CircleData Retention & Deletion Policy — Circle
Version: 3.0 · Effective: 2026-10-22 · Review cadence: at least annually. Contact: security@horizonlogistics.info
1. Purpose
Define how long Circle keeps each category of data and how data is deleted, so that information is retained only as long as a carrier needs it to run its business or the law requires, in line with U.S. data-privacy and record-keeping expectations for motor carriers.
2. Principles
- Data minimization — we process only what the service needs; we do not store Social Security numbers or full bank account or routing numbers.
- Purpose limitation — data is used only for the purpose it was collected for.
- Carrier control — a carrier can export its data at any time and decides, within legal limits, how long its records are kept.
- Retain only as needed — data past its retention period is deleted or anonymized.
3. Retention schedule
| Data category | Retention | Basis |
|---|---|---|
| Financial records (pay statements, settlements, invoices, load revenue, fuel and toll transactions, reconciliations) | 7 years, or as the carrier instructs within that limit | Tax and accounting record-keeping |
| Bank balances and transactions (where a bank account is connected) | Kept with financial records; disconnecting the account revokes ongoing access, historical transactions remain per this schedule unless deletion is requested | Accounting and audit |
| Contractor payment and year-end records | 7 years | Tax reporting |
| Driver and staff personal data (name, address, phone, license number, qualification dates, emergency contact) | Duration of engagement plus up to 3 years after the carrier marks the person inactive; records with tax or DOT relevance follow those schedules | Business, DOT and tax |
| Safety and compliance records (incidents, inspections, hours-of-service, qualification files) | As required for motor carriers (typically 6 months to 3 years by record type), or longer at the carrier's instruction | Regulatory |
| Location and hours-of-service data from connected vehicle devices | Detailed positions for the current and prior 12 months; weekly mileage and duty summaries with financial records | Operations and pay |
| Connected-account content (documents and messages processed to update the workspace) | Extracted records live with the data they update; source copies are kept only as long as needed to reprocess or audit them, at most 24 months | Operations |
| Sign-in tokens and integration credentials | Until the integration is disconnected or the member is removed, then revoked and deleted | Least privilege |
| Messaging activity with Circle (messages, taps, group membership) | 24 months | Operations and dispute resolution |
| Website and demo contacts | 24 months from last contact, or on request | Follow-up |
| Application, security and audit logs | 12–24 months | Security monitoring |
| Backups | Rolling 30 days | Recovery |
4. Deletion procedures
- Member removal: a carrier administrator removes the member; access ends immediately, sign-in tokens are revoked, and personal data not required by the schedule above is purged after the retention window.
- Disconnecting an account (vehicle device, fuel account, bank account, business account or document source): access is revoked and the credential deleted at once; data already recorded in the workspace remains under the schedule above.
- Cancellation: the carrier can export its complete workspace before or after cancelling. The workspace is deleted 30 days after termination, except records we are legally required to keep or that the carrier asks us to keep, which are retained for the minimum required period and then deleted.
- Secure deletion: records and files are deleted or anonymized; backups age out on schedule, so deleted data leaves them within 30 days.
- Deletion requests: a person whose data we hold, or a carrier administrator, may request deletion through the security contact; we honor it unless a legal or tax retention obligation applies, in which case we keep the minimum required and delete the rest.
5. Legal holds
If data is subject to litigation, audit or regulatory hold, retention is extended for the affected records until the hold is released, overriding the schedule above.
6. Review
Reviewed at least annually and whenever new data categories or providers are added. Complements the Information Security Policy and the Privacy Policy.