Data Retention Policy

Effective Date: March 2026Last Updated: March 29, 2026Version: 1.0

How Long We Keep Your Data

CAIRL retains your data only as long as necessary to provide our services, comply with legal obligations, and prevent fraud. This policy expands on the retention schedule described in our Privacy Policy.

Retention Schedule

Data TypeRetention PeriodNotes
Account information (email, name, preferences)Until account deletionYou can close your account at any time
Raw identity document imagesUntil you delete them or account closure + 30 daysYou can delete document images at any time through your account
Biometric session data (raw processing)Duration of verification session onlyEphemeral — not retained after session completes
Biometric reference (facial embedding)Until account deletion + 30 daysUsed for uniqueness enforcement and fraud prevention. Deletable at your request at any time
Verification records (results, timestamps, attestations)Up to 7 yearsRetained to meet regulatory, audit, and fraud prevention obligations as applicable
Proxy email relay metadata90 daysSender, recipient, timestamps for abuse prevention
Usage logs90 daysIP, browser, device information
Payment and billing recordsDuration of business relationship + 7 yearsTax and legal compliance obligations
Partner API credentials and webhook configurationsDuration of business relationshipDeleted on account closure
Audit logs (routine)90 daysStandard operational logging
Audit logs (security events)PermanentSecurity incidents, access violations, rejected authentication attempts

Biometric Data

Biometric references (facial embeddings) associated with your account are permanently destroyed within 30 days of: your deletion request, your withdrawal of consent, or your account closure.

Raw biometric session data (such as selfie processing results) is ephemeral and is not retained beyond the verification session.

Biometric data is not used to track your behavior across unrelated services.

For full details on how biometric data is collected, used, and protected, see our Privacy Policy and Biometric Data Policy.

What We Never Retain

  • Raw selfie images after face comparison completes
  • Plaintext passwords
  • Full payment card numbers (handled by Stripe)
  • Bank login credentials (handled by Plaid)

Your Rights

You may request deletion of your data at any time by contacting privacy@cairl.app or through your account settings. Data may persist in secure, isolated backups for a limited period and is automatically deleted in accordance with backup retention schedules.

Verification records may be retained for up to 7 years even after account closure, as required for regulatory, audit, and fraud prevention obligations. These records do not contain your document images, biometric references, or biometric session data.

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