Purpose and Scope

BrainSim Technologies Inc. is committed to protecting our systems, information, and our customers’ information. The purpose of this Policy is to ensure that necessary records and documents are adequately protected and maintained and to ensure that records that are no longer needed by BrainSim Technologies Inc. or are of no value are discarded at the proper time. This policy defines the retention requirements for customer data in the BrainSim Technologies Inc. SaaS service and BrainSim Technologies Inc. business systems and data. This policy applies to all BrainSim Technologies Inc. employees or contractors working on behalf of BrainSim Technologies Inc..

BrainSim Technologies Inc. business systems include:

• Mail and Email
• Instant Messaging and Text Messaging
• Business server logs
• Storage
• IT authentication
• Helpdesk ticketing 
• CRM, Sales, Marketing
• HR
• Learning and Certification
• ITSM
• Internal ticketing 
• Finance
• BrainSim Technologies Inc. websites
• Knowledge Center
• Cloud computing
• Database storage

Policy

BrainSim Technologies Inc. will define a retention schedule for all systems and data in use within the organization and will document them in the Data Retention Schedule.

Data retention for customer data – SaaS  

Services 

The customer is in full control of the customer data stored through the BrainSim Technologies Inc. SaaS service and has responsibility to determine the retention scheme for the customer data. The BrainSim Technologies Inc. contract specifies that customer data will be available in industry-standard format for download upon termination or completion of the service (free of charge). Except as otherwise agreed or required by applicable law, the customer will have 30 days to download such data before it is deleted and, thereafter, all such customer data (including backups) will be cycled out of the SaaS service systems and deleted within 120 days.

Responsibilities

Employees and Contractors

All employees who create and use records and information are responsible for maintaining BrainSim Technologies Inc. Records according to this Policy.

Management and Business Units

All levels of management within BrainSim Technologies Inc. are responsible for ensuring compliance with this Policy within their respective group, region, or function. They are responsible for ensuring that their employees know where to locate the current Data Retention Schedule and that hard copy and electronic files are kept, stored, or destroyed in compliance with this Policy.

Retention Requirements

• BrainSim Technologies Inc. will retain or destroy data files in compliance with the retention periods stated in the Data Retention Schedule.
• The retention periods provided in the Data Retention Schedule are intended to be as short as possible to minimize the volume of BrainSim Technologies Inc. Records while still complying with legal, contractual, and/or operational requirements. Records will be kept only for the period stated in the Schedule and will be destroyed or discarded at the stated retention period expiration.

Safeguarding of Data

Measures will be taken to ensure that the information can be accessed by authorized users during the retention period (both with respect to the information carrier and the readability of formats) and will also be stored according to its classification level. For BrainSim Technologies Inc. internal systems, the responsibility for the storage belongs to the IT team.

Disposal of Data

As data expires according to the Retention Schedule, the data will be deleted, shredded or otherwise destroyed in accordance to its classification and destruction requirements. Overall responsibility for the disposal of data belongs to the IT team for business systems and Cloud team for Cloud systems.

Policy Enforcement

The BrainSim Technologies Inc. Chief Information Security Officer (CISO) is responsible for ensuring compliance with this policy and will assist with the protection of BrainSim Technologies Inc. data. Any employee found to willfully or intentionally violate this policy may be subject to disciplinary action, up to and including termination of employment.

Record of Changes

Type of Information	Document Data
Document Title:	BrainSim Technologies Inc.  Data Retention Policy
Document Owner:	Reuben Kraft - BrainSim Technologies Inc. Chief Engineering and Information Security Officer (CISO)
Approved by:	Reuben Kraft – Founder/Chief Engineer
Issued:	08/12/2021
Reviewed & Revised:	08/12/2021

Revision Control

Version Number	Nature of Change	Date Approved
1.0	Initial version	08/21/2021

Document Distribution and Review

The document owner will distribute this document to all approvers when it is first created and as changes or updates are made. This document will be reviewed and updated annually or upon written request by an approver or stakeholder. Questions or feedback about this document can be directed to the owner or a listed approver.