Record Retention Policy

JHS Solutions LLC ("Company," "we," "our," or "us") recognizes the importance of maintaining reliable, accurate, secure, and appropriately retained business records.

This Record Retention Policy describes the Company's approach to retaining, protecting, archiving, and securely disposing of records generated through the Portal Platform™ and related services.

The objectives of this Policy are to:

preserve important business records;

support electronic transactions;

protect customer information;

comply with applicable legal obligations;

support investigations;

facilitate audits;

improve operational efficiency;

support future Platform growth.

This Policy forms part of the Portal Platform Legal Suite™ and should be read together with:

LEGAL-001 — Master Terms of Service;

LEGAL-002 — Privacy Policy;

LEGAL-003 — Communications Policy;

LEGAL-004 — Security Policy;

LEGAL-005 — AI Services Policy;

LEGAL-006 — Electronic Signature Disclosure & Consent;

LEGAL-007 — Cookie Policy;

LEGAL-008 — Acceptable Use Policy;

LEGAL-009 — Trust Center™ Policy;

and all other applicable Platform policies.

1.1 Purpose

The purpose of this Policy is to establish consistent practices governing:

record creation;

record classification;

record retention;

record protection;

record archiving;

record retrieval;

secure disposal;

legal preservation.

1.2 Scope

This Policy applies to records generated through:

Portal Platform™;

eSignare®;

Customer Workspace;

Signer Portal;

Administrator Portal;

Trust Center™;

Dispatch Center™;

APIs;

AI Services;

Enterprise Services;

Mobile Applications;

future Company products.

1.3 Types of Records

Records governed by this Policy may include:

executed documents;

draft documents;

electronic signatures;

Certificates of Completion™;

Verification IDs;

audit trails;

authentication records;

communication records;

invoices;

receipts;

subscription information;

payment records;

customer support records;

AI interaction logs;

API logs;

security logs;

system logs;

administrative records;

enterprise records;

future Platform records.

1.4 Record Management Principles

The Company seeks to maintain records in accordance with the following principles:

accuracy;

integrity;

confidentiality;

availability;

accountability;

security;

lawful retention;

operational efficiency;

responsible disposal.

1.5 Ownership of Records

Platform-generated operational records remain the property of the Company unless otherwise provided by applicable law or written agreement.

User-owned content remains subject to the Master Terms of Service and applicable contractual arrangements.

1.6 Legal Compliance

The Company retains records as reasonably necessary to:

comply with applicable federal laws;

comply with Florida law;

comply with court orders;

satisfy contractual obligations;

support litigation;

respond to governmental requests;

support regulatory compliance;

maintain business operations.

Where legal obligations require longer retention periods than operational needs, the longer applicable period shall govern.

1.7 Continuous Improvement

Record management practices may evolve as:

technology changes;

business operations expand;

legal requirements develop;

cybersecurity risks evolve;

enterprise requirements increase;

future Platform services are introduced.

The Company reserves the right to modify record management practices consistent with applicable law.

2.1 General Retention Principles

The Company retains records only for as long as reasonably necessary to:

provide Platform services;

support electronic transactions;

comply with contractual obligations;

satisfy applicable legal requirements;

maintain Platform security;

support fraud prevention;

facilitate audits;

resolve disputes;

preserve evidence;

support business continuity.

Retention periods may differ depending upon the category of record, applicable law, contractual commitments, operational needs, or active legal preservation requirements.

2.2 Categories of Records

The Company may maintain records including:

customer account records;

signer account records;

administrator records;

enterprise organization records;

executed documents;

draft documents;

document templates;

uploaded files;

Certificates of Completion™;

Verification IDs;

audit trails;

authentication logs;

communication records;

billing records;

subscription records;

payment records;

AI interaction records;

API logs;

security logs;

system logs;

support records;

training records;

future Platform records.

Each category may be subject to different retention practices.

2.3 Executed Documents

Completed electronic documents may be retained for a period determined by:

customer subscription;

enterprise agreement;

operational requirements;

legal obligations;

customer-selected retention settings where available.

Unless otherwise required by law or contract, the Company reserves the right to establish reasonable retention periods for completed documents.

2.4 Draft Documents

Draft documents may be retained for operational purposes.

The Company may automatically archive or permanently remove inactive drafts after a reasonable period, subject to:

subscription level;

customer settings;

enterprise agreements;

legal preservation requirements.

Users are encouraged to maintain independent copies of important draft materials.

2.5 Certificates of Completion™

Certificates of Completion™ may be retained for the same or a longer period than the associated completed electronic record where reasonably necessary to support verification, audit, dispute resolution, or legal compliance.

2.6 Trust Center™ Records

Trust Center™ records may include:

Verification IDs;

audit summaries;

authentication information;

document integrity indicators;

verification metadata;

timestamp records;

future verification information.

