User Data Deletion Policy for AtlasIQ Mobile

Effective Date: September 19, 2025

Last Updated: September 19, 2025

 1. Introduction

This User Data Deletion Policy explains how Kalyna Vision handles requests for data deletion from users of the AtlasIQ Mobile application ("App"). This policy complies with the Virginia Consumer Data Protection Act (VCDPA) and Meta's data deletion requirements.

2. Your Right to Data Deletion

2.1 VCDPA Rights

Under the Virginia Consumer Data Protection Act, you have the right to request deletion of your personal data when:

- The personal data is no longer necessary for the original purpose

- You withdraw consent and there is no other legal basis for processing

- The personal data has been processed unlawfully

- The personal data must be deleted to comply with legal obligations

 2.2 Additional Rights

You may also request deletion when:

- You no longer wish to use AtlasIQ Mobile services

- You want to remove your account and associated data

- You have privacy concerns about data retention

3. Types of Data We Delete

3.1 Personal Data Deleted

When you request data deletion, we will delete:

- Account Information: User profile, authentication data, Apple ID information

- Location Data: Precise location history and location-based analysis

- Usage Data: App usage patterns, preferences, and interaction history

- Generated Reports: Personal intelligence reports and sentiment analysis

 3.2 Data Retained (Legal Requirements)

We may retain certain data when required by law:

- Financial Records: Payment and billing information (7 years)

- Legal Compliance: Data required for regulatory compliance

- Security Logs: Security-related data for fraud prevention

- Anonymized Data: Data that cannot identify you personally

4. How to Request Data Deletion

4.1 Request Methods

You can request data deletion through:

Primary Method:

- Email: privacy@kalyna-vision.com

- Subject Line: "Data Deletion Request - AtlasIQ Mobile"

4.2 Required Information

To process your request, please provide:

- Full Name: As registered in the App

- Email Address: Associated with your account

- Account Information: Username or account identifier

- Verification: Proof of identity (government ID, utility bill)

- Specific Request: Which data you want deleted

4.3 Verification Process

We will verify your identity before processing deletion requests to protect your privacy and prevent unauthorized deletions.

5. Deletion Process Timeline

5.1 Initial Response

- Acknowledgment: Within 5 business days of receiving your request

- Verification: Identity verification within 5 business days

- Confirmation: Confirmation of deletion scope within 7 business days

5.2 Deletion Timeline

- Primary Data: Deleted within 30 days of verification

- Backup Data: Deleted within 60 days of verification

- Third-Party Data: Coordinated deletion within 90 days

5.3 Completion Notification

We will notify you when deletion is complete via:

- Email Confirmation: Detailed deletion summary

- App Notification: If you still have the App installed

6. Technical Deletion Process

6.1 Data Removal Steps

1. Account Deactivation: Immediate account access suspension

2. Primary Database: Removal from active databases

3. Backup Systems: Deletion from backup storage

4. Cache Systems: Clearing of cached data

5. Third-Party Systems: Coordination with Meta and other partners

6.2 Meta Platform Coordination

For data shared with Meta platforms:

- Facebook Data: Request deletion through Meta's systems

- Instagram Data: Coordinate with Instagram data deletion

- API Data: Remove access tokens and associated data

6.3 Residual Data

Some data may persist in:

- System Logs: For security and debugging purposes

- Legal Archives: When required by law

- Anonymized Analytics: Cannot be traced back to you

7. Exceptions to Deletion

7.1 Legal Requirements

We may retain data when required by:

- Court Orders: Legal proceedings requiring data retention

- Regulatory Compliance: Government or industry regulations

- Fraud Prevention: Security and fraud detection systems

- Contractual Obligations: Business agreements requiring retention

7.2 Technical Limitations

Some data may be retained due to:

- System Architecture: Technical constraints on immediate deletion

- Backup Systems: Time required for backup deletion

- Third-Party Dependencies: External system limitations

8. Impact of Data Deletion

8.1 Service Impact

After data deletion:

- Account Access: You will no longer be able to access your account

- Intelligence Reports: Personal reports will be permanently deleted

- App Usage: You will need to create a new account to use the App

- Data Recovery: Deleted data cannot be recovered

8.2 Third-Party Impact

- Meta Platforms: Your Facebook/Instagram data sharing will cease

- Location Services: Location-based features will be disabled

- Social Media Analysis: Personal sentiment analysis will stop

9. Data Deletion Confirmation

9.1 Deletion Certificate

Upon completion, we will provide:

- Deletion Summary: What data was deleted

- Retention Notice: What data was retained and why

- Timeline: When deletion was completed

- Contact Information: For any follow-up questions

9.2 Verification Process

You can verify deletion by:

- Account Access: Confirming inability to log in

- Data Requests: Requesting data to confirm deletion

- Third-Party Verification: Checking Meta platform data

10. Appeals and Complaints

10.1 Appeal Process

If you disagree with our deletion decision:

- Internal Review: Request internal review within 30 days

- Management Escalation: Escalate to management if needed

- External Review: Contact Virginia Attorney General if necessary

10.2 Complaint Process

For complaints about data deletion:

- Internal Complaint: Submit complaint to privacy@kalyna-vision.com

- Regulatory Complaint: File complaint with Virginia Attorney General

- Legal Action: Pursue legal remedies as appropriate

 11. Contact Information

For data deletion requests or questions:

Kalyna Vision - Privacy Team 

Email: privacy@kalyna-vision.com 

Website: https://kalyna-vision.com/privacy

12. Policy Updates

This policy may be updated to reflect changes in:

- Legal Requirements: New privacy laws or regulations

- Technical Capabilities: Improved deletion processes

- Business Practices: Changes in data handling procedures

We will notify you of material changes through:

- App Notification: In-app notification

- Email: Email to registered users

- Website: Updated policy on kalyna-vision.com

13. Virginia-Specific Provisions

This policy complies with the Virginia Consumer Data Protection Act (VCDPA) and includes all required consumer rights and protections for Virginia residents.

This User Data Deletion Policy is effective as of September 19, 2025and was last updated on September 19, 2025.