Custominder Data Retention & Deletion Policy

1. Introduction and Purpose

Custominder is a cloud-based business operations management platform developed, owned, and operated by Lotusware Inc. (“Lotusware,” “we,” “us,” or “our”). This Data Retention & Deletion Policy explains how information is retained, managed, archived, deleted, or anonymized through Custominder websites, applications, business management tools, community portals, integrations, and related services (the “Custominder Services”). It supports service continuity, Customer access, privacy, security, recovery, and legal compliance. It supplements the Custominder Privacy Policy, Cookie Policy, and Terms of Service.

2. Scope and Definitions

This Policy applies to information processed or maintained through the Custominder Services, including business accounts, authorized users, community portal users, Customers, and website visitors. “Customer” means a business, organization, association, or other legal entity responsible for a Custominder business account. “Customer Data” means information submitted to, stored in, or generated through Custominder by or on behalf of a Customer, including business records, contacts, memberships, events, financial records, documents, and operational information. “Account Data” means information used to register, authenticate, administer, secure, or support an account. “Website Visitor Data” means technical and usage information recorded in connection with website visits. “Deletion” means removal from applicable active systems, subject to backups, technical limits, and lawful retention exceptions. “Anonymization” means processing information so it no longer identifies and cannot reasonably be linked to an individual.

3. Data Ownership and Responsibilities

Customers retain ownership of Customer Data under the Custominder Terms of Service. Lotusware provides infrastructure and services for processing and maintaining that data. Customers manage their records, authorized users, permissions, and applicable recordkeeping duties. Lotusware is responsible for Account Data and other personal information for which it determines processing purposes and means, subject to law. Requests about personal information in Customer business records may need to be directed to the Customer responsible for that data. Lotusware may assist through available application and support processes.

4. General Retention Principles

Lotusware seeks to retain information for no longer than reasonably necessary for operational, contractual, security, and legal purposes. Relevant factors include collection purpose, account status, service necessity, Customer instructions, available deletion functionality, security and fraud prevention, tax and accounting requirements, disputes, legal claims, and preservation obligations. Different categories may have different retention periods; no universal period applies. Information no longer required and not subject to an exception should be deleted, securely disposed of, or anonymized.

5. Customer Data During Active Subscriptions

During an active subscription, Customer Data is generally retained as needed to provide the Custominder Services and support authorized operations, including business profiles, contacts, memberships, events, planning, voting, governance, invoices, financial records, uploaded files, and operational history. Customers may modify, archive, or delete records using available features and permissions. Deleting a record does not necessarily erase related information needed for accounting, audit, security, legal compliance, or data integrity. Where appropriate, archival or access restrictions may be used.

6. Subscription Expiration and Service Termination

When a subscription expires, is canceled, or is terminated, access to some or all Custominder Services may be restricted under the applicable Terms of Service and subscription arrangement. Termination does not automatically delete every business record immediately. Recovery, reactivation, data access, and deletion depend on account status and applicable terms. Customers are responsible for retaining necessary copies and using available exports before access ends, where provided. Lotusware does not guarantee indefinite post-termination availability of Customer Data.

7. Business Account Recovery

The Custominder Terms of Service provide for a business account recovery period of up to 90 days, subject to recovery eligibility and conditions. Recovery is not a guarantee that every deleted record, file, integration, or historical state can be restored. After the recovery period, Customer Data may become eligible for permanent deletion under applicable procedures and lawful retention requirements. Billing, security, transaction, and legally preserved records may need to be retained longer. The recovery period is not a universal deadline for erasing all data.

8. Website Visitor Logs

Custominder may record website visits for operational reporting, analytics, security, and service improvement. Depending on available data, recorded information may include URL, domain, referring page, IP address, browser, operating system, device, user agent, available country, region, city, postal code, geographic coordinates, timezone, and visit timestamp. This server-side logging may occur independently of browser cookies. The standard retention period for Custominder website visitor logs is 730 days from creation. The database is configured to expire these records automatically; actual deletion may occur asynchronously after the expiry threshold. Specific information may require separate lawful preservation.

9. Account and Authentication Data

Custominder maintains information necessary for registration, authentication, authorization, account administration, and security, including account identifiers, contact details, authentication-related records, roles, permissions, account status, sessions, and administrative records. Session expiry differs from account and security-record retention. Suspension, deactivation, or deletion of an account does not necessarily immediately erase associated records retained for justified security, billing, administrative, or legal reasons. Unneeded information is handled under applicable deletion procedures.

