Data Retention and Deletion Policy

Effective Date: December 2, 2025

Company Name: Fine Grain LLC

Company Address: 75 E 3rd St, Sheridan, WY 82801, United States

Website: https://www.branislavnenin.com/

Email: kontakt@branislavnenin.com

1. Purpose and Scope

This Data Retention and Deletion Policy explains how Fine Grain LLC retains,

manages, and deletes personal data collected through its website and during the

provision of its services.

This Policy applies to all personal data processed by the Company, including data

relating to website visitors, clients, photographed individuals, business contacts, and

vendors.

This Policy forms part of the Company’s broader data protection framework and should

be read together with the Privacy Policy.

2. Principles of Data Retention

Fine Grain LLC retains personal data only for as long as necessary to fulfill the

purposes for which the data was collected, including:

 Performance of contractual obligations

 Delivery of professional services

 Legal, accounting, and tax compliance

 Protection of legal rights and interests

 Business operations and record keeping

Data retention decisions are guided by the principles of necessity, proportionality, and

minimization.

3. Categories of Data and Retention Periods

Retention periods may vary depending on the nature of the data and applicable legal

requirements.

Typical retention practices include:

 Contact and inquiry data: retained for as long as necessary to respond to

inquiries and for a reasonable follow up period

 Client and booking records: retained for the duration of the business

relationship and thereafter as required for legal and accounting obligations

 Billing and transaction records: retained in accordance with applicable tax,

accounting, and financial regulations

 Photographic images: retained for delivery, archival, portfolio, or legal purposes

unless otherwise agreed or requested

 Website usage and technical data: retained for limited periods consistent with

analytics and security needs

Exact retention periods may be extended or reduced where legally required or justified

by legitimate business needs.

4. Archiving of Image Files

Delivered photographic images may be retained by the Company for a limited archival

period to:

 Facilitate re delivery if files are lost

 Support additional licensing requests

 Protect against legal claims or disputes

The Company does not guarantee indefinite storage of image files.

Clients remain responsible for maintaining their own backups of delivered materials.

5. Data Deletion and Anonymization

When personal data is no longer required for the purposes for which it was collected,

Fine Grain LLC will take reasonable steps to:

 Securely delete the data

 Anonymize the data where deletion is not feasible

Deletion methods may vary depending on the storage medium, technical constraints,

and applicable legal requirements.

6. Legal and Regulatory Exceptions

Certain data may be retained beyond standard retention periods where required by law

or where necessary to:

 Comply with legal obligations

 Respond to lawful requests from authorities

 Establish, exercise, or defend legal claims

In such cases, data will be retained only for as long as the legal basis applies.

7. Requests for Deletion

Where applicable under GDPR or comparable laws, individuals may request deletion of

their personal data.

Deletion requests are subject to verification of identity and assessment of applicable

legal obligations.

Requests may be refused or limited where retention is required by law or where deletion

would impair legal rights.

Requests should be submitted using the contact details provided below.

8. Data Security During Retention

Throughout the retention period, Fine Grain LLC applies reasonable technical and

organizational measures to protect personal data against unauthorized access, loss,

misuse, or disclosure.

Access to retained data is limited to authorized personnel and service providers.

9. Third Party Storage and Processing

Personal data may be stored or processed using third party service providers, including

cloud storage, hosting, and accounting systems.

Such providers are selected based on appropriate security and data protection

standards and are subject to contractual obligations.

10. Policy Review and Updates

Fine Grain LLC reviews this Data Retention and Deletion Policy periodically and

updates it as necessary to reflect changes in legal requirements or business practices.

Updated versions will be published on the website with an updated Effective Date.

11. Contact Information

For questions or requests related to data retention or deletion, please contact:

Fine Grain LLC

75 E 3rd St, Sheridan, WY 82801, United States

Website: https://www.branislavnenin.com/

Email: kontakt@branislavnenin.com