Expert Data Deletion Protocol

EXPERT DATA DELETION PROTOCOL

(Expert Account Deletion & Personal Data Erasure Procedure)

This Data Deletion Protocol describes the technical and organizational procedure applied by FitForm for the deletion of Expert accounts and the erasure of personal data, in accordance with:

the General Data Protection Regulation (GDPR),
the legislation of the Republic of Moldova, and
the Apple App Store and Google Play Developer Policies.

This Protocol applies to all Experts (“Expert”, “you”) of the website www.fitform.life and the FitForm mobile application (collectively, the “Platform”).

1. Purpose and Legal Basis

1.1 This Protocol ensures transparent, secure, and lawful deletion of personal data in the following situations:

upon the User’s request.

1.2 It implements the right of erasure (“right to be forgotten”) under Article 17 GDPR and the corresponding data-protection legislation of the Republic of Moldova.

1.3 This Protocol also fulfills the data deletion and account removal requirements imposed by the Apple App Store and Google Play.

2. Scope of Data Subject to Deletion

2.1 Upon initiation of the Expert account deletion procedure, FitForm takes full control of the account in accordance with the approved agreement between the Platform and the Expert. After expiration of the 2-month retention period, all Expert products and data become the property of the Platform, and the Expert account shall be deleted.

2.2 All products associated with the Expert’s account shall remain available to Users who have purchased them.

2.3 Upon deletion of the Expert account, FitForm deletes or irreversibly anonymizes the following categories of personal data:

identity and account data (username, profile details);
user-generated content (notes, images, comments);
usage data and technical data linked to the account;
communications with the support team;
device identifiers associated with the account;
subscription metadata (where legally permissible).

2.4 This scope excludes only data subject to mandatory statutory retention requirements or those specified in the collaboration agreement, including, but not limited to:

contact data (name, email address, phone number);
nutrition and fitness data (meal plans, training programs, other products, goals, progress tracking, etc.);
accounting and tax records;
invoicing data;
transaction logs required by law;
anti-fraud and audit records.

3. Account Deletion Request Procedure

3.1 Users may request account deletion by:

using the in-app account deletion feature (where available); or
sending a written request to: privacy@fitform.life.

3.2 FitForm may verify the Expert’s identity before processing the deletion request to prevent unauthorized access.

3.3 Deletion requests are logged internally for audit and compliance purposes.

4. Deletion Timeline and Restoration Period

4.1 Upon confirmation of an account deletion request:

the account is immediately deactivated; and
access to services and content is revoked.

4.2 The account and associated personal data are retained in a restricted and non-active state for a 2-month restoration period.

4.3 During this period:

the data are not processed for any operational, commercial, or analytical purpose;
the data are accessible only to authorized personnel for restoration or legal-compliance purposes.

4.4 The User may request account restoration within the 2-month period by contacting: support@fitform.life.

4.5 After expiration of the 2-month period:

the account and all associated personal data are permanently deleted or irreversibly anonymized in accordance with Section 2.

5. Technical and Organizational Deletion Measures

5.1 FitForm applies appropriate technical and organizational measures to ensure secure deletion, including:

logical deletion from production databases;
secure erasure from backups within defined backup cycles;
anonymization of residual records;
revocation of authentication credentials;
disassociation of identifiers.

5.2 Where immediate deletion from backups is not technically feasible:

the data are isolated and rendered inaccessible; and
permanently deleted upon the next scheduled backup-rotation cycle.

6. Third-Party Data Deletion

6.1 Where personal data are processed by third-party service providers (e.g., hosting providers, analytics providers, Apple, Google):

FitForm submits deletion or anonymization requests to such providers, where technically and legally feasible.

6.2 For purchases made via the Apple App Store or Google Play:

transaction records are retained by the respective platform in accordance with their legal obligations and internal policies.

7. Exceptions and Legal Holds

7.1 FitForm may postpone or partially restrict deletion where:

retention is required by law;
data are needed to establish, exercise, or defend legal claims;
data are subject to a legal hold, audit, or regulatory investigation.

7.2 In such cases, the affected data are:

isolated;
access-restricted; and
used solely for compliance or legal purposes.

8. User Confirmation

8.1 Upon completion of permanent deletion, FitForm may send a confirmation email to the User.

8.2 FitForm does not retain deleted account credentials after permanent deletion.

9. Security and Accountability

9.1 All deletion actions are logged for internal accountability.

9.2 FitForm regularly reviews its deletion procedures to ensure ongoing compliance with:

GDPR;
the data-protection legislation of the Republic of Moldova;
Apple App Store Review Guidelines; and
Google Play Developer Policy.

10. Changes to This Policy

10.1 FitForm reserves the right to update this Policy at any time.

10.2 Users will be notified of material changes via the Website or by electronic means.

10.3 Continued use of the Website after changes take effect constitutes acceptance of the revised Policy.

11. Contact Details

For account deletion requests or data-protection inquiries, contact:

Email: privacy@fitform.life
Support: support@fitform.life