​Document Owner: Adam
Last Updated: December 24, 2024
Next Review Date: December 24, 2025

1. Purpose

This Data Retention and Disposal Policy establishes guidelines for the collection, retention, and deletion of data within the Lumen Budget application. The policy ensures compliance with applicable data privacy laws while maintaining operational efficiency and protecting user privacy.

2. Scope

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

• User authentication and account information

• Third-party API integration tokens

• Application logs and analytics

• User-generated financial data stored locally on devices

3. Data Architecture Overview

Lumen Budget employs a local-first architecture where sensitive financial data remains on the user's device. The backend infrastructure does not store or process actual financial information (account balances, transactions, personal financial records). All financial data synchronization occurs directly between the user's device and authorized third-party services (Plaid).

Backend systems handle only:

• User authentication via Firebase Authentication

• API token management for Plaid integration

• Minimal application logs for security and debugging purposes

4. Data Categories and Retention Periods

4.1 User Authentication Data

Data Type: Email addresses, Firebase Authentication UIDs, account creation dates
Retention Period: Retained for the lifetime of the active user account
Deletion Trigger: User account deletion request or 2 years of inactivity

4.2 API Access Tokens

Data Type: Plaid Link tokens, Firebase session tokens
Retention Period:

• Plaid tokens: Retained only during active session or until user revokes access

• Firebase tokens: Retained per Firebase Authentication standard session management (typically 1 hour for ID tokens, with refresh tokens valid until revoked)
  Deletion Trigger: User logout, token expiration, or explicit revocation

4.3 Application Logs

Data Type: Authentication attempts, API calls, error logs
Retention Period: 90 days
Deletion Trigger: Automatic deletion after retention period expires
Purpose: Security monitoring, debugging, and system performance analysis

4.4 Local Device Data

Data Type: Financial transactions, account balances, budgets, user preferences (stored on user's device)
Retention Period: Controlled entirely by the user
Deletion Trigger: User-initiated deletion through app interface or device uninstallation
Note: This data never resides on Lumen Budget servers

4.5 Analytics Data (if applicable)

Data Type: Aggregated, anonymized usage statistics
Retention Period: 12 months
Deletion Trigger: Automatic deletion after retention period

5. Data Deletion Procedures

5.1 User-Initiated Account Deletion

When a user requests account deletion:

1. Firebase Authentication account is permanently deleted within 30 days

2. Associated Plaid tokens are immediately revoked

3. Any remaining authentication logs containing user identifiers are purged within 90 days

4. User is notified of successful account deletion via email

5.2 Automated Data Deletion

• Application logs older than 90 days are automatically purged on a monthly schedule

• Expired or revoked API tokens are removed immediately upon expiration/revocation

• Inactive accounts (no login for 2+ years) trigger automated notification to user with 30-day grace period before deletion

5.3 Secure Deletion Methods

• Database records are permanently deleted (not soft-deleted)

• Backup systems purge deleted data within 30 days

• Token revocation requests are immediately sent to third-party services (Firebase, Plaid)

5.4 Local Data Deletion

Users maintain full control over financial data stored locally:

• Data can be deleted through in-app settings

• Complete data removal occurs upon app uninstallation

• Users are responsible for their own device-level data security and deletion

6. Legal Compliance Framework

This policy is designed to comply with:

6.1 General Data Protection Regulation (GDPR)

• Right to erasure (Article 17)

• Data minimization (Article 5)

• Storage limitation (Article 5)

6.2 California Consumer Privacy Act (CCPA)

• Right to deletion (Section 1798.105)

• Consumer data protection requirements

6.3 Other Applicable Laws

• State-level privacy laws

• Financial data protection regulations

• Industry best practices for data security

7. User Rights

Users of Lumen Budget have the following rights regarding their data:

7.1 Right to Access

Users can request information about what data is stored about them

7.2 Right to Deletion

Users can request complete deletion of their account and associated data at any time

7.3 Right to Revoke Access

Users can revoke Plaid integration access at any time, immediately invalidating API tokens

7.4 How to Exercise Rights

Users can exercise these rights by:

• Using in-app settings for data management

• Contacting support at [your contact email]

• Submitting requests through the Lumen Budget website

8. Data Breach Protocol

In the event of a data breach:

1. Affected users are notified within 72 hours

2. Relevant authorities are notified as required by law

3. Immediate investigation and remediation procedures are initiated

4. Compromised credentials and tokens are immediately revoked

5. Post-incident review and policy updates are conducted

9. Third-Party Data Processors

9.1 Firebase (Google)

Purpose: User authentication
Data Shared: Email addresses, authentication UIDs
Retention: Per Firebase/Google privacy policies
Privacy Policy: https://firebase.google.com/support/privacy

9.2 Plaid

Purpose: Financial institution connectivity
Data Shared: API tokens only (no financial data stored by Lumen Budget)
Retention: Per Plaid privacy policies
Privacy Policy: https://plaid.com/legal/

10. Policy Review and Updates

10.1 Review Schedule

This policy is reviewed annually or when:

• Significant changes are made to data processing activities

• New privacy regulations come into effect

• Data breach or security incident occurs

• Changes to third-party service providers

10.2 Version Control

All policy updates are:

• Versioned and dated

• Communicated to users via in-app notification

• Archived for compliance documentation

10.3 Responsibility

Policy review and updates are the responsibility of the application owner/developer.

11. Contact Information

For questions, concerns, or requests regarding this Data Retention and Disposal Policy:

Email: support@lumenbudget.com
Application: Lumen Budget
Last Updated: December 24, 2024

12. Acknowledgment

By using Lumen Budget, users acknowledge and agree to this Data Retention and Disposal Policy. Users will be notified of material changes to this policy and may be required to acknowledge updated versions.

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