Silverchair Publisher Site Traffic Data Retention Policy 

Policy Version: 1.0
Effective Date: January 1, 2025
Policy Owner: Lily Garcia Walton, Chief People Officer + General Counsel 

1. Purpose: The purpose of this Data Retention Policy is to establish the obligations of Silverchair during the term of the customer’s subscription regarding the retention and deletion of site traffic data (including Silverchair proprietary analytics reports and COUNTER data) collected through the Silverchair platform. This policy ensures that Silverchair handles site traffic data responsibly, complies with applicable laws and regulations, and meets the needs of our customers and users. 
2. Scope: This policy applies to all site traffic data generated or collected by the Silverchair Platform reflecting user interactions with a publisher website. It includes data related to user interactions with publisher content collected in the normal course of site operations. This policy does not include data unrelated to site traffic (examples: order confirmation data, user profile data, ecommerce data, or PPV data).  
3. Data Retention Period: Unless a different retention period is contractually required, Silverchair will retain site traffic data for a period of three (3) calendar years after the calendar year in which it was collected, not to exceed a total retention period of four (4) years (the “Retention Period”). Once data exceeds this Retention Period, it will be considered outside the scope of active retention and will be subject to deletion unless Silverchair is legally required to retain the data. 
4. Deletion Schedule: At the commencement of each calendar year, the site traffic data collected prior to the three previous (3) historical calendar years will be systematically wiped from Silverchair’s active databases unless Silverchair is legally required to retain the data. This process will occur annually to ensure compliance with the Retention Period defined in section 3. 
5. Publisher Responsibility: Publishers using the Silverchair platform are responsible for downloading and storing any site traffic data they wish to retain beyond the Retention Period outlined above. It is the sole responsibility of the publisher to take necessary action before the start of each calendar year to preserve their data. Silverchair will not be responsible for retaining site traffic data once it has aged out of the retention window. 
6. Retention Following Termination: Upon termination of a Publisher’s contractual relationship with Silverchair, site traffic data in Silverchair’s production environment will be retained for 30 days, and site traffic data from files created for security, backup, or business continuity purposes will be retained for 90 days.  
7. Compliance and Monitoring: Silverchair will ensure internal compliance within Silverchair with this Data Retention Policy and will conduct periodic reviews to monitor that the policy is being implemented effectively. 
8. Amendments: This policy may be amended or updated at Silverchair’s discretion. However, Silverchair will not modify its default Retention Period without giving then-existing customers notice. 
9. Contact Information: For questions or concerns regarding this Data Retention Policy, please contact legal@silverchair.com. 

By using the Silverchair platform, publishers acknowledge and agree to this Data Retention Policy. It is the publisher’s responsibility to ensure that they have made necessary arrangements to retain their own data in accordance with their needs and legal obligations. 

This Data Retention Policy is effective as of the Effective Date and supersedes all previous data retention policies and practices regarding the Silverchair Platform.