BAMBEE, INC. USER DOCUMENT RETENTION AND DESTRUCTION POLICY


  1. Policy and Purposes

    This Policy represents the policy of Bambee, Inc. (the “Company”) with respect to the retention and destruction of Customer (“Users”) documents and other records, both in hard copy and electronic media (collectively, “Documents”). Purposes of the Policy include (a) retention and maintenance of User documents. Notwithstanding the foregoing, the Company reserves the right to revise or revoke this Policy at any time.

    Please refer to our Privacy Policy for more information on the manner in which Company collects, uses, discloses and otherwise treats your personal information. The Privacy Policy is fully incorporated herein by reference.

  2. Administration

    2.1 Responsibilities of the Administrator. The Company’s CTO shall be the administrator (“Administrator”) in charge of the administration of this Policy. The Administrator’s responsibilities shall include supervising and coordinating the retention and destruction of User documents pursuant to this Policy and particularly the Document Retention Schedule included below. The Administrator shall also be responsible for documenting the actions taken to maintain and/or destroy Company documents and retaining such documentation. The Administrator is also authorized to periodically review this Policy and Policy compliance with legal counsel. The Administrator may also appoint one or more assistants to assist in carrying out the Administrator’s responsibilities, with the Administrator, however, retaining ultimate responsibility for administration of this Policy.

  3. Suspension of Document Destruction; Compliance.

    The Company becomes subject to a duty to preserve (or halt the destruction of) documents once proper notification of litigation has been received. Proper notification must be made in writing, and mailed with tracking information available to verify delivery to the address below. Additional notification or tracking information may be electronically mailed to the below email address, although is not effective until written notification is received.

    Bambee, Inc.
    127 Broadway
    Suite 200
    Santa Monica, CA 90401
    Attention: Legal Administrator
    Email: [email protected]

  4. Electronic Documents; Document Integrity

    Documents in electronic format shall be maintained just as hard copy or paper documents are, in accordance with the Document Retention Schedule. Due to the fact that the integrity of electronic documents, whether with respect to the ease of alteration or deletion, or otherwise, may come into question, the Administrator shall attempt to establish standards for document integrity, including guidelines for handling electronic files, backup procedures, archiving of documents, and regular checkups of the reliability of the system; provided, that such standards shall only be implemented to the extent that they are reasonably attainable considering the resources and other priorities of the Company.

  5. Privacy

    It shall be the responsibility of the Administrator, after consultation with counsel, to determine how privacy laws will apply to the Company’s documents from and with respect to employees and other constituencies; and to establish reasonable procedures for compliance with such privacy laws.


  6. Emergency Planning

    Documents shall be stored in a safe and accessible manner. Documents which are necessary for the continued operation of the Company in the case of an emergency shall be regularly duplicated or backed up and maintained in an off-site location. The Administrator shall develop reasonable procedures for document retention in the case of an emergency.

  7. Document Creation and Generation

    The Administrator shall discuss with staff the ways in which documents are created or generated. With respect to each employee or Company function, the Administrator shall attempt to determine whether documents are created which can be easily segregated from others, so that, when it comes time to destroy (or retain) those documents, they can be easily culled from the others for disposition.

  8. Document Retention Schedule

    Document Type

    Retention Period

    -Accounting and Finance-

    Accounts Payable

    7 years

    Accounts Receivable

    7 years

    Annual Financial Statements and Audit Reports

    Permanent

    Bank Statements, Reconciliations & Deposit Slips

    7 years

    Canceled Checks – routine

    7 years

    Canceled Checks – special, such as loan repayment

    Permanent

    Credit Card Receipts

    3 years

    Employee/Business Expense Reports/Documents

    7 years

    General Ledger

    Permanent

    Interim Financial Statements

    7 years

    -Corporate and Exemption-

    Articles of Incorporation and Amendments

    Permanent

    Bylaws and Amendments

    Permanent

    Minute Books, including Board & Committee Minutes

    Permanent

    Annual Reports to Attorney General & Secretary of State

    Permanent

    Other Corporate Filings

    Permanent

    IRS Exemption Application (Form 1023 or 1024)

    Permanent

    IRS Exemption Determination Letter

    Permanent

    State Exemption Application (if applicable)

    Permanent

    State Exemption Determination Letter (if applicable)

    Permanent

    Licenses and Permits

    Permanent

    Employer Identification (EIN) Designation

    Permanent

    -Correspondence and Internal Memoranda-

    Hard copy correspondence and internal memoranda relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate.

    Hard copy correspondence and internal memoranda relating to routine matters with no lasting significance

    Two years

    Correspondence and internal memoranda important to the Company or having lasting significance

    Permanent

    -Electronic Mail (E-mail) to or from the Company-

    Electronic mail (e-mails) relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate, but may be retained in hard copy form with the document to which they relate.

    E-mails considered important to the Company or of lasting significance should be printed and stored in a central repository.

    Permanent

    E-mails not included in either of the above categories

    12 months

    -Electronically Stored Documents-

    Electronically stored documents (e.g., in pdf, text or other electronic format) comprising or relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document which they comprise or to which they relate, but may be retained in hard copy form (unless the electronic aspect is of significance).

    Electronically stored documents not included in either of the above categories

    Two years

    -Employment, Personnel and Pension-

    Personnel Records employment ends

    10 years after

    Employee contracts termination

    10 years after

    Retirement and pension records

    Permanent

    -Insurance-

    Property, D&O, Workers' Compensation and General Liability Insurance Policies

    Permanent

    Insurance Claims Records

    Permanent

    -Legal and Contracts-

    Contracts, related correspondence and other supporting documentation

    10 years after

    Termination legal correspondence

    Permanent

    -Management and Miscellaneous-

    Strategic Plan

    7 years after expiration

    Disaster Recovery Plan Replacement

    7 years after

    Policies and Procedures Manual

    Current Version with Revision History