Provision record
Plaid · Plaid Terms of Use (Legal Index) [SPA-QUARANTINE: needs human capture] · View original document ↗

Data Retention Following App Disconnection

Medium severity Medium confidence Inferredfromcontext Common · 290 of 352 platforms
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Document Record

What it is

The terms indicate that Plaid may retain consumer financial data after a consumer disconnects an application, subject to described retention limits, and that consumers must separately exercise deletion rights through the Plaid consumer portal to request removal of retained data.

This analysis describes what Plaid'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that disconnecting an application through a partner interface does not automatically result in deletion of financial data from Plaid's systems, and that consumers must take an additional affirmative step through the Plaid portal to request data deletion.

Interpretive note: Specific retention periods and the precise conditions under which data is retained post-disconnection were not directly quotable from the truncated document; description reflects publicly known Plaid data practices and document context.

Recent Activity

This document changed recently

Medium Apr 21, 2026

Developers who use Plaid's services now face expanded accountability for all activities on their accounts and stricter rules around who can access end-user financial data. If developers allow employees, contractors, or other agents to access their accounts, they must ensure those users only access data for approved business purposes and in compliance with Plaid's terms; Plaid reserves the right to monitor this activity through session replay and activity monitoring. Developers should audit which team members have account access, document the business need and approved use case for each, and ensure all authorized users understand their obligations under Plaid's terms.

View change record →
Medium Apr 19, 2026

Plaid's updated terms shift its business model from primarily connecting your accounts to third-party apps toward also providing direct consumer services, including account monitoring and alerts through a new web-based platform called Plaid Web-App. The terms now specify that your Plaid Account can store your financial and identity information, and that Plaid can use this data to provide its own streamlined services (like alerts and notifications) in addition to facilitating third-party app connections. This is not a privacy reduction, but a clarification that Plaid is now a service provider in its own right, not just an intermediary. You may want to review what the Plaid Web-App monitoring service entails and what data it collects, since it is a new direct service from Plaid rather than a third-party app feature.

View change record →
Medium Apr 16, 2026

Plaid has reframed its service model to emphasize a direct relationship between you and Plaid, rather than positioning itself primarily as a bridge to third-party apps. This means Plaid now states it provides services directly to you when you request them. Additionally, Plaid has introduced a new account monitoring and alerts service available via a web application directly to consumers, separate from third-party app integrations. The terms clarify that your Plaid Account remains non-transactional and does not store funds or enable direct payments, but now explicitly mentions it helps third-party apps initiate payments to or from you. You may wish to review the new web-based monitoring service offering and understand what account data it accesses and how it uses that data.

View change record →

Clause Stability Stable

0
Changes
4
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Under this provision, financial account data including transaction history and identity information collected through a Plaid-powered app connection may remain in Plaid's systems after the consumer disconnects the app, unless the consumer separately submits a deletion request at my.plaid.com.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    After disconnecting any app, visit my.plaid.com separately, complete identity verification, and submit a data deletion request to request removal of retained financial data from Plaid's systems.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...

See all platforms with this clause type →

Monitoring

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ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: Post-disconnection data retention engages CCPA/CPRA data minimization and deletion rights, which require businesses to delete personal information upon verified consumer request within 45 days; GDPR's storage limitation principle, which requires personal data not be kept longer than necessary for the stated purpose; and GLBA's data retention and disposal requirements. The CFPB's emerging Section 1033 rulemaking may also address data retention obligations following consumer revocation of data access authorization. 2) GOVERNANCE EXPOSURE: Medium. Retaining financial data after app disconnection without automatic deletion creates regulatory exposure if retention is not adequately justified by a stated lawful purpose and is not disclosed clearly to consumers at the time of disconnection. The absence of automatic deletion upon app disconnection may not align with consumer expectations or certain regulatory minimization principles. 3) JURISDICTION FLAGS: California residents have CPRA rights to request deletion with a 45-day response requirement. EU and UK users have GDPR rights to erasure where data is no longer necessary for its original purpose. States with enacted comprehensive privacy legislation imposing data minimization requirements create additional jurisdiction-specific exposure. 4) CONTRACT AND VENDOR IMPLICATIONS: Developer partners should assess whether their user-facing product flows adequately disclose to consumers that disconnecting an app within the partner application does not delete data held by Plaid, and whether this disclosure is sufficient to satisfy joint GLBA privacy notice obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether post-disconnection retention is supported by a documented lawful purpose for each data category retained; retention schedules should be reviewed against CCPA/CPRA and GDPR storage limitation requirements; and consumer-facing disclosure language should be assessed for clarity regarding the distinction between app disconnection and data deletion.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • CFPB
    The CFPB has authority over consumer financial data practices including data retention following revocation of data access authorization, relevant to its ongoing Section 1033 rulemaking.
    File a complaint →
  • State AG
    State attorneys general in California and other states with privacy laws have enforcement authority over data retention practices that may not comply with statutory deletion and minimization requirements.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Plaid Terms of Use (Legal Index) [SPA-QUARANTINE: needs human capture]
Entity
Plaid
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013097
Document ID
CA-D-00170
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d237d1c00462e75d5d533b760cfa67756e21b1bc9ca5a561b65efe42daabe732
Analysis generated
May 21, 2026 04:58 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Plaid
Document: Plaid Terms of Use (Legal Index) [SPA-QUARANTINE: needs human capture]
Record ID: CA-P-013097
Captured: 2026-05-21 04:58:39 UTC
SHA-256: d237d1c00462e75d…
URL: https://conductatlas.com/platform/plaid/plaid-terms-of-use-legal-index-spa-quarantine-needs-human-capture/provision/CA-P-013097/data-retention-following-app-disconnection/
Accessed: July 26, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Plaid's Data Retention Following App Disconnection clause do?

This provision establishes that disconnecting an application through a partner interface does not automatically result in deletion of financial data from Plaid's systems, and that consumers must take an additional affirmative step through the Plaid portal to request data deletion.

How does this clause affect you?

Under this provision, financial account data including transaction history and identity information collected through a Plaid-powered app connection may remain in Plaid's systems after the consumer disconnects the app, unless the consumer separately submits a deletion request at my.plaid.com.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Plaid?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Plaid.