Data Retention Policy

Last update date: 7 August 2026

This policy explains how Happy Leads Ltd retains, reviews, stores, archives, and disposes of data in a responsible and compliant way.

1. About this policy

This policy explains how Happy Leads Ltd retains, reviews, stores, and disposes of information connected with The Reward website and related campaign registrations.

The objective is to keep information no longer than necessary while preserving records required for lawful operations, accountability, dispute handling, and regulatory compliance.

2. Scope of this policy

It applies to personal and non-personal data across registration systems, support records, technical logs, analytics outputs, compliance files, and other operational records, whether stored electronically or in physical form.

It also applies to data hosted by approved third-party providers acting on our behalf under relevant contractual controls.

3. Guiding principles

Retention decisions are made by balancing operational need, legal obligations, risk management, and the rights of individuals.

4. Roles and responsibilities

Happy Leads Ltd is responsible for determining and reviewing retention periods. Operational, compliance, and technical teams may share responsibilities for retention and secure disposal decisions.

Teams responsible for data systems should support scheduled review, archive controls, and deletion workflows in line with this policy.

5. Types of data covered

6. Retention periods

Retention periods are determined by purpose, sensitivity, legal requirements, fraud prevention needs, evidence requirements, and operational necessity.

Registration and campaign data may be retained for administration, validation, compliance, and analytics for as long as reasonably necessary. Marketing consent and suppression records may be retained for extended periods to demonstrate compliance and respect user preferences.

Financial and contractual records may be retained in line with statutory accounting, tax, and audit requirements. Temporary working files should be removed once no longer needed.

7. Storage, backup, and disposal

Data is stored in controlled systems with access restrictions and backup processes. Where data is no longer required, it is deleted, anonymised, or securely destroyed, subject to any lawful hold.

Backup copies may persist for continuity and recovery purposes for a limited period after live data changes, with retention controls applied to backup environments.

Disposal methods may include secure deletion, controlled overwrite, anonymisation, or physical destruction of documents where applicable.

8. Special circumstances and preservation holds

Deletion schedules may be paused where data is required for legal claims, audits, investigations, security incidents, or regulatory requests.

Where a hold applies, relevant records are preserved until the hold is formally released.

9. Data subject rights and retention decisions

Rights requests are assessed under applicable law. Where deletion cannot be completed due to legal or compliance reasons, we may restrict use, archive securely, or retain only the minimum required information.

Where practical and lawful, information no longer required may be anonymised so it cannot be linked back to an identifiable individual.

10. Monitoring, review, and audit

We periodically review the data we hold, retention periods, and disposal controls to ensure continued proportionality and compliance.

Review outcomes may lead to updated retention schedules, process changes, or additional internal controls.

11. Contact us

For retention or data rights queries, contact support@thereward.co.uk.

Happy Leads Ltd, Office 1315 182-184 High Street North, Area 1/1, East Ham, London, United Kingdom, E6 2JA
ICO registration number: ZB877062