Data Retention Policy

1. Overview

This Retention Policy governs the retention, recovery, and permanent deletion of personal and financial data stored on the Reed Financial Lab Platform (the "Platform"). Our retention practices are designed to: retain data while your service is active so you can use the Platform effectively; provide a structured deletion process with a recovery window so you can restore accidentally deleted items; comply with legal obligations and litigation holds; and minimize unnecessary data retention after your service ends.

All retention calculations are based on your actual service end date — never on document upload dates, statement dates, or record creation dates — except for specific categories noted below.

2. Service-Based Retention (Most Document Categories)

The following document categories follow the standard service-based retention schedule: Bank or credit-card statements, loan or debt statements, retirement or brokerage statements, budget or cash-flow documents, goal or action-plan documents, financial plans or assessments, coaching or meeting summaries, agreements/disclosures/consents, and other RFL documents.

While your service is Active or Paused: Documents are retained indefinitely. No deletion date is scheduled. You may delete documents at any time through the Document Center.

When your service is Ended: Documents become eligible for deletion 90 days after your actual service end date. On the eligible deletion date, documents enter a 30-day Recovery period (see Section 5).

If your service is reactivated before permanent deletion: All deletion dates are cancelled and recoverable documents return to Active status.

3. Identity-Verification Documents

Identity-verification documents are retained for 90 days after your identity verification date. If no verification date has been recorded, the document is retained until verification occurs. There is no fallback to the upload date or current date. After 90 days post-verification, these documents enter the standard 30-day Recovery period before permanent deletion.

4. Billing Records

Billing records follow the same service-based schedule as standard document categories: retained while your service is Active or Paused, and eligible for deletion 90 days after your actual service end date. After the eligible deletion date, billing records enter the 30-day Recovery period.

5. Recovery Period and Permanent Deletion

When a document or record reaches its eligible deletion date (either through the service-end schedule or through a client-initiated deletion), it enters a 30-day Recovery period. During this period:

The item is marked as "Recovery" status and is no longer visible in your active document list. The recovery window is calculated from the moment the item enters Recovery status (not from the eligible deletion date), ensuring a full 30-day window even if the daily processing runs late. You may request restoration of the item during this period. The permanent deletion date is set to 30 calendar days after the Recovery start date.

After the permanent deletion date, the item is permanently purged from our systems. Permanent deletion is irreversible. An audit trail (recording that the deletion occurred, when, and by whom) is retained even after the document content is permanently deleted.

6. Client-Initiated Deletion

You may request deletion of your documents at any time through the Document Center. Client-initiated deletions enter the standard 30-day Recovery period and are subject to the same permanent deletion process. If you request deletion, the recovery window and permanent deletion date are set based on your request — the daily retention process will not override them. You may request restoration during the Recovery period through the Platform or by contacting us.

7. Support, Complaint, and Dispute Documents

Documents associated with a support case, complaint, or dispute are retained while the related case is open. When the case is closed, the document follows the standard service-based retention schedule. If a case is resolved (including auto-closure after 14 days without a client response), any legal holds placed on related documents are automatically removed and retention is recalculated.

8. Support Case Records

Support case records (including case descriptions, resolution notes, and audit trails) follow the standard service-based retention schedule: retained while your service is Active or Paused, and eligible for deletion 90 days after your actual service end date. Case records then enter the 30-day Recovery period. Legal holds on cases override all deletion actions.

9. Legal Holds

A legal hold overrides all retention and deletion schedules. When a legal hold is applied to a document or case, the item is preserved indefinitely until the hold is removed. Legal holds may be applied by authorized administrators when required by litigation, regulatory inquiry, or other legal obligations.

When a legal hold is removed (e.g., when a related support case is resolved), retention is recalculated based on your current service status. If your service has been reactivated, deletion dates are cleared and the item returns to Active status.

Legal hold records include the reason, date, case number, and authorizing admin. This information is retained as part of the item's audit trail.

10. Account Deletion

You may request deletion of your entire account at any time through the Platform settings. Account deletion initiates the following process: Your service status is set to Ended, with the current date recorded as your actual service end date. All documents and records become eligible for deletion 90 days after the service end date. After the eligible deletion date, items enter the 30-day Recovery period. Permanent deletion occurs after the Recovery period.

In total, full account deletion takes approximately 120 days from the date of your request (90-day retention + 30-day recovery). During this period, your data is preserved in case you change your mind. Once permanent deletion is complete, your data cannot be recovered.

Audit trails (records of actions taken on your account) are retained even after your personal data is permanently deleted, for legal and operational record-keeping.

11. Staff and Coach Data Retention

Staff and coach records are subject to a separate business-records retention schedule. When a coach or staff member is deactivated: Their role is set to inactive and their access to the Platform is revoked. Their client assignments are removed (clients are unassigned, not deleted). A 90-day retention period begins for their personal data.

After 90 days of inactivity, the staff member's personal data is purged from administrative visibility while their historical records and audit trails are preserved as business records. If the staff member is reactivated within the retention period, all retention and purge flags are cleared and their data is restored.

Deactivated coaches are completely blocked from accessing the Platform. They cannot fall back into the client-facing view. Reactivation requires a new administrative invitation.

12. Audit Trails

Audit trails (records of actions taken on documents, cases, and accounts — including who took the action, when, and what was done) are retained as business records and are not subject to the standard client-data retention schedule. Audit trails are preserved for legal, compliance, and operational purposes even after the underlying personal data is permanently deleted.

13. Data Subject to Legal Obligations

Where applicable law, regulation, or contractual obligation requires us to retain certain data for a specific period (e.g., tax records, billing records, or records subject to regulatory examination), we will retain that data for the required period notwithstanding the schedules in this policy. Legal holds take precedence over all retention schedules.

14. Daily Retention Processing

Retention schedules are processed daily by an automated workflow. The workflow: identifies items that have reached their eligible deletion date; transitions them to Recovery status and sets their permanent deletion date; permanently deletes items past their permanent deletion date (unless a legal hold is in place); and recalculates retention for items whose service status has changed. This daily process ensures that retention schedules are applied consistently and that recovery windows are respected.

15. Changes to This Policy

We may update this Retention Policy from time to time. We will post the updated policy on this page with a revised "Last updated" date. If we make material changes, we will provide notice through the Platform or by email. Changes to retention periods will apply prospectively and will not shorten any active recovery window.

16. Contact Us

If you have questions about this Retention Policy or wish to exercise your data retention or deletion rights, please reach out to support@reedfinanciallab.com or via our Contact page.