. Contact

Questions about this Policy or requests relating to retention or deletion should be directed to Mentor to Marry through the contact details published on the website or platform.

Urgent safeguarding or safety concerns should be reported through the appropriate reporting or safety channels.

Data Retention & Deletion Acknowledgement

By using Mentor to Marry, members acknowledge that:

Mentor to Marry may retain information for as long as reasonably necessary for the purposes described in this Policy;

account deletion does not automatically remove all records immediately;

some records may be retained for legal, safeguarding, complaint handling, fraud prevention, enforcement or security reasons;

messages, reports and moderation records may be preserved where necessary;

payment and subscription records may be retained for accounting, refund, chargeback or legal purposes;

information may remain temporarily in backups or technical systems;

anonymised or aggregated information may be retained for platform improvement or governance purposes;

third-party providers may have their own retention processes;

deletion requests may be refused or limited where retention remains necessary and lawful;

account deletion or data deletion requests do not automatically reverse moderation decisions or enforcement outcomes;

limited records may be retained to prevent re-registration, enforcement evasion or repeated harm; and

users should cancel recurring subscriptions before deleting their accounts.