Data Retention, Deletion and Legal Hold Policy

This Policy explains how Zoiko Tech Inc. retains, stores, deletes, exports, archives, suspends deletion of, and permanently disposes of data processed through ZoikoTime.

This Policy forms part of the ZoikoTime legal and governance framework. Where a signed Order Form, enterprise agreement, regulatory requirement, court order, or legal hold requires a different retention period, that instrument controls to the extent permitted by applicable law.

1. Purpose and Legal Function

This Data Retention, Deletion and Legal Hold Policy explains how Zoiko Tech Inc. retains, stores, deletes, exports, archives, suspends deletion of, and permanently disposes of data processed through ZoikoTime. The policy is designed to support enterprise-grade workforce assurance, regulatory defensibility, customer control, privacy-by-design, security, auditability, and operational reliability.

This Policy should be read together with the ZoikoTime Terms of Service, Data Processing Addendum, Privacy Notice, Worker Transparency Notice, Security Measures Schedule, Subprocessor Policy, Cookie Notice, Acceptable Use Policy, AI and Automated Insights Policy, and Service Level Agreement.

2. Scope

This Policy applies to Customer Data, Personal Data, worker-facing data, administrator data, audit logs, operational telemetry, AI-generated insights, support data, billing records, security logs, cookies, backup copies, derived metadata, and records generated in connection with the use, administration, support, security, compliance, billing and improvement of ZoikoTime.

This Policy does not transfer ownership of Customer Data to Zoiko Tech Inc. Customer Data remains owned or controlled by the Customer or its relevant rights holder, subject to the limited rights granted to Zoiko Tech Inc. to provide, secure, maintain, support, improve, and evidence the Services.

4. Retention Principles

ZoikoTime applies retention controls according to the following principles:

Purpose limitation: Data is not retained beyond what is necessary for its documented purpose
Data minimization: Retention is proportionate to the operational, legal, compliance, evidentiary, billing and security purposes for which data is processed
Legal defensibility: Critical audit, evidentiary, and governance records are retained to support legal defensibility and accountability
Audit integrity: Retention policies must not undermine the integrity of audit trails or chain-of- custody evidence
Customer configurability: Where technically and commercially feasible, customers may configure retention periods appropriate to their legal, operational, and employment obligations
Controlled deletion: Deletion must be controlled, logged, and reasonably irreversible once completed, except where residual copies remain temporarily in encrypted backups

Legal hold overrides ordinary deletion until the hold is released by an authorized legal, compliance, or customer governance function.

5. Default Retention Schedule

Unless an Order Form, Customer configuration, enterprise agreement, legal hold, regulatory rule, or applicable law requires otherwise, ZoikoTime applies the following baseline retention standards:

Active workforce records and time data: Retained for the duration of the subscription plus a configurable post-termination period (default 30 days)
Audit logs and access-to- view logs: Retained for a minimum of 12 months; enterprise configurations may extend this period
Evidence records and chain-of-custody documentation: Retained based on customer legal and compliance configuration
Billing and financial records: Retained for at least 7 years or as required by applicable tax and accounting law
Security and incident logs: Retained for a minimum of 90 days; critical incidents may be retained longer for legal and regulatory purposes
Support interaction records: Retained for the duration of the engagement plus commercially reasonable periods for quality, compliance, and dispute resolution
Deleted user records: Purged from production within 30 days of deletion trigger unless subject to legal hold

11. Legal Hold

ZoikoTime may suspend ordinary deletion, modification or destruction of records when Zoiko Tech Inc., Zoiko Group Inc., a Customer, a regulator, a court, law enforcement authority, auditor, insurer, counsel or authorized governance function identifies that data may be relevant to litigation, investigation, audit, regulatory inquiry, employment dispute, wage/hour claim, billing dispute, security incident, or other legally significant matter.

A legal hold may apply to a Customer workspace, specific worker records, time periods, evidence types, audit logs, AI insight records, support tickets, billing records, security logs, exports, backups or any other data category reasonably relevant to the matter.

Legal holds must identify the hold owner, scope, reason, effective date, affected systems, and review cadence where practicable
Data subject deletion requests and customer deletion requests may be paused for data subject to legal hold
Access to data under legal hold should be restricted to authorized legal, compliance, security, or administrator personnel
Legal holds should be periodically reviewed and released when the underlying legal or business need no longer exists
Upon release of a legal hold, data returns to the ordinary retention and deletion rules unless another hold or legal basis applies

13. Audit Integrity and Non-Destructive Corrections

Because ZoikoTime is designed to support workforce assurance, legal defensibility and chain-of- custody evidence, certain records are retained in append-only or audit-preserving form.

Where a record is inaccurate, disputed or superseded, the preferred correction method is to add a correction, dispute marker, explanatory note, adjusted record, replacement version, administrative override, or human-review decision — rather than deleting or silently rewriting the original record.

This approach protects workers, Customers and Zoiko Tech Inc. by preserving context, preventing tampering, supporting transparency and enabling reconstruction of how workforce conclusions were reached at a point in time.

15. Backups, Disaster Recovery and Residual Copies

Data deleted from active production systems may remain temporarily in encrypted backups, disaster recovery systems, replicated storage, logs or immutable archives until those systems are overwritten, retired, expired or technically remediated. These residual copies are access-restricted and are not used for ordinary business purposes.

If backup data must be restored, ZoikoTime will take commercially reasonable steps to ensure that data previously deleted from production systems is re-deleted or suppressed unless a legal hold, security incident, regulatory requirement or operational necessity requires continued retention.

Contact ZoikoTime

For questions about this document or your legal rights:

1401 21st Street, Suite R, Sacramento, CA 95811, USA

European HQ: 67-69 Great Portland Street, 5th Floor, London W1W 5PF, UK