Document Retention and Destruction Policy

Effective Date: September 1, 2025
Company: 1438076 B.C. LTD. Operating as "Dealmaker"

PURPOSE AND SCOPE

This Document Retention and Destruction Policy ("Policy") establishes guidelines for the systematic review, retention, and destruction of documents and records created or received by 1438076 B.C. LTD., operating as Dealmaker ("Company," "we," "us," or "our"). This Policy applies to all Company personnel, contractors, and third-party service providers who create, receive, maintain, or have access to Company documents and records.

POLICY STATEMENT

The Company maintains a policy of routine document destruction to minimize storage costs, reduce legal exposure, and ensure compliance with applicable laws and regulations. Documents and records shall be retained only for the minimum period required by law or business necessity, after which they shall be systematically destroyed in accordance with this Policy.

DEFINITIONS

Document/Record: Any recorded information, regardless of medium or characteristics, created, received, or maintained by the Company in the conduct of its business activities, including but not limited to:

Electronic files and databases
Email communications
Customer information and communications
Financial records and transaction data
Training materials and course content
Marketing and promotional materials
Legal documents and contracts
Personnel records
Meeting minutes and notes

Destruction: The irreversible elimination of documents and records such that they cannot be reconstructed or retrieved.

RETENTION SCHEDULE

General Business Documents

Retention Period: 30 days from creation or receipt
Scope: All business documents not specifically covered by other retention categories

Customer Communications

Retention Period: 30 days from final communication
Scope: Email correspondence, chat logs, support tickets, and other customer interactions

Marketing Materials

Retention Period: 30 days from publication or distribution
Scope: Advertisements, promotional content, social media posts, and marketing campaigns

Financial Transaction Records

Retention Period: 30 days from transaction completion
Scope: Payment processing records, refund requests, and billing information

Training and Educational Content

Retention Period: 30 days from last access or modification
Scope: Course materials, training videos, educational resources, and related documentation

Legal and Compliance Documents

Retention Period: 30 days from expiration or termination
Scope: Contracts, agreements, compliance reports, and legal correspondence

EXCEPTIONS TO STANDARD RETENTION

Legal Hold

When the Company becomes aware of pending, threatened, or reasonably anticipated litigation, government investigation, or audit, all potentially relevant documents must be preserved regardless of their normal retention period until the legal hold is lifted by legal counsel.

Regulatory Requirements

Documents subject to specific regulatory retention requirements shall be retained for the period mandated by applicable law, provided such period does not exceed 30 days unless specifically required by statute.

Business Critical Records

The following documents may be retained beyond the standard 30-day period only with written approval from senior management:

Corporate formation documents
Insurance policies (current)
Intellectual property registrations
Tax returns (current year only)

DESTRUCTION PROCEDURES

Automated Destruction

The Company shall implement automated systems to ensure documents are destroyed at the end of their retention period without manual intervention. Electronic records shall be permanently deleted using industry-standard data destruction methods.

Secure Destruction

All document destruction shall be performed using secure methods appropriate to the sensitivity of the information:

Electronic Records: Multi-pass overwriting or cryptographic erasure
Physical Documents: Cross-cut shredding or incineration
Storage Media: Physical destruction or degaussing

Documentation of Destruction

The Company shall maintain a destruction log recording:

Types of documents destroyed
Destruction dates
Destruction methods used
Personnel responsible for destruction

Note: The destruction log itself shall be retained for 30 days from the date of each destruction event.

RESPONSIBILITIES

Management

Ensure Policy compliance across all departments
Approve exceptions to standard retention periods
Authorize legal holds when necessary
Provide resources for Policy implementation

IT Department

Implement automated destruction systems
Ensure secure destruction of electronic records
Maintain backup and recovery procedures consistent with retention schedules
Monitor compliance with electronic record destruction requirements

All Personnel

Comply with document retention and destruction requirements
Report potential legal holds to management
Avoid creating unnecessary documents or records
Participate in training on Policy requirements

COMPLIANCE AND MONITORING

Regular Review

This Policy shall be reviewed annually and updated as necessary to reflect changes in business operations, legal requirements, or industry best practices.

