Last updated: November 11, 2026

This Data Retention Policy explains how long Egan-Jones Ratings Company ("Egan-Jones", "we" or "us") keeps personal information collected through our websites, client platforms and services, and what happens to it afterwards. It supplements our Privacy Policy.

1. Principles

  • We keep personal information only for as long as we need it for the purposes for which we collected it, or for as long as the law, a regulator or a contract requires.
  • In setting each retention period, we consider the type and sensitivity of the information, why we hold it, our clients' needs, the risk of harm from unauthorized use, and legal, regulatory, tax and accounting requirements, including the record-keeping rules that apply to our business.
  • When a retention period ends, we delete the information or anonymize it so that it no longer identifies anyone. Where immediate deletion is not possible, we keep the information secure and out of use until it can be deleted.

2. Retention periods

The periods below are our standard practice. Each is subject to the exceptions in section 3.

  • Inquiries, requests and meeting bookings. Kept while we respond and follow up. If no client relationship results, we delete or anonymize them no later than five years after our last interaction with you.
  • Marketing lists. Subscriptions are kept until you unsubscribe. Business contact information we hold for marketing is reviewed periodically, removed when it is no longer accurate or relevant, and in any case deleted no later than five years after our last interaction with you. If you unsubscribe or ask us not to contact you, we keep your email address on a suppression list for as long as needed to honor that request.
  • Client account and user information. Kept for the duration of the client relationship and afterwards for as long as the client agreement or the law requires. When a client removes a user, that user loses access, and records of the user's activity are kept with the client's other records.
  • Client service records. Information clients provide and records of the work we perform for them are kept for the term of the client agreement and afterwards for the period the client agreement or applicable regulations require.
  • Ratings, research and supporting materials. Our ratings, research and reports, including the publicly available information about individuals they contain, and the data and analysis behind them, are kept as business records for as long as needed to document their basis, to handle questions and corrections, and to meet legal and regulatory requirements.
  • Communications. Business correspondence, support requests and any recordings or transcripts of calls and meetings are kept in line with our record-keeping obligations and for as long as needed for the purposes for which they were made.
  • Billing and financial records. Kept for the periods required by tax and accounting rules.
  • Job applications. Kept for the duration of the hiring process and afterwards for the period required by employment laws, or longer if you agree that we may consider you for future roles. Background check reports are kept confidential and are seen only by the people involved in the hiring process. Information about candidates we hire becomes part of their employment records.
  • Website logs and analytics. Kept for a limited period for security, troubleshooting and measuring traffic. Aggregated statistics that do not identify anyone may be kept longer.
  • Platform security and audit logs. Kept for as long as needed to protect our platforms, investigate incidents and support audit and record-keeping needs.

3. Exceptions

  • Legal holds. We suspend deletion of information relevant to actual or reasonably anticipated litigation, regulatory examinations, investigations or other legal proceedings until the matter is resolved.
  • Legal and regulatory requirements. Where a law or regulator requires us to keep information for longer than the period above, we keep it for the required period.
  • Backups. Deleted information may remain in secure backups until those backups are overwritten in the normal cycle. We restore information from backups only to recover from an outage or data loss, and if we do, we take steps to delete again any information that had already been deleted.
  • Anonymized information. Information that has been anonymized or aggregated so that it no longer identifies anyone may be kept without time limit.

4. Service providers

Our service providers handle personal information on our behalf and delete or return it at the end of their services, in line with their contracts with us and their own legal obligations.

5. Requests to delete information

You may ask us to delete personal information about you by emailing compliance@egan-jones.com. We will do so unless we need to keep the information for a reason set out in this policy or permitted by law, such as meeting a record-keeping obligation or establishing or defending legal claims. If we cannot delete information, we will tell you why. Our Privacy Policy explains your other rights and how we verify requests.

Where we hold information on behalf of a client, we handle deletion requests with that client, which decides how long its records are kept under its agreement with us.

6. Review

We review this policy periodically and whenever our services, systems or legal obligations change. We will post any updates and change the "Last updated" date.

7. Contact us

Questions about this policy can be sent to compliance@egan-jones.com or to Egan-Jones Ratings Company, Attn: Compliance, 1120 Avenue of the Americas, 4th Floor, New York, NY 10036.