Data Retention and Deletion Policy

1. Scope

This policy applies to information processed through the Diversified Payday public website, payroll platform, customer-support systems, subscription operations, and related services.

It should be read together with the Privacy Policy, Terms and Conditions, and applicable customer agreements.

2. Retention Principles

Diversified Payday retains information only for periods reasonably necessary to:

• Provide and support the Services
• Maintain payroll and tax records
• Provide read-only customer access
• Comply with legal and contractual obligations
• Maintain financial and accounting records
• Resolve disputes
• Enforce agreements
• Protect security
• Prevent fraud and abuse
• Maintain audit trails
• Support legitimate business operations

Retention periods vary by record type, jurisdiction, customer status, and operational purpose.

A single retention period does not apply to every record.

3. Active Accounts

While an account remains active, Diversified Payday may retain information needed to provide and support the Services, including:

• Employer profiles
• Authorized-user records
• Employee and contractor records
• Payroll calculations and histories
• Tax forms and filing records
• Bank and routing information
• NACHA and payroll instruction records
• Reports
• Documents
• Certifications
• Audit activity
• Billing records
• Support communications
• Security records

Customers may be unable to delete information that is required for payroll history, audit integrity, tax compliance, fraud prevention, system security, or legal obligations.

4. Cancelled Accounts and Read-Only Access

Following cancellation, eligible Customers are intended to retain authenticated read-only access to historical payroll records, reports, and available tax documents for at least seven years.

During read-only status:

• New payroll processing is disabled
• Direct-deposit file creation may be disabled
• Automated tax services may be disabled
• Historical records remain viewable where supported
• Available records may be downloaded or exported
• Account authentication remains required

Read-only access is subject to:

• Legal requirements
• Technical feasibility
• Platform availability
• Security requirements
• Identity and account verification
• Legal holds
• Enforcement actions
• Record integrity
• Other legitimate operational limitations

Customers should independently preserve records they are legally required to maintain.

5. Trial Accounts

Trial-account information may be retained after a trial ends to:

• Allow account recovery
• Support a later subscription
• Prevent fraud and repeated trial abuse
• Maintain consent and agreement records
• Resolve support or billing issues
• Comply with legal obligations

Unless a longer period is required or justified, inactive trial data may be scheduled for deletion after at least 90 days.

Diversified Payday is not required to preserve unused trial data permanently.

6. Payroll and Employment-Tax Records

Employment-tax and payroll records may be subject to federal, state, and local retention requirements.

Certain federal employment-tax records generally must be retained for at least four years after the tax becomes due or is paid, whichever is later.

Other wage, hour, benefits, unemployment, tax, and employment records may require different or longer periods.

The Customer remains responsible for identifying and satisfying its own recordkeeping obligations.

Diversified Payday's intended seven-year read-only period is a customer-access practice and does not represent a statement that every record is legally required to be retained for exactly seven years.

7. Tax Forms and Filing Records

Tax forms, filing records, acknowledgments, corrections, agency responses, and related information may be retained for the longer of:

• The period reasonably necessary to provide the Services
• The period required by applicable law
• The period needed to support audits, corrections, disputes, or agency inquiries
• The applicable read-only customer-access period
• A legal hold or enforcement period

8. Billing and Business Records

Subscription invoices, payment records, credits, refunds, account status, contracts, and related financial records may be retained for accounting, tax, audit, fraud-prevention, dispute, and legal purposes.

Payment-card information is generally processed by the applicable subscription payment provider. Diversified Payday may retain provider tokens, status information, and transaction references rather than complete card numbers.

9. Website, Analytics, and Advertising Information

Public website information may be retained according to the settings and requirements of the applicable analytics, advertising, security, and hosting providers.

Cookie and privacy choices may be retained for the period stated in the Cookie Policy.

Advertising technologies are not permitted on authenticated payroll-platform routes.

10. Security, Audit, and Diagnostic Records

Authentication events, access logs, permission changes, security alerts, error records, audit trails, and diagnostic information may be retained for periods reasonably necessary to:

• Maintain security
• Investigate incidents
• Detect fraud
• Troubleshoot problems
• Document customer instructions
• Enforce agreements
• Comply with law

Retention periods may vary according to system purpose, risk, storage limitations, and investigative needs.

11. Support and Communications

Support requests, emails, notices, chat records, call notes, consent records, and related communications may be retained to:

• Resolve requests
• Maintain service history
• Train authorized personnel
• Document instructions
• Enforce agreements
• Defend legal claims
• Improve support
• Comply with law

Text-message consent and opt-out records may be retained as necessary to document compliance with messaging requirements.

12. Backups

Information may remain in encrypted or access-controlled backups after deletion from active systems.

Backup copies are protected from ordinary use and are overwritten, expired, or deleted according to the applicable backup cycle and operational requirements.

Restored backup data remains subject to applicable deletion and access restrictions.

13. Deletion Requests

Customers and individuals may request deletion where applicable.

A request may be denied, limited, or delayed when retention is reasonably necessary to:

• Comply with law
• Maintain payroll or tax records
• Complete a transaction
• Provide requested services
• Protect security
• Detect fraud
• Exercise or defend legal claims
• Enforce agreements
• Maintain audit integrity
• Honor a legal hold
• Preserve records controlled by an employer
• Protect the rights of others

Employees and contractors should generally direct requests concerning employer-controlled payroll information to their employer.

14. Account Closure Is Not Immediate Deletion

Cancelling a subscription, disabling a User, placing an account into Seasonal Inactive Status, or closing an account does not automatically delete historical information.

These actions may change access rights and available functionality while retention continues under this policy.

15. Legal Holds

Normal deletion schedules may be suspended when information is relevant to:

• Litigation
• An investigation
• A subpoena
• Government inquiry
• Audit
• Security incident
• Contract dispute
• Anticipated legal claim

Information subject to a legal hold will be retained until the hold is released and any additional applicable retention period is satisfied.

16. Secure Disposal

When information is eligible for deletion, Diversified Payday uses disposal methods appropriate to the system, provider, record type, and available technology.

Methods may include:

• Logical deletion
• Access revocation
• Provider deletion functions
• Expiration under lifecycle rules
• Deletion from active databases
• Deletion or expiration of stored files
• Cryptographic erasure where supported
• Overwriting through provider-managed storage processes
• Backup expiration

No specific disposal method applies universally to every system.

17. De-Identified Information

Diversified Payday may retain aggregated or de-identified information that cannot reasonably be linked to a Customer or identifiable individual.

Such information may be retained for analytics, security, research, product improvement, benchmarking, and business operations.

18. Changes to This Policy

Diversified Payday may revise this policy to reflect changes in law, services, technology, retention practices, or business requirements.

The Last Revised date and version number will be updated when changes are published.

19. Contact Information

Questions or requests may be directed to:

Diversified Payday
A Division of Diversified Company
6212 US Highway 6, Suite 184
Portage, Indiana 46368-5057
Phone: 833-990-7297
Email: CustomerService@ChooseDiversified.com