The policy establishes that personal data is retained as long as necessary for service provision or business purposes, with extended retention permitted for legal obligations, dispute resolution, or fee collection, without specifying fixed retention periods for most data categories.
This analysis describes what Figure AI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The retention framework does not establish fixed deletion timelines for most personal data categories, instead applying a necessity standard that permits indefinite retention in operational or legal contexts. The policy specifically notes that device and IP data is retained for as long as needed to ensure systems operate appropriately, without a defined outer limit.
The agreement establishes that personal data, including device and IP data, is retained without fixed deletion timelines under a necessity standard that permits extended retention for legal obligations or dispute resolution. Users in states with data minimization or retention limitation requirements should be aware that the policy does not specify maximum retention periods for most data categories.
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"We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.— Excerpt from Figure AI's Figure AI Privacy Policy
1) REGULATORY LANDSCAPE: Data retention limitations are a core requirement under GDPR Article 5(1)(e) (storage limitation principle) and are addressed under CCPA and CPRA through the requirement that retention periods be disclosed in privacy policies. Several U.S. state privacy laws require that data not be retained longer than necessary for the disclosed purpose. The absence of specific retention periods for most categories may create disclosure adequacy issues under these frameworks. 2) GOVERNANCE EXPOSURE: Medium. The open-ended retention standard, particularly for device and IP data, may not satisfy storage limitation or data minimization requirements under applicable state privacy laws or GDPR if EU users are in scope. The policy's examples of retention (contact form data and device/IP data) leave most other categories without defined periods. 3) JURISDICTION FLAGS: EU and UK GDPR create the most prescriptive retention limitation obligations, requiring specific retention periods or criteria for determining them. California (CPRA) requires privacy policies to disclose retention periods or the criteria used to determine them for each category of personal information. Colorado and other state laws similarly address retention requirements. 4) CONTRACT AND VENDOR IMPLICATIONS: Service provider agreements should include contractual retention limitations aligned with applicable law, particularly for vendors processing sensory or biometric data categories. Audit rights over vendor retention practices should be assessed. 5) COMPLIANCE CONSIDERATIONS: A data retention schedule specifying maximum retention periods for each personal data category should be evaluated, particularly for sensory data, geolocation data, and professional data. If EU or UK users access the services, a GDPR-compliant retention policy with specific criteria or timelines for each category is required. Compliance teams should assess whether the current disclosure satisfies CPRA's retention period disclosure requirement.
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The retention framework does not establish fixed deletion timelines for most personal data categories, instead applying a necessity standard that permits indefinite retention in operational or legal contexts. The policy specifically notes that device and IP data is retained for as long as needed to ensure systems operate appropriately, without a defined outer limit.
The agreement establishes that personal data, including device and IP data, is retained without fixed deletion timelines under a necessity standard that permits extended retention for legal obligations or dispute resolution. Users in states with data minimization or retention limitation requirements should be aware that the policy does not specify maximum retention periods for most data categories.
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