10. Financial, Billing, and Transaction Records

Custominder may maintain subscription information, invoices, payment status, transaction references, and related financial records. These may be retained to reconcile payments, resolve disputes, support audits, meet tax and accounting duties, and establish or defend legal claims. Financial information may remain after account closure where justified or required. Retention depends on the record type, responsible entity, and applicable law; no single period is established here. Customer financial records remain Customer Data and do not become Lotusware property simply through processing.

11. Membership, Community, and Governance Records

Custominder supports memberships, applications, renewals, events, voting, decisions, and governance activities. Records may have organizational, audit, historic, or legal significance. Customers determine their applicable recordkeeping obligations, subject to application controls and law. Some records may need to remain after an individual's participation ends, with access restricted where appropriate. Customer-controlled deletion requests may require Customer authorization or action.

12. Uploaded Files and Documents

Custominder may store Customer-uploaded business documents, membership materials, images, and supporting files while needed for the relevant service and subject to retention requirements. Removing a file from an active interface may not immediately erase backups or references. Deletion processes must consider storage locations, references, permissions, and backup lifecycles. Lotusware seeks to prevent access through ordinary application functions after applicable deletion is complete.

13. Backups and Disaster Recovery

Lotusware may use provider backups, snapshots, or recovery systems for resilience. Information deleted from active systems may remain temporarily in backups until the applicable backup lifecycle expires. Backups are not intended for ordinary operational access to deleted information. Restored data remains subject to applicable deletion requirements where feasible. Exact backup retention periods depend on actual infrastructure configuration; this Policy does not promise immediate selective deletion from immutable backups or state an unverified universal backup retention period.

14. Data Deletion Requests

Customers and individuals may request access, correction, or deletion of personal information subject to applicable rights and limitations. Requests may be submitted through Custominder support or the channels identified in the Privacy Policy. Lotusware may verify identity and authority, determine whether a Customer controls the records, identify applicable legal holds, and protect against unauthorized deletion. Valid requests are processed through appropriate procedures consistent with law. If deletion cannot be completed, an explanation may be provided subject to lawful and security limitations. No unverified universal processing deadline is promised.

15. Deletion Methods and Security

Depending on the system and record type, deletion may include removing database records and files, revoking permissions, closing accounts, automated expiry, secure disposal, or anonymization. Technical and organizational safeguards should protect information during storage, access, transfer, and disposal. Where lawful retention remains necessary, access may be restricted instead of immediately deleting records. Processes seek to reduce unauthorized access, unintended recovery, and exposure.

16. Third-Party Service Providers

Custominder may rely on hosting, infrastructure, authentication, storage, communication, payment, and other providers. Provider-specific retention, backup, security, and deletion processes may apply. Lotusware seeks appropriate contractual, organizational, and technical protections consistent with its obligations. Some providers may independently be legally required to retain transaction or operational records. Lotusware cannot guarantee erasure where a provider is legally required to retain information or where the information is outside Lotusware's authorized control.

17. Legal Holds and Retention Exceptions

Information may be retained beyond ordinary periods where reasonably needed to meet law or valid legal process; tax, accounting, or regulatory duties; security investigations; fraud prevention; disputes; contractual rights; legal claims; or litigation holds. Retention should be limited to the information reasonably required. When the obligation ends and no other basis remains, the information should be evaluated for deletion or anonymization.

18. International Storage and Processing

Custominder data may be stored, backed up, accessed, or processed outside Canada depending on infrastructure and providers. Applicable data-protection rules and agreements govern retention, transfer, and deletion. Information in another jurisdiction may be subject to its lawful-access requirements. Lotusware seeks appropriate safeguards consistent with applicable privacy obligations.

19. Changes to This Policy

Lotusware may revise this Policy to reflect changes to Custominder functions, infrastructure, retention practices, operations, or law. Published versions will identify their effective dates. Where required, Lotusware will provide notice or take other steps before material changes take effect. Updates do not eliminate applicable legal rights or obligations.

20. Contact and Questions

Questions about retention, deletion, recovery, or personal information processed through Custominder may be directed to Lotusware Inc., the company that operates Custominder, through the Contact Us page on the Custominder website. Registered users may also submit support requests through the application.

21. Effective Date

This Policy becomes effective on the date identified in its published version. This draft has no effective date and must not be represented as an approved or published policy.