These records may be retained to support:

fraud prevention;

verification;

legal compliance;

dispute resolution;

customer support;

Platform integrity.

2.7 Audit Logs

Audit logs may record:

account creation;

authentication events;

document uploads;

document preparation;

signature events;

communication events;

administrative actions;

API activity;

workflow completion;

security events;

future operational events.

Audit logs may be retained for longer periods than customer-facing records where reasonably necessary to support Platform security, investigations, compliance, and operational integrity.

2.8 Authentication Records

Authentication records may include:

login history;

successful authentication events;

failed authentication attempts;

Multi-Factor Authentication events;

password reset events;

account recovery events;

device information;

session history.

Authentication records support security investigations, fraud prevention, and account protection.

2.9 Communications Records

Communication records may include:

emails;

SMS;

MMS;

WhatsApp messages;

push notifications;

Dispatch Center™ activity;

customer support communications;

delivery confirmations;

communication metadata;

future communication technologies.

Communication records may be retained for operational, legal, security, customer service, or audit purposes.

2.10 Billing and Financial Records

The Company may retain:

invoices;

receipts;

subscription history;

payment confirmations;

refunds;

credits;

billing adjustments;

transaction identifiers;

tax-related information;

future financial records.

Financial records may be retained as required by applicable accounting, tax, contractual, or legal obligations.

2.11 Security Records

Security records may include:

incident reports;

vulnerability reports;

monitoring logs;

firewall logs;

intrusion detection events;

access reviews;

administrative security actions;

future cybersecurity records.

Security records may be retained as reasonably necessary to support investigations, legal compliance, and the continuous improvement of the Company's security program.

2.12 Artificial Intelligence Records

Where AI Services are provided, the Company may retain:

AI interaction metadata;

prompts;

responses;

system performance information;

abuse detection information;

security events;

troubleshooting records;

future AI operational records.

Retention of AI-related records is governed by this Policy, the Privacy Policy, and the AI Services Policy, and may vary based on applicable law and the specific AI service used.

2.13 Backup Systems

The Company may maintain backup copies of certain records to support:

disaster recovery;

business continuity;

operational resilience;

cybersecurity recovery;

restoration following system failures.

Backup copies may persist for a period after operational records have been deleted, subject to normal backup rotation schedules, disaster recovery procedures, legal preservation requirements, and technical limitations.

2.14 Legal Holds

The Company may suspend ordinary record deletion or disposal procedures when records are subject to:

litigation;

arbitration;

governmental investigation;

subpoena;

court order;

regulatory inquiry;

internal investigation;

anticipated legal proceedings.

Records subject to a legal hold will be preserved until the Company determines that the hold may lawfully be released.

2.15 Secure Disposal

When records are no longer required to be retained, the Company may securely dispose of them using methods reasonably designed to prevent unauthorized recovery.

Secure disposal methods may include:

secure deletion;

cryptographic destruction where appropriate;

secure overwriting;

physical destruction of storage media where applicable;

future secure disposal technologies.

The Company may retain aggregated, anonymized, or de-identified information where permitted by law and operationally appropriate.

2.16 Enterprise Retention

Enterprise customers may receive customized retention options through separate written agreements.

Enterprise retention settings may address:

document retention periods;

legal hold procedures;

archival options;

export capabilities;

organization-specific compliance requirements;

regulatory obligations.

Where an Enterprise Agreement conflicts with this Policy, the written Enterprise Agreement shall control for that customer to the extent permitted by law.

2.17 Future Record Technologies

As technology evolves, the Company may implement new record management technologies, including:

intelligent archival systems;

AI-assisted classification;

automated retention schedules;

digital preservation technologies;

advanced search capabilities;

immutable storage technologies where appropriate;

future record lifecycle management systems.

The Company reserves the right to modify its record management practices as operational, legal, and technological requirements evolve.

3.1 User Access to Records

Subject to applicable law, subscription level, contractual obligations, security requirements, and Platform functionality, Users may have the ability to:

access certain records;

review completed documents;

review Certificates of Completion™;

review Verification IDs;

download completed documents;

retrieve invoices;

retrieve receipts;

review account history;

access communication history where available;

review audit-related information where appropriate.

The Company may require identity verification before granting access to requested records.

3.2 Record Export

Where supported by the Platform, Users may export certain records for their own lawful purposes.

Exportable records may include:

completed documents;

Certificates of Completion™;

verification reports;

invoices;

receipts;

account information;

enterprise reports;

future exportable records.

Export functionality may vary depending upon:

subscription level;

enterprise agreements;

applicable law;

operational limitations.

3.3 Record Correction

Users may request correction of inaccurate account information maintained by the Company.

Operational records documenting completed Platform events, including audit trails, authentication events, timestamps, Certificates of Completion™, Verification IDs, and other historical transaction records, generally cannot be modified except where correction is required by applicable law or necessary to correct a documented system error.