Compliance Monitoring

The Company shall conduct periodic audits to ensure compliance with this Policy and take corrective action when necessary.

Training

All personnel shall receive training on this Policy upon hire and annually thereafter.

LEGAL CONSIDERATIONS

Obstruction of Justice

This Policy is designed to ensure routine, good-faith document destruction in the ordinary course of business. Any attempt to destroy documents to impede a legal proceeding, investigation, or audit is strictly prohibited and may constitute obstruction of justice.

Regulatory Compliance

While this Policy establishes a 30-day retention period for most documents, the Company acknowledges that certain regulatory requirements may mandate longer retention periods. In such cases, documents shall be retained for the minimum period required by law.

Litigation Readiness

The Company maintains this Policy to minimize document retention while ensuring compliance with legal obligations. The systematic destruction of documents in accordance with this Policy is a legitimate business practice designed to reduce storage costs and legal exposure.

POLICY ENFORCEMENT

Violations of this Policy may result in disciplinary action, up to and including termination of employment or contractual relationships. Intentional destruction of documents subject to legal hold or regulatory requirements may result in civil and criminal liability.

CONTACT INFORMATION

Questions regarding this Policy should be directed to:

Email: contact@thedealmaker.io
Phone: 778-986-3435

POLICY APPROVAL

This Policy has been approved by the management of 1438076 B.C. LTD. and shall remain in effect until modified or superseded.

Effective Date: September 1, 2025
Next Review Date: September 1, 2026

IMPORTANT NOTICE: This Policy is designed to establish routine document destruction procedures in the ordinary course of business. Any legal hold or regulatory requirement supersedes the standard retention periods outlined in this Policy. Personnel must immediately cease document destruction and notify management upon becoming aware of any litigation, investigation, or audit that may require document preservation.

Disclaimer:

The DealMaker program is an educational offering designed to teach business strategy, deal structuring, and capital raising frameworks. It does not promise or guarantee earnings, results, or specific outcomes of any kind. The examples and case studies shared in the video and on this page, including those involving 6-, 7-, or 8-figure commissions and 9-figure transactions, are extraordinary and non-typical. These results are not a guarantee of what you should expect, and the vast majority of participants will not achieve similar outcomes. We do not claim that success is easy, fast, or guaranteed. Deal-making, investment banking, and capital raising are complex, highly regulated fields that require skill, persistence, and legal compliance. Results depend entirely on individual effort, experience, market conditions, and the ability to follow through on the training provided. Some participants in the program may already have backgrounds in finance, sales, entrepreneurship, or professional services, which may influence their outcomes. No prior finance degree or Wall Street experience is required, but prior business or sales experience may enhance your ability to apply the program’s concepts. Nothing in this presentation or on this website should be construed as financial, legal, or investment advice. We are not acting as financial advisors, and this content is not a recommendation to buy or sell any financial instrument or participate in any specific deal. This offering is intended for accredited investors and professionals who understand the risks of business and capital markets. If you are not sure what that means, consult with a qualified advisor before making any decisions. As required by law, we do not and cannot make any guarantees about your ability to earn money using our ideas, tools, or strategies. Your business is your responsibility. Your results are your responsibility.

Earnings Disclosure

According to data from the U.S. Bureau of Labor Statistics, the odds of building a business that generates $10 million per year are approximately 0.1%. That means 99.9% of businesses never reach that level. While some members of our community have reported earning 7- and 8-figure commissions or closing 9-figure transactions, these outcomes are not typical. Average reported gross revenue among active and former members of the Dealmaker program generally ranges from $50,000 to $300,000 per month, depending on their level of activity and previous experience. This is not a promise or a prediction, simply a reflection of historical data from program participants. Ultimately, your effort, consistency, and judgment will determine your success.