Approve Owl

Data Retention Policy

LAST UPDATED November 14, 2022

In order to keep organizations compliant with FTC Safeguard rules, Approve Owl limits retention of consumer data to 21 months after profile archiving or a maximum retention period of 25 months total per profile.

Consumers can request removal of their data from our platform before it is set for removal, as is their right by law in certain jurisdictions. We also extend that right to consumers in any jurisdiction as laws are subject to change and subject to adopt stricter data and privacy protections.

Customer Data

If customer data must be kept longer than consumer data due to regulations governing an organization, it is the organization's responsibility to export consumer data from Approve Owl to systems with more appropriate data retention policies. We offer API access and PDF packet downloads of consumer data for moving data to those systems.

Data Removed

When consumer data is set to be removed from our platform, the all data related to the individual consumer is removed from our platform including the following data:

Consumer Data

  • Profile information
  • Phone numbers
  • Addresses
  • Email addresses
  • Employers and other specified income sources
  • References
  • Uploaded documents
  • Generated and aggregated data, such as our compiled Report Card

Third-Party Data

  • Bank account transactions and balances
  • SentiLink scores and insights data
  • Additional address metadata
  • Additional phone number metadata

CRM Data

  • Notes
  • Appointments
  • Inbound text messages
  • Outbound text messages
  • Logged sales data
  • Applicant activity feeds
  • Profile access logs

Ephemeral Data

Approve Owl also logs additional data for active consumers, but we do not consider it core to a consumer profile. This is data that would not necessarily be used for loan consideration by an underwriter.

If the data has not been enumerated above, it is considered ephemeral data. The time of the removal of ephemeral data varies based on the type. Below is a table of the minimum retention period for some data types with the max period being 24 months.

Data TypeMinimum Retention
User Notifications1 week after dismissal
Applicant invite codes90 days after profile archiving
User Reminders90 days after profile archiving
Applicant activity stream90 days after profile archiving
Consumer portal visits and events90 days after event
Raw logged sales import files1 week after import
Raw bank account responses30 days after import

Copyright © 2024 ThirtySixteen Group, LLC. All rights reserved.