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 |
| Stock watchlist and stock alert settings | Duration of active account | Stock Tracker and stock alert emails |
| AI chat history | Duration of active account | Personalized AI context |
| AI reply sources, charts, and ratings | Until you clear your chat history, or for the duration of your active account | Reloading replies with their sources and charts, finding the causes of poor AI answers, and reading a rated reply with its question to fix mistakes in the tutor (see Privacy Policy §2.8) |
| 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 |
| Province and age (optional, encrypted) | Duration of active account | Tax estimate defaults and age-based Pilot Score benchmarks |
| Transaction categorization model (aggregate, de-identified) | Most recent 3 trained versions | Improves automated categorization accuracy for all users (see §3.1) |
3.1 The Transaction Categorization Model
Pilot Wealth trains and operates its own machine learning model to help assign a spending category to transactions. This model is trained periodically on a combined, de-identified dataset of transaction descriptions and categories drawn from across our user base. See our Privacy Policy §4.1 for what is and is not included in that dataset.
Deleting your account removes your own transaction records immediately, the same as any other data category above, and stops them from being used in any future training run. It does not retroactively alter a model version that was already trained using data that existed at the time. A trained model reflects general word-to-category patterns learned in combination from many users, not a retrievable record of any one person's transactions, so there is no individual copy to remove from it. Only the 3 most recent trained model versions are kept; older versions are deleted outright as each new one is trained.
3.2 Bill Entries Replaced by Bank Transactions
When a bank is connected, Pilot Wealth stops creating its own monthly entries for bills that bank pays, because the real charges arrive with your bank transactions. An entry it created for an earlier month is removed only when your bank's real transaction for the same bill appears, so nothing is counted twice. Your bill settings, bills you pay from an account that isn't connected, and anything you entered yourself are never removed.
3.3 Rated AI Replies
When you rate an AI tutor reply, we may read that reply together with the question it answered, to find and fix mistakes in the tutor. Only the founder does this. The reply and question are the encrypted chat messages already stored for your chat history, and they are kept on the same terms as the rest of that history. Clearing your chat history deletes them, along with the sources, charts, and rating saved with them, and so does deleting your account; this use ends when they are deleted. We do not use them to train an AI model, and they are not sent to xAI.
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, stock watchlist, stock alert settings, income sources, assets, debts, budget settings, AI chat history (including the sources, charts, and ratings saved with replies), resume generations, and Pilot Coins balance and transaction history are all deleted
- Your province and age, if you provided them, are 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 deleted. Transactions you entered yourself are kept
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: Pilot Wealth does not run automated backups or keep a rolling backup copy of the database. Before a major change to the database, we may take a one-off snapshot. Each snapshot is encrypted, stored only on a device we control, and deleted within 14 days of being taken. A record you delete can therefore remain in a snapshot taken before the deletion until that snapshot is deleted, which is at most 14 days
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 are subject to xAI's Privacy Policy. We use xAI's Zero Data Retention setting, so xAI processes each AI request without storing the request or its response
- Resend: email delivery records subject to Resend'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