3.4 Privacy

Information retained under this Policy remains subject to:

LEGAL-002 — Privacy Policy;

applicable privacy laws;

contractual confidentiality obligations;

applicable legal requirements.

The Company seeks to protect retained records using commercially reasonable administrative, technical, organizational, and operational safeguards.

3.5 Security

Records maintained by the Company may be protected through safeguards including:

encryption where implemented;

access controls;

Multi-Factor Authentication;

audit logging;

monitoring;

role-based permissions;

secure backups;

disaster recovery planning;

future security technologies.

Although the Company continuously improves its security program, no information system can guarantee absolute protection against every cybersecurity risk.

3.6 Regulatory Compliance

The Company seeks to maintain records in a manner consistent with applicable:

federal laws;

Florida laws;

electronic transaction laws;

privacy laws;

consumer protection laws;

tax requirements;

accounting obligations;

court orders;

regulatory directives;

contractual commitments.

Where legal obligations conflict with ordinary retention schedules, the applicable legal requirement shall govern.

3.7 Availability Disclaimer

The Company seeks to maintain access to retained records using commercially reasonable operational practices.

However, records may become temporarily unavailable because of:

scheduled maintenance;

software updates;

disaster recovery procedures;

cybersecurity incidents;

cloud provider interruptions;

Internet outages;

force majeure events;

other circumstances beyond the Company's reasonable control.

The Company does not guarantee uninterrupted access to retained records.

3.8 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES ARISING FROM:

lawful record deletion;

expired retention periods;

failure to export records before expiration;

third-party infrastructure failures;

cloud provider interruptions;

cybersecurity incidents;

force majeure events;

circumstances beyond the Company's reasonable control.

Nothing in this section limits liability that cannot lawfully be limited.

3.9 Relationship to Other Policies

This Record Retention Policy forms part of the Portal Platform Legal Suite™ and should be interpreted together with:

LEGAL-001 — Master Terms of Service;

LEGAL-002 — Privacy Policy;

LEGAL-003 — Communications Policy;

LEGAL-004 — Security Policy;

LEGAL-005 — AI Services Policy;

LEGAL-006 — Electronic Signature Disclosure & Consent;

LEGAL-007 — Cookie Policy;

LEGAL-008 — Acceptable Use Policy;

LEGAL-009 — Trust Center™ Policy;

LEGAL-011 — Accessibility Statement;

LEGAL-012 — Subprocessors & Third-Party Services;

LEGAL-013 — Data Processing Addendum;

LEGAL-014 — Enterprise Terms;

LEGAL-015 — eSignare Notary™ Terms;

LEGAL-016 — IPEN & RON Supplement; and

any additional legal documents adopted by the Company.

Where another policy governs a more specific category of records, that policy shall control with respect to that subject matter while this Policy governs the Company's overall record retention practices.

3.10 Amendments

The Company may revise this Policy to reflect:

changes in technology;

legal developments;

regulatory guidance;

security enhancements;

operational improvements;

Platform expansion;

future record management technologies.

Material revisions will be communicated using reasonable electronic methods where required by applicable law.

Continued use of the Platform following the effective date of revised policies constitutes acceptance of the updated Record Retention Policy to the extent permitted by applicable law.

3.11 Contact Information

Questions regarding this Record Retention Policy or the Company's record management practices may be submitted to:

JHS Solutions LLC

Email: support@esignare.com

Support is available for matters including:

Record Retention Questions

Record Access Requests

Data Export Requests

Record Correction Requests

Record Deletion Requests (where applicable)

Audit Record Questions

Document Retention Inquiries

General Customer Support

Additional contact methods and support resources may be published through the Portal Platform™ from time to time.

Where required by applicable law, the Company may designate a records management, compliance, or legal representative to assist with record retention-related inquiries.

3.12 Severability

If any provision of this Record Retention Policy is determined by a court of competent jurisdiction to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.

Any invalid provision shall be interpreted or modified only to the extent necessary to preserve its intended purpose while maintaining the overall effectiveness of this Policy.

3.13 Survival

The provisions relating to:

record retention;

legal holds;

audit records;

Verification IDs;

Certificates of Completion™;

dispute resolution;

limitation of liability;

governing law;

regulatory compliance;

and other provisions intended by their nature to survive,

shall remain effective following termination of an account or completion of a transaction to the extent permitted by applicable law.

ACKNOWLEDGMENT

BY ACCESSING OR USING THE PORTAL PLATFORM™, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS RECORD RETENTION POLICY.

YOU FURTHER ACKNOWLEDGE THAT THE COMPANY MAY RETAIN, ARCHIVE, PRESERVE, EXPORT, OR SECURELY DISPOSE OF RECORDS IN ACCORDANCE WITH THIS POLICY, APPLICABLE LAW, AND ITS LEGITIMATE OPERATIONAL REQUIREMENTS.