1. Purpose

This policy establishes guidelines for how CliqSpend retains, archives, and securely disposes of data—including consumer financial data obtained via the Plaid API—in order to minimize risk, comply with applicable laws, and honor commitments made in our privacy policy.

2. Scope

This policy applies to all data collected, processed, or stored by CliqSpend, including:

• Consumer personal and financial data, such as account information and transaction history obtained via Plaid
• Authentication credentials and access tokens
• Employee and contractor records
• System logs, backups, and audit trails
• Marketing and analytics data

3. Data Classification

Classification	Description	Examples
Restricted	Highly sensitive consumer financial data	Account numbers, balances, transaction history, and Plaid access tokens
Confidential	Sensitive internal or personal data	Employee records, authentication credentials, and internal financials
Internal	Business data not for public release	Internal communications and non-sensitive operational data
Public	Information intended for public consumption	Marketing materials and the published privacy policy

4. Retention Periods

• Consumer Financial Data: Plaid-sourced account and transaction data is retained only as long as necessary to provide the service the consumer has requested, and no longer than the duration of the active user relationship plus 90 days.
• Access Tokens: Retained only while the consumer’s account link remains active and revoked or deleted immediately upon disconnection or account closure.
• Account and Profile Data: Retained for the duration of the active account. Upon account closure or deletion request, data is deleted within 30 days except where retention is required by law (see Section 6).
• Authentication and Security Logs: Retained for 12 months to support security monitoring, fraud detection, and incident investigation.
• Employee and Contractor Records: Retained for the duration of employment plus 7 years as required for tax, employment, or legal purposes.
• Backups: System backups are retained for 90 days on a rolling basis and are subject to the same disposal standards as live data.

5. Data Deletion Triggers

Data deletion or de-identification is initiated when:

• A consumer requests account closure or data deletion
• A consumer revokes access via Plaid or disconnects a linked account
• The retention period for the applicable data classification has expired
• A contractual relationship with a vendor or partner ends
• Legal hold requirements have been lifted

6. Legal and Regulatory Holds

Where applicable law, such as GLBA, state financial recordkeeping laws, or tax law, requires retention beyond the standard periods above, data will be retained only for the minimum period required and clearly flagged as under legal hold, exempt from routine deletion processes.

7. Consumer-Initiated Deletion Requests

Consumers may request deletion of their personal data in accordance with applicable privacy laws, such as CCPA and GDPR where applicable.

Requests are verified, processed, and completed within [Insert period, e.g., “45 days”], consistent with our published privacy policy. Confirmation of deletion is provided to the consumer upon completion.

8. Secure Disposal Methods

Digital Data

• Deletion from production databases using secure deletion methods, such as cryptographic erasure or overwrite
• Removal from backup systems upon the next backup cycle following deletion, or immediate purge where technically feasible
• Revocation of associated encryption keys where cryptographic erasure is used

Physical Media

If applicable, hard drives and physical storage media are securely wiped or physically destroyed, such as through degaussing or shredding, prior to disposal or reuse. Disposal is performed by a certified vendor, with certificates of destruction retained.

Third-Party Systems

Where data is stored with subprocessors or cloud providers, contractual agreements require deletion in accordance with this policy and confirmation of deletion upon request.

9. Roles and Responsibilities

• Data Owner — Vernon Smith: Oversees enforcement of retention schedules and disposal practices.
• Engineering Team: Implements automated deletion and archival processes in production systems.
• Customer Support: Processes and escalates consumer deletion requests.
• Compliance/Legal: Advises on legal holds and regulatory retention requirements.

10. Audit and Review

This policy is reviewed at least annually, or upon changes to applicable privacy laws or business practices.

• Deletion processes are periodically audited to confirm compliance with stated retention periods.
• Any exceptions or failures in the disposal process are logged and remediated.

11. Related Documents

• CliqSpend Information Security Policy
• CliqSpend Privacy Policy
• CliqSpend Incident Response Plan

Document Control

Version	Date	Owner	Change
1.0	8/18/2026	Vernon Smith	Initial policy creation