Data Retention Policy

This policy explains how long Initek Consulting, Inc. ("we," "us," or "our") keeps the information in Fleet Integrations, how it is deleted, and what happens when a subscription ends. It applies to the Services described in our Privacy Policy and uses the terms "Customer," "Customer Data," and "Services" as defined in our Terms and Conditions. It describes the settings in effect on the date above.

Questions? Contact us at support@initekconsulting.com.

Summary of key points

How long is data kept? It depends on the type. Short-lived records such as notifications and caches are deleted after days or months. Trip records are kept 2 years. Payroll and billing notes are kept 7 years from the date they explain. Account and configuration data is kept for as long as the Customer subscribes. See section 2.

What happens when a subscription ends? We stop processing on the last day of service. For 30 days after, the Customer can ask for a limited export, for an additional fee, and we delete or de-identify its Customer Data within 90 days. See section 5.

Where is it kept? In Amazon Web Services in the United States (Oregon region), with backup copies of user accounts and company settings in the Ohio region. See section 1.

1. How retention works

In Short: Time-limited records are deleted automatically. Everything else is kept while the Customer subscribes and deleted after the subscription ends.

Customer Data is stored in Amazon Web Services in the United States (Oregon region), in databases and file storage that are encrypted at rest. Backup copies of user accounts and company settings are also kept in the Ohio region, as described in section 3. Every Customer record carries that Customer's identifier, and the Services show each Customer only its own data. Service providers listed in section 5 of our Privacy Policy may process copies elsewhere, as described in section 4.

• Automatic deletion. Records with a time limit are deleted automatically after the period in section 2 ends, normally within a few days.
• Life of account. Records marked "life of account" have no automatic time limit. They are deleted when the Customer deletes them in the Services, or after the subscription ends as described in section 5.
• The clock. Each period runs from the event listed in the table. For payroll and billing notes and passenger lists, that is the date the record describes, so editing a record later does not extend it. Bookings and trips count from their last update, so a booking that keeps changing is kept longer.
• Deletion is final. We do not keep an archive of deleted records, apart from the backups described in section 3.
• Exceptions. We may keep information longer where we must to meet a legal obligation, resolve a dispute, or enforce our agreements, and we may keep aggregated or de-identified data that does not identify any Customer or person.

2. Retention schedule

In Short: Each type of record has its own period, set to what the Services need and what Customers are commonly required to keep.

Information	Kept for	Measured from
Bookings and trips, TBN customers	2 years	The later of the trip's finish and its last update
Bookings and trips, Coach Manager and Moovs customers	2 years	Last update
Booking change history	Life of account (Moovs: 2 years)
Trip results: actual times, miles, and hours derived from telematics	Life of account (Coach Manager: 2 years)
Booking export files received by FTP (Coach Manager)	2 years	Upload
Emails and emailed files received for processing, such as payroll punch reports, Samsara reports, and passenger lists	90 days; the information taken from them follows the other rows in this table	Receipt
Vehicle and driver records	Life of account; removed when removed in the Customer's source system
Vehicle status history and vehicle sync history	1 year	Change
Driver scorecards	3 years	Month scored
Payroll and billing notes	7 years	The pay or billing date the note explains
Report history	Life of account
On-time performance results, including the driver for each run	Life of account
Trip notifications to passengers, group contacts, and drivers: message, recipient, and delivery status	90 days	Send
Late alerts, booking alerts, and inbound text and email replies	2 years	Receipt
Hours-of-service, ELD, gateway, and inactivity alerts	1 year	Alert
Text-message delivery and billing records: phone numbers, time, message segments, and delivery receipt, without message text	Life of account
In-app notifications	30 days	Send
Event reports, coaching records, and Bus SOS requests	Life of account; attached files 2 years	Upload, for attached files
Passenger lists	1 year	Trip date
Support tickets	Life of account; attached files 2 years	Upload, for attached files
Fleet Assistant conversations	90 days; a conversation the user clears is archived for 1 year	Last activity, or the day it was cleared
Web application session recordings (FullStory)	30 days	Recording
User accounts, company settings, and settings change history	Life of account
Short links and live tracking links	90 days and 30 days	Creation
Location, address, and telematics caches	30 days or less	Cache write
Sign-in sessions	7 days, renewed while in use, and never more than 30 days after the user last entered a password	Sign-in
Invoices, payment history, and billing contacts	7 years	Invoice date

3. Logs and backups

In Short: Logs are kept up to 180 days. Backups are kept up to 1 year and then deleted.

