Data Retention and Disposal Policy
This policy defines how Pilot Wealth retains, manages, and permanently disposes of consumer data in compliance with Canada's PIPEDA and applicable privacy legislation.
1. Purpose and Scope
This Data Retention and Disposal Policy governs how Pilot Wealth retains and disposes of personal and financial data collected through the Pilot Wealth platform. It applies to all data collected from users including financial account data, transaction history, investment holdings, personal profile information, and any data received via third-party integrations such as Plaid.
This policy is designed to ensure Pilot Wealth retains data only for as long as necessary to provide services and meet legal obligations, and that data is disposed of securely when no longer needed.
2. Data Retention Principles
Pilot Wealth adheres to the following principles for data retention:
- Minimum necessary retention — data is retained only as long as required to provide the service or meet legal obligations
- Purpose limitation — data is not retained beyond the purpose for which it was collected
- User control — users may request deletion of their data at any time
- Secure disposal — data is permanently and irreversibly deleted when no longer needed
3. Data Retention Schedule
The following table outlines retention periods for each category of data:
| Data Category | Retention Period | Basis for Retention |
|---|---|---|
| Plaid access tokens | Duration of active bank connection | Required to maintain bank sync functionality |
| Transaction history | Duration of active account | Core service functionality |
| Account balances and holdings | Duration of active account | Core service functionality |
| AI chat history | Duration of active account | Personalized AI context |
| Income and budget settings | Duration of active account | Core service functionality |
| Subscription and billing records | 7 years after account closure | Canadian tax and financial record obligations |
| Security and access logs | Up to 30 days | Security monitoring and incident response |
| Pilot Coins balance and transaction ledger | Duration of active account | Deleted permanently on account closure |
4. User-Initiated Data Deletion
Pilot Wealth provides users with full self-service account and data deletion directly within the application. When a user deletes their account:
- All personal financial data is permanently deleted from the database immediately
- Transaction history, account balances, investment holdings, income sources, assets, debts, budget settings, AI chat history, resume generations, and Pilot Coins balance and transaction history are all deleted
- Plaid access tokens are revoked with Plaid and deleted from our database
- The Clerk user account is permanently deleted
- Active Stripe subscriptions are cancelled immediately
- Billing records are retained for 7 years as required by Canadian law
5. Bank Connection Disconnection
Users may disconnect individual bank connections at any time without deleting their full account. When a bank connection is removed:
- The Plaid access token for that institution is revoked with Plaid and deleted from our database immediately
- All synced accounts and investment holdings associated with that connection are removed
- Transaction history previously synced from that institution is retained as part of the user's financial record until full account deletion
6. Data Disposal Procedures
When data reaches the end of its retention period or a deletion request is received, Pilot Wealth ensures permanent disposal through the following methods:
- Database records — permanently deleted via SQL DELETE operations. Records are not soft-deleted or archived
- Plaid access tokens — revoked via Plaid's API before database deletion, ensuring the token cannot be used even if somehow recovered
- Clerk user accounts — permanently deleted via Clerk's API, removing all authentication data
- Backups — Database records deleted via the disposal process described above are not retained in any backup archive. Pilot Wealth does not maintain a rolling backup copy of deleted data
7. Third-Party Data Retention
Pilot Wealth uses third-party services that maintain their own data retention policies. Users should refer to the relevant policies for each:
- Plaid — subject to Plaid's Privacy Policy and data retention practices
- Stripe — payment and billing records retained per Stripe's Privacy Policy and financial regulations
- Clerk — authentication records subject to Clerk's Privacy Policy
- xAI — AI interactions subject to xAI's Privacy Policy
8. Compliance
This policy is designed to comply with:
- Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
- Applicable Canadian provincial privacy legislation
- Plaid's Developer Policy and data handling requirements
9. Policy Review
This policy is reviewed at minimum annually and updated whenever there are material changes to our data practices, applicable law, or third-party integrations. The last review date is shown at the top of this document.
Data and Privacy Contact
For questions about data retention, disposal, or to submit a deletion request:
Pilot Wealth, Canada