The purpose of this Policy is to ensure that necessary data and documents of are adequately
protected and maintained and to ensure that records that are no longer needed by or are of
no value are discarded at the proper time. This Policy is also for the purpose of aiding
employees of N-Squared eCommerce Company Limited in understanding their obligations in
retaining electronic documents - including e-mail, Web files, text files, sound and movie
files, PDF documents, and all Microsoft Office or other formatted files.
This Policy represents N-Squared eCommerce Company Limited’s policy regarding
the retention and disposal of data and the retention and disposal of electronic documents.
Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance,
retention and disposal schedule for data of N-Squared eCommerce Company Limited and the retention
and disposal of electronic documents. The Data Protection Officer (the “Administrator”) is the
officer in charge of the administration of this Policy and the implementation of processes and
procedures to ensure that the Data Retention Schedule is followed. The Administrator is also
authorized to: make modifications to the Data Retention Schedule from time to time to ensure
that it is in compliance with laws and includes the appropriate document and data categories
for N-Squared eCommerce Company Limited; monitor laws affecting data retention; annually review
the data retention and disposal program; and monitor compliance with this Policy.
4) Suspension of Data Disposal In Event of Litigation or Claims
In the event N-Squared eCommerce Company Limited is served with any subpoena or request for
documents or any employee becomes aware of an investigation or audit concerning N-Squared
eCommerce Company Limited or the commencement of any litigation against or concerning N-Squared
eCommerce Company Limited, such employee shall inform the Administrator and any further disposal
of documents shall be suspended until shall time as the Administrator, with the advice of counsel,
determines otherwise. The Administrator shall take such steps as is necessary to promptly inform
all staff of any suspension in the further disposal of data.
This Policy applies to data generated in the course of N-Squared eCommerce Company Limited’s operation,
including both original and reproductions.