**Data Retention Policy**

**Effective Date:** ___ [Date] ___  
**Issued by:** **Midas Technologies LLC**  

This Data Retention Policy (“Policy”) outlines the practices of **Midas Technologies LLC** regarding the retention, storage, and deletion of data, including operational, financial, and analytical data. This Policy ensures compliance with best practices, regulatory standards, and operational needs.

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### 1. **Purpose and Scope**
   - **Purpose**: This Policy is intended to establish guidelines for data retention, deletion, and protection, ensuring that Midas Technologies LLC effectively manages its data lifecycle.
   - **Scope**: This Policy applies to all data collected, processed, and stored by Midas Technologies LLC, including operational data, financial data, client data, and log files. It applies to employees, contractors, and any third parties handling Company data.

### 2. **Data Categories and Retention Periods**
   Midas Technologies LLC organizes data into the following categories, each with a defined retention period to support business needs and compliance requirements:

   | **Data Category**         | **Description**                                                   | **Retention Period**           |
   |---------------------------|-------------------------------------------------------------------|--------------------------------|
   | Operational Data          | Data related to daily business operations, including project data, workflow, and team communications. | 3 years                         |
   | Financial Data            | Invoices, receipts, transaction records, and tax documentation.  | 7 years (for tax and audit)     |
   | Analytical Data           | Data used for performance analysis, model training, and backtesting. | 5 years                         |
   | Log Files                 | System and application logs, including access and error logs.    | 1 year                          |
   | Backup Data               | Copies of operational and critical business data for disaster recovery purposes. | 1 year                          |
   | Regulatory Compliance Data | Records required for compliance with regulations, including audit trails. | Minimum of 7 years              |

### 3. **Data Storage and Security**
   - **Data Storage Locations**: All data shall be stored on secure, access-controlled servers located on-premises or with trusted cloud providers that comply with industry standards for security and data protection.
   - **Access Control**: Access to data is limited to authorized personnel based on role and necessity. Security measures, including password protection and encryption, are applied to safeguard data integrity.

### 4. **Data Deletion Protocols**
   - **Scheduled Deletion**: Data that has reached the end of its retention period will be permanently deleted from Company systems, unless subject to a legal hold or exception.
   - **Secure Deletion Methods**: Midas Technologies LLC employs secure deletion methods for all electronic data, including data wiping and, where applicable, physical destruction for printed materials.
   - **Exceptions for Legal Holds**: In the event of ongoing litigation or regulatory investigations, data related to such cases will be retained until legal action concludes and no longer required.

### 5. **Data Compliance Standards**
   - **Compliance with Applicable Laws**: This Policy complies with relevant data management laws, including but not limited to data protection and financial record-keeping regulations.
   - **Audit and Monitoring**: Midas Technologies LLC may periodically audit data retention practices to ensure compliance with this Policy and applicable legal standards.

### 6. **Data Retention Responsibilities**
   - **Data Owners**: Department heads and data owners are responsible for ensuring compliance with this Policy and reporting any issues related to data retention and deletion.
   - **IT Department**: The IT Department is responsible for implementing data retention schedules, securing data storage, and performing scheduled data deletions.
   - **Legal and Compliance Team**: The Legal and Compliance Team monitors data retention to ensure it aligns with regulatory and legal requirements.

### 7. **Review and Amendment of Policy**
   - This Policy will be reviewed annually and updated as necessary to reflect changes in legal requirements, industry standards, and Company practices. Any updates will be communicated to all employees and relevant stakeholders.

### 8. **Exceptions and Legal Hold**
   - **Exceptions**: Requests for exceptions to the retention periods defined in this Policy must be submitted in writing to the Legal and Compliance Team for review and approval.
   - **Legal Hold**: In the event of a legal hold, all relevant data will be retained until the hold is lifted by the Legal and Compliance Team.

### 9. **Policy Acknowledgment**
   - All employees and contractors handling Company data are required to sign an acknowledgment of this Policy, confirming their understanding of and commitment to adhering to these data retention standards.

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**Acknowledgment of Data Retention Policy**

By signing below, I acknowledge that I have read, understand, and agree to comply with the Midas Technologies LLC Data Retention Policy.

| **Employee’s Name**  | **Signature** | **Date** |
|----------------------|---------------|----------|
|                      |               |          |

