D6 · Data retention and deletion
This policy sets which data Bolívar Connect processes, how long it keeps it and how it deletes it. It complements Coco’s published privacy policy (in Spanish).
1. Principles
Section titled “1. Principles”- Minimization: only the data essential to execute and trace each payment is processed.
- Storage limitation: no record with personal data is kept indefinitely.
- Protection throughout the data’s life: encryption in transit and at rest, tenant isolation, and no personal data in clear text in the logs.
- Role: regarding the beneficiary data sent by clients, the platform acts as a data processor on behalf of the client.
2. Inventory and retention periods
Section titled “2. Inventory and retention periods”| Record | Content | Personal data | Retention | On expiry |
|---|---|---|---|---|
| Payment instructions and traceability ledger | Amounts, statuses, history, references from the regulated financial institution, beneficiary data | Yes | 10 years from the transaction (accounting and AML/CFT/CPF obligations) | Anonymization |
| Beneficiaries | Name, national ID, bank, account or phone | Yes | While the client uses them; afterwards, the period of the associated instructions | Anonymization |
| Client data | Company, contact email, webhook URL, API key hashes | Yes (contact) | Contract term + 10 years | Deletion |
| Audit log | Administrative actions with internal identifiers | No | Contract term + 10 years | Deletion |
| Portal access log | IP and user agent of each access | Yes | 12 months | Anonymization of IP and user agent |
| Application logs | request_id, path, response code, masked emails |
No | 12 months | Deletion |
| Backups | Copy of the database | Yes | 7 days (see D5) | Automatic deletion |
A legal obligation or an open dispute can extend a period. When that happens, the reason is recorded.
3. Deletion and anonymization
Section titled “3. Deletion and anonymization”- Anonymization: personal fields are replaced with non-reversible values. Amounts, statuses and dates needed for traceability are kept.
- Deletion: permanent removal of the records from the database.
- Backups: deleted data disappears from the copies when they expire, within at most 7 days.
- Physical media: AWS volumes are destroyed according to AWS secure erasure procedures.
- Execution: short-lived technical data, such as quotes and idempotency keys, is purged automatically. The retention periods in section 2 are applied by a scheduled process that records each run, in place before the first record reaches its period.
4. Data subject rights
Section titled “4. Data subject rights”Requests for access, rectification, erasure or objection from beneficiaries are channeled through the client that sent their data. The platform assists within at most 15 days, as long as the legal retention obligation allows it.
5. Transfers
Section titled “5. Transfers”Data is hosted on AWS (United States). It is only shared with the third parties in document D7, and each one receives only what is necessary for its function.