Application logs are kept for 180 days in Amazon Web Services and 15 days in Datadog. Logs can include request paths, Customer identifiers, and error details. Only our engineering staff can see them.

Backup	Covers	Kept for
Point-in-time recovery	Customer Data in our databases, including bookings and trips, trip results, vehicle and driver records, vehicle status and sync history, driver scorecards, payroll and billing notes, report history, on-time performance results, alerts, notifications and text-message records, event reports, coaching records, Bus SOS requests, passenger lists, support tickets, Fleet Assistant conversations, user accounts, company settings, and settings change history	Rolling 35 days
Daily snapshot	User accounts and company settings, with a copy in a second AWS region in the United States (Ohio)	35 days
Monthly snapshot	User accounts and company settings, with a copy in the Ohio region	1 year

Point-in-time recovery does not cover TBN booking change history; bookings and trip results for customers whose bookings come from FASTTRAK, which are copies of FASTTRAK's own records; location, address, and telematics caches; short links and live tracking links; or files kept outside our databases, such as attached files, booking export files, and emailed files.

Information deleted from the Services remains in these backups until the backup expires, and is then gone. We do not restore deleted information from a backup except to recover from an incident.

4. Copies held by service providers

In Short: A few service providers keep short-lived copies under their own terms.

The service providers in section 5 of our Privacy Policy handle information on our instructions. Those that keep their own copies do so for these periods:

• OpenAI: up to 30 days for abuse monitoring, after which it is deleted. It is not used to train OpenAI's models.
• Datadog: 15 days.
• FullStory: 30 days.
• Google Maps Platform: we cache address lookups for 30 days at most, as Google's terms require.
• Stripe: as long as Stripe must keep payment records for its own legal and tax obligations.
• Heymarket: according to the Customer's own Heymarket settings, for Customers that use it.

Systems a Customer connects, such as its telematics, booking, payroll, and maintenance providers, keep their own copies under their own agreements with the Customer.

5. When a subscription ends

In Short: Processing stops on the last day of service, the Customer can ask for a limited export for 30 days, for a fee, and its data is deleted within 90 days.

1. Last day of service. We stop syncing, alerts, and text messages for the Customer. Its users' access to the Services ends.
2. Export, 30 days. For 30 days after the subscription ends, the Customer may ask for a limited export of its Customer Data, which we provide for an additional fee, as described in section 4 of our Terms and Conditions. Before then, users can download reports themselves.
3. Deletion, within 90 days. We remove the Customer's users and delete or de-identify its Customer Data within 90 days after the subscription ends, including the credentials it gave us for connected systems.
4. Backups and logs. Copies in backups and logs expire on the schedule in section 3.
5. Confirmation. On request, we confirm in writing when deletion is complete.

Invoices and payment records are kept for the period in section 2 to meet our own tax and accounting obligations.

6. Deletion requests and legal holds

• Customer requests. A Customer's administrator can ask support@initekconsulting.com to delete a type of record, a date range, or the whole account before its scheduled time.
• Requests from drivers, passengers, and contacts. Their information is Customer Data controlled by the operator, as described in section 1 of our Privacy Policy. We refer these requests to the operator and act on its instructions.
• Legal holds. When a Customer tells us about a claim, investigation, or other legal matter, we preserve the affected Customer Data until the Customer releases the hold, either by suspending automatic deletion or by keeping a secure export.

7. The Customer's own record-keeping obligations

Rules that apply to bus and motorcoach operators, such as federal hours-of-service, accident-register, and vehicle-maintenance requirements and state payroll-record laws, apply to the operator. As our Terms and Conditions explain, the Services are not a system of record or a backup service. Customers should export and keep the records they are required to keep for longer than the periods above.

8. Changes to this policy

We review this policy at least once a year and whenever a retention setting changes. The "Last updated" date at the top shows the current version. We will notify Customers by email or in the Services at least 30 days before a change that shortens how long we keep information they can see in the Services.

Questions can be sent to support@initekconsulting.com or to Initek Consulting, Inc., Attn: Privacy Officer, 10272 Aviary Dr, San Diego, CA 92131, United States.