Privacy Policy

1. Scope of This Policy

This policy covers the financial account data handled by ChiroUnchained's Digital Office Manager module, specifically the bank account connection feature powered by Plaid. It applies to any practice (“tenant”) using this feature, and to the individual staff member or practice owner who connects a bank account through it.

This policy does NOT cover patient clinical or health records. Patient protected health information (PHI) is handled by a separate part of the ChiroUnchained platform, under a separate Business Associate Agreement with AWS for HIPAA-covered processing, and is not accessed by or connected to the Plaid integration described here.

2. Who This Applies To

The person who connects a bank account through this feature (“you”, “the user”) is a member of practice staff — typically the practice owner, office manager, or a designated bookkeeping role — connecting the practice's own business bank account for internal cash reconciliation and financial tracking. This is not a patient-facing feature and does not collect any patient financial information.

3. What Data Is Collected

Through Plaid, ChiroUnchained receives and stores the following, and only the following:

• Transaction records: amount, date, raw description, and associated account identifier
• Account balance data
• Recurring transaction patterns (used to identify regular deposits and bills)
• A Plaid access token, which represents the connection itself

ChiroUnchained does not request, and Plaid's response does not include, full bank account or routing numbers beyond what is required to maintain the connection. No transfer, payment-initiation, or account-modification data or capability is requested.

4. How Data Is Used

Data received through this connection is used exclusively for:

• Matching bank deposits against the practice's cash reconciliation records (front desk, till, and office manager counts)
• Identifying and labeling recurring payers from transaction descriptions
• Internal cash flow forecasting for bill and payroll planning (where enabled)

Data is never used to make automated financial decisions. Every recommendation or flagged discrepancy generated from this data requires a human staff member to review and respond — nothing is auto-approved, auto-transferred, or auto-resolved.

5. How Data Is Protected

• Encrypted at rest: all data received from the Plaid API (tokens, transactions, balances, account identifiers) is encrypted at the column level before storage, using AES-256-GCM. The encryption key is never stored in the database.
• Encrypted in transit: all connections use TLS 1.2 or higher.
• Access control: access to this data requires an authenticated session under the platform's centralized, role-based access control system, and multi-factor authentication (emailed one-time passcode) is required for every login.
• Audit trail: every read of this data is logged, tied to the authenticated staff member who accessed it.
• No write access: the integration is read-only. No feature of this platform can move, transfer, or withdraw funds.

6. Data Retention

Raw transaction records are retained for 13 months, after which they are automatically deleted. Monthly and yearly summary totals are retained indefinitely for historical reporting, but these summaries do not contain individual transaction details — they are aggregate numbers only, calculated before the underlying raw records are deleted.

7. Data Sharing

Financial account data collected through this integration is not sold, rented, or shared with any third party for marketing or any purpose unrelated to the practice's own internal financial tracking. Data is not shared between practices (tenants) using this platform — each practice's financial data is isolated to that practice.

8. Your Consent and Control

Connecting a bank account through this feature requires explicit authorization through Plaid's own consent flow at the time of connection. You may disconnect a linked account at any time; upon disconnection, no further data is retrieved for that account, and previously stored data remains subject to the retention schedule in Section 6.

To request access to, correction of, or deletion of data collected under this policy, contact the practice's designated information security contact (see the practice's Information Security Policy for current contact details).

9. Changes to This Policy

This policy will be updated as the platform's data handling practices change. The effective date at the top of this document reflects the version currently in force.

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