Data Retention & Disposal Policy
Standards and procedures for retaining, archiving, and securely disposing of consumer data, financial records, and API credentials across Parakith LLC and PanoramaDr services.
Effective Date: November 14, 2026•Last Updated: November 14, 2026
Parakith LLC (Umbrella Entity for PanoramaDr Services)
Office of the Managing Member • API Governance & Data Security
1. Purpose and Scope
This Data Retention and Disposal Policy defines the mandatory standards and operational procedures for retaining, archiving, and securely disposing of consumer data, financial records, and credentials acquired through the operation of Parakith LLC and its managed services (including the PanoramaDr suite of services).
This policy applies to all active application services, storage resources, and third-party integrations—specifically API connections established through Plaid Inc. and telecommunications pipelines established through Twilio Inc.
2. Regulatory and Compliance Alignment
This policy is established to ensure compliance with applicable data privacy frameworks, consumer consent requirements, financial data exchange (FDX) standards, and third-party API provider agreements. It enforces four core principles:
- Data Minimization: Only data strictly required to deliver active monitoring, communication, and ledger reconciliation services is collected.
- Storage Limitation: Data is kept in an identifiable form only as long as necessary for the specified purposes.
- Integrity and Confidentiality: All retained data is protected by encryption at rest and in transit.
- Consumer Right to Erasure: Consumers and authorized users retain the right to terminate connections and demand immediate, total data deletion.
3. Data Classification and Retention Schedule
Data processed by Parakith LLC is categorized and maintained according to the following retention periods and storage controls:
| Data Category | Data Elements | Retention Period | Storage Controls & Encryption |
|---|---|---|---|
| Financial API Credentials | Plaid access tokens, item identifiers, and synchronization state. | Retained only for the duration of the active connection. Invalidated immediately upon disconnection. | Encrypted at rest (AES-256) with restricted administrative access controls. |
| Financial Ledger Data | Account metadata, masked numbers, balances, transaction records, and normalized merchant names. | Retained only for the duration of active user authorization. Permanently purged within 24 to 48 hours upon disconnection, account closure, or an explicit deletion request. | Encrypted at rest (AES-256). Accessible only via authenticated administrative channels. |
| SMS Telecommunications Data | Subscriber name, mobile phone numbers, opt-in consent records and timestamps, and opt-out flags (STOP). | Maintained until user opt-out or service decommissioning. Opt-out flags preserved to suppress future SMS. | Stored with strict access controls and excluded from all third-party marketing sharing. |
| System & Security Logs | Access logs and operational security audit records (excluding banking credentials, API access tokens, and raw financial transaction payloads). | 90-day rolling retention cycle; rotated and purged automatically. | Restricted administrative directory with controlled access permissions. |
| Raw Banking Credentials | Banking usernames, passwords, multi-factor authentication (MFA) codes/answers, full account numbers. | 0 Days (Never collected, retained, or processed). | Handled exclusively via direct financial institution OAuth 2.0 handshake or Plaid Link modal. |
4. Data Disposal and Sanitization Procedures
When data reaches its retention threshold, an Item connection is revoked, or an authorized consumer requests deletion, data is permanently sanitized using the following procedures:
4.1 Financial Data and API Token Invalidation
- Plaid Token Invalidation: When a bank connection is removed, the service immediately executes an API call to Plaid's
/item/removeendpoint, ensuring that Plaid access and third-party data polling are immediately terminated. - Record Deletion: Stored account identifiers, historical transactions, pending events, and sync states associated with that Item are permanently purged and overwritten.
- Cache Purging: Any temporary cached records referencing the Item are cleared immediately.
4.2 Media Sanitization
- All persistent storage resources designated for decommissioning are sanitized in accordance with NIST SP 800-88 Guidelines for Media Sanitization.
- Decommissioned storage media containing residual financial or personal records undergoes cryptographic erasure or destruction prior to disposal.
- Non-production environments never retain copies of production financial records or live Plaid access tokens.
4.3 Backup Lifecycle and Non-Restoration
- Encrypted backups rotate on a fixed rolling schedule and are automatically purged and overwritten upon expiration.
- Purged financial ledger records and invalidated API access tokens are never restored into active production systems from historical snapshots.
5. Consumer Consent, Revocation, and Deletion Requests
Parakith LLC strictly honors consumer data rights:
- Opt-In Consent: Consent for data processing is obtained directly prior to ingestion (via the Plaid Link OAuth handshake for financial data and via verified opt-in portals for SMS alerts).
- Self-Service Revocation: Users can revoke third-party API consent at any time within the application dashboard, via the Plaid Portal, or directly through their participating financial institution's connected-apps security portal.
- Direct Deletion Requests: Users may submit a written deletion request at [email protected] or [email protected]. Upon receiving a verified request, we will execute a complete purge of the user's records within 24 to 48 hours and provide written confirmation of deletion.
6. Policy Review and Enforcement
- Periodic Audit: This policy is formally reviewed on an annual basis (or following any material operational change) to ensure ongoing compliance with privacy standards and API contractual obligations.
- Enforcement: Compliance with this policy is enforced through periodic auditing and strict access control monitoring.
7. Contact Information
For data retention, revocation, or disposal inquiries, contact:
Parakith LLC
United States
Email: [email protected] • [email protected]