Data Retention & Destruction Policy
How long Immersive Realities retains data, and how it is securely destroyed or de-identified once no longer required. Last updated: 1 October 2026.
Document Reference: IR-POL-DRP-2026
Entity: Immersive Realities Pty Ltd (ACN 656 930 899)
Address: Level 2/161 Collins Street, Melbourne VIC 3000
Website: immreal.io
Effective Date: 1 October 2026
Jurisdiction: Commonwealth of Australia
Regulatory Alignment: Privacy Act 1988 (Cth), Australian Privacy Principles (APPs, specifically APP 11), Privacy and Other Legislation Amendment Act 2024 (Cth), Corporations Act 2001 (Cth), Income Tax Assessment Act 1997 (Cth).
1. Purpose and Scope
Immersive Realities Pty Ltd ("Immersive Realities", "we", "us", "our") designs, builds, and deploys AI, digital twin, and extended reality (XR) systems for enterprise, including spatial computing and virtual/augmented reality platforms, delivered via our website and related services at immreal.io. This Data Retention Policy defines the requirements for retaining, de-identifying, and securely destroying data collected or processed across our platforms.
Under Australian Privacy Principle 11.2 (APP 11.2) and modernised Australian privacy standards, an entity must take reasonable steps to destroy or permanently de-identify personal information if it no longer needs the information for any purpose for which it may be used or disclosed, and is not required by Australian law or a court/tribunal order to retain it.
This policy applies to:
- All employees, contractors, and third-party vendors of Immersive Realities.
- All digital personal data, spatial/extended reality (XR) telemetry, session telemetry, user account data, financial records, and operational logs collected through immreal.io and associated software.
2. Statutory and Compliance Obligations
Immersive Realities retains data strictly in accordance with statutory minimum and maximum limits mandated by Australian Commonwealth and State laws:
- Privacy Act 1988 (Cth) & APPs: Mandates that personal information, including spatial telemetry and biometric identifiers, be retained only as long as necessary for legitimate business or legal purposes.
- Privacy and Other Legislation Amendment Act 2024 (Cth): Restricts over-retention practices, enforces explicit de-identification standards, and subjects organisations to civil penalties and individual statutory privacy tort actions for deliberate or negligent over-retention leading to privacy breaches.
- Corporations Act 2001 (Cth) & Income Tax Assessment Act 1997 (Cth): Requires financial, transactional, and tax records to be retained for a minimum of seven (7) years.
- Fair Work Act 2009 (Cth): Mandates retention of employee personnel and payroll records for seven (7) years post-employment.
3. Data Classification and Retention Schedule
Data collected via immreal.io and associated services is classified into specific categories, each subject to defined retention periods and disposal mechanisms:
| Data category | Description & examples | Retention period | Action upon expiry |
|---|---|---|---|
| Account & Identity Data | Name, email address, physical address, user credentials, account preferences. | Duration of active account plus 12 months post-deactivation. | Permanent digital destruction / cryptographic erasure. |
| Spatial & XR Telemetry Data | Head/hand positioning, spatial anchor coordinates, mesh mapping data, render pipeline metrics. | 30 days in raw format. Aggregated performance metrics retained up to 12 months (non-identifiable). | Automated purge of raw logs; permanent de-identification. |
| Biometric & Interaction Data | Gaze tracking vectors, gesture dynamics, or facial expression metrics (where consented). | Immediate local processing; raw data deleted upon session termination. | Immediate memory buffer flush; no persistent storage. |
| Financial & Transaction Data | Invoices, subscription billing, payment receipts, tax identifiers, transaction logs. | 7 years from the end of the financial year in which the transaction occurred. | Secure digital shredding in compliance with ATO standards. |
| Automated Decision-Making (ADM) & AI Logs | Inputs, prompts, decision audit trails, and algorithmic output logs affecting users. | 24 months from date of decision generation. | De-identification and archival or secure deletion. |
| Support & Communications | Support tickets, customer service emails, live chat transcripts, feedback forms. | 3 years from ticket resolution date. | Secure digital deletion. |
| System Access & Audit Logs | IP addresses, authentication timestamps, API logs, firewall audit traces. | 12 months rolling retention window. | Automated rolling overwrite / permanent deletion. |
| Employee & Contractor Data | Employment agreements, tax file declarations, performance reviews, payroll logs. | 7 years following termination of employment or engagement. | Confidential document destruction / cryptographic purge. |
| Unsuccessful Job Applications | Resumes, interview notes, background check results. | 6 months post-recruitment outcome. | Secure digital deletion. |
4. Technical De-Identification and Secure Destruction Standards
When retention periods expire, Immersive Realities executes destruction or de-identification in accordance with the National Institute of Standards and Technology (NIST SP 800-88 Rev. 1) guidelines for media sanitisation.
4.1 Digital data destruction
- Data at rest: Data stored in Cloudflare's infrastructure (Australian data centres, with disaster-recovery replication across Cloudflare's global network) is destroyed via cryptographic erasure (deletion of encryption keys) and logical overwrite procedures that render the data unrecoverable.
- Database purging: Automated schedules run across production data stores to purge expired telemetry, temporary session tokens, and deleted user profiles.
4.2 Spatial data & telemetry anonymisation
Spatial environment meshes, room dimensions, and physical tracking vectors collected during XR sessions are processed through noise-injection and stripping pipelines to remove identifiable spatial fingerprints before long-term analytic retention.
4.3 Physical media destruction
Where physical media or paper records exist (for example, hard-copy tax filings), they are shredded onsite using cross-cut shredders compliant with DIN 66399 Level P-4, or destroyed by a certified secure document destruction vendor.
5. Legal Hold and Statutory Exceptions
Notwithstanding the schedule in Section 3, Immersive Realities will suspend data destruction routines ("Legal Hold") upon:
- Service of a legal subpoena, court order, or warrant.
- Formal notification of an investigation by the Office of the Australian Information Commissioner (OAIC), the Australian Competition and Consumer Commission (ACCC), or law enforcement agencies.
- Active or reasonably anticipated civil litigation (including potential claims under the Australian statutory tort for serious invasion of privacy).
When a Legal Hold is lifted, affected records revert to the retention schedule outlined in Section 3.
6. Roles, Governance, and Policy Audit
- Privacy Officer oversight: The Immersive Realities Privacy Officer oversees compliance with this policy and ensures retention automation remains functional.
- Annual policy review: This policy is audited annually to maintain full compliance with evolving statutory obligations under Australian Commonwealth and State privacy legislation.
- Inquiries: Internal or external queries regarding data retention practices may be directed to [email protected].
For how we collect, use, and protect personal information more broadly, see our Privacy Policy.
Immersive Realities Pty Ltd (ACN 656 930 899)
Level 2/161 Collins Street, Melbourne VIC 3000
Email: [email protected]
Or use the contact form on our website.
This Data Retention & Destruction Policy was last updated on 1 October 2026.