Compliance

Records Retention Policy

Effective Date: May 27, 2026

This policy describes baseline retention periods for operational and compliance records maintained by True Home Payment LLC. Retention may be extended when required for legal holds, investigations, contractual obligations, or regulatory requirements.

Retention Schedule

• Lead submission records (form payloads, routing metadata): 4 years from submission date.
• TCPA/SMS consent records (including TrustedForm certificates and consent snapshots): minimum 4 years from consent date.
• Privacy rights request records (access/deletion/correction/opt-out): 4 years from request closure date.
• Do Not Sell/Share and GPC opt-out event records: 4 years from opt-out date.
• Business email correspondence related to lead operations and consumer requests: 4 years.
• Security and access logs relevant to consumer data handling: 1 to 2 years based on system class and risk.

Deletion and Minimization

At the end of each retention period, records are deleted, de-identified, or archived under restricted controls consistent with legal and operational requirements. Where consumer deletion rights apply, requests are processed in accordance with applicable privacy law timelines and documented for audit purposes.

Legal Holds and Exceptions

If litigation, regulatory inquiry, or formal legal hold applies, scheduled deletion may be paused until the hold is lifted. Exceptions must be documented with reason, owner, and review date.

Policy Governance

This policy is reviewed periodically and updated when legal, operational, or data-processing changes require revised retention periods. Questions can be sent to info@truehomepayment.com.