Records Retention Policy

1.1 Purpose

This Records Retention Policy explains how Tool-O manages the retention, storage, protection and disposal of business records and information.

The purpose of this Policy is to support legal compliance, operational efficiency, accountability and appropriate record management practices.

1.2 Objectives

Tool-O seeks to:

• retain records for appropriate periods;

• protect confidential information;

• comply with applicable legal obligations;

• support business operations;

• preserve important business information;

• securely dispose of records when no longer required.

1.3 Scope

This Policy applies to records created, received or maintained by Tool-O in connection with its operations, including:

• business records;

• Booking records;

• financial records;

• payment records;

• communications;

• User information;

• contracts;

• policies;

• operational documents;

• digital records;

• other business information.

1.4 Record Formats

This Policy applies regardless of whether records are maintained in:

• electronic form;

• cloud systems;

• emails;

• databases;

• paper documents;

• photographs;

• videos;

• other storage formats.

1.5 Relationship with Other Policies

This Policy should be read together with the:

• Privacy Policy;

• Security Policy;

• Terms of Use;

• all other Platform policies.

1.6 Updates

Tool-O may amend this Records Retention Policy from time to time.

The most current version published on the Platform replaces all previous versions.

2.1 General Principle

Tool-O seeks to retain records only for as long as reasonably necessary to:

• comply with applicable laws;

• support business operations;

• resolve disputes;

• enforce legal rights;

• meet regulatory obligations;

• satisfy legitimate business purposes.

2.2 Categories of Records

Records that may be retained include:

• User Account records;

• Booking records;

• payment records;

• invoices;

• tax records;

• communications;

• reviews;

• Claims;

• dispute records;

• contracts;

• identity verification information where applicable;

• Platform logs;

• audit records;

• security records;

• other operational records.

2.3 Retention Periods

Retention periods may vary depending upon:

• applicable legal requirements;

• regulatory obligations;

• contractual obligations;

• business needs;

• operational requirements;

• dispute resolution requirements.

2.4 Legal Holds

Where litigation, regulatory investigations or legal proceedings are reasonably anticipated or underway, Tool-O may retain relevant records beyond ordinary retention periods until the matter is resolved.

2.5 Secure Storage

Tool-O seeks to store records using reasonable administrative, technical and organisational security measures appropriate to the nature of the information.

2.6 Restricted Access

Access to retained records may be limited to authorised personnel or service providers who require access for legitimate business, operational or legal purposes.

2.7 Disposal

Where records are no longer required, Tool-O may securely delete, destroy or permanently de-identify them where reasonably practicable and permitted by law.

2.8 Backups

Certain records may remain temporarily within encrypted backups or disaster recovery systems following deletion until routine backup cycles expire.

2.9 Exceptions

Tool-O may retain records for longer periods where reasonably necessary to:

• comply with legal obligations;

• investigate misconduct;

• resolve disputes;

• prevent fraud;

• protect legal rights;

• satisfy regulatory requirements.

2.10 No Guarantee of Immediate Deletion

Deletion of a User Account or other information does not necessarily result in the immediate deletion of all related records.

Certain information may continue to be retained where permitted or required by applicable law.

3.1 Accuracy

Tool-O seeks to maintain records that are accurate, complete and reasonably up to date.

Authorised personnel should take reasonable steps to ensure records accurately reflect relevant business activities.

3.2 Record Integrity

Records should not be intentionally altered, destroyed, concealed or falsified except where authorised under this Policy or required by applicable law.

3.3 Security

Tool-O seeks to protect retained records through reasonable security measures including, where appropriate:

• access controls;

• encryption;

• secure cloud storage;

• monitoring;

• backups;

• other appropriate safeguards.

3.4 Confidentiality

Records containing confidential or personal information will be handled in accordance with:

• the Privacy Policy;

• applicable laws;

• internal security practices;

• contractual obligations where applicable.

3.5 Access Requests

Access to retained records may be granted only to authorised persons who require access for legitimate:

• business purposes;

• legal obligations;

• regulatory requirements;

• operational needs;

• security investigations.

3.6 Third-Party Service Providers

Where Tool-O uses third-party providers to store or process records, Tool-O seeks to engage providers that maintain reasonable security and confidentiality standards appropriate to the services provided.

3.7 Data Recovery

Tool-O may maintain backup and disaster recovery processes to assist with restoring records following system failures, cyber incidents or other operational disruptions.

3.8 Audits

Tool-O may review retained records for purposes including:

• legal compliance;

• financial reporting;

• operational improvement;

• fraud prevention;

• security investigations;

• regulatory compliance.

3.9 Disposal Procedures

When records are eligible for disposal, Tool-O may securely:

• delete electronic records;

• destroy physical records;

• permanently de-identify information;

• dispose of storage media using appropriate methods.

3.10 Continuous Improvement

Tool-O may periodically review its record management practices to improve compliance, efficiency, information security and operational effectiveness.

4.1 Governance

Tool-O is responsible for administering this Records Retention Policy and may periodically review its record management practices.

4.2 Periodic Review

Tool-O may review this Policy from time to time having regard to:

• changes in applicable laws;

• business operations;

• regulatory requirements;

• technology developments;

• information security practices;

• operational requirements.

4.3 Continuous Improvement

Tool-O is committed to continually improving its records management framework to support legal compliance, operational efficiency, information security and responsible governance.

4.4 Compliance with Law

Tool-O seeks to comply with applicable laws relating to record retention, taxation, privacy, financial reporting and other legal obligations relevant to its operations.

Nothing in this Policy excludes, restricts or modifies any rights or obligations that cannot lawfully be excluded.

4.5 No Waiver

Failure by Tool-O to enforce any provision of this Policy at any time does not constitute a waiver of its rights.

4.6 Relationship with Other Policies

This Records Retention Policy should be read together with the:

• Terms of Use;

• Privacy Policy;

• Security Policy;

• all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.7 Contact

Questions regarding this Policy may be directed to Tool-O using the contact details published on the Platform.

4.8 Policy Updates

Tool-O may amend this Records Retention Policy from time to time.

The most current version published on the Platform replaces all previous versions.

4.9 Commitment

Tool-O is committed to responsible record management that supports transparency, accountability, legal compliance and the secure handling of information throughout its lifecycle.

4.10 Final Statement

Effective records management helps protect Users, supports business continuity and promotes confidence in the operation of the Tool-O Platform.

END OF RECORDS RETENTION POLICY