User Data Deletion Protocol

DATA DELETION PROTOCOL FOR USERS
(Procedure for Account Deletion and Removal of Users’ Personal Data)

This Data Deletion Protocol describes the technical and organizational procedure applied by FitForm for deleting User accounts and removing personal data, in accordance with:

• the General Data Protection Regulation (GDPR);
• the legislation of the Republic of Moldova; and
• the developer policies of the Apple App Store and Google Play.

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

 

1. Purpose and Legal Basis

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

• at the User’s request;
• upon account termination;
• upon expiration of the data retention period.

1.2 This Protocol implements the right to erasure (“right to be forgotten”) provided by Article 17 of the 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 account deletion, FitForm deletes or irreversibly anonymizes the following categories of personal data:

• identity and account data (name, username, email address, profile details);
• contact data (email address, phone number);
• nutrition and physical activity data (meal plans, goals, progress tracking);
• user-generated content (notes, images, comments);
• usage data and technical data associated with the account;
• communications with the support team;
• device identifiers associated with the account;
• subscription metadata (where permitted by law).

2.2 This scope excludes only data subject to mandatory statutory retention obligations, including but not limited to:

• accounting and tax records;
• billing data;
• legally required transaction logs;
• anti-fraud and audit records.

Such data is retained strictly for the period required by law and is not used for any other purpose.

 

3. Account Deletion Request Procedure

3.1 Users may request account deletion by:

• using the account deletion function within the application (where available);
• or sending a written request to: privacy@fitform.life.

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

3.3 Deletion requests are internally logged 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;
• access to services and content is revoked.

4.2 The account and associated personal data are retained in a restricted and inactive state for a restoration period of 2 months.

4.3 During this period:

• the data is not processed for operational, commercial, or analytical purposes;
• the data is 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 the expiration of the 2-month period:

• the account and all associated personal data are permanently deleted or irreversibly anonymized.

 

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 removal from backups within defined backup cycles;
• anonymization of residual records;
• revocation of authentication credentials;
• dissociation of identifiers.

5.2 Where immediate deletion from backups is not technically feasible:

• the data is isolated and made inaccessible; 
• it is permanently deleted at the next scheduled backup rotation cycle.

 

6. Deletion of Data by Third Parties

6.1 Where personal data is 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 through 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. Legal Exceptions and Suspensions

7.1 FitForm may delay or partially restrict deletion where:

• data retention is required by law;
• data is necessary for the establishment, exercise, or defense of legal claims;
• data is subject to a legal hold, audit, or regulatory investigation.

7.2 In such cases, the affected data is:

• isolated;
• access-restricted;
• used exclusively for legal or compliance purposes.

 

8. User Confirmation

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

8.2 FitForm does not retain the authentication credentials of a deleted account after permanent deletion.

 

9. Security and Accountability

9.1 All deletion actions are logged for internal accountability.

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

• the GDPR;
• the data protection legislation of the Republic of Moldova;
• Apple App Store Review Guidelines;
• Google Play Developer Policies.

 

10. Changes to this Policy

• FitForm reserves the right to update this Policy at any time.
• Users will be notified of significant changes via the Website or by electronic means.
• Continued use of the Website after the changes take effect constitutes acceptance of the revised Policy.

 

11. Contact Details

For account deletion requests or data protection inquiries, please contact:
Email: privacy@fitform.life
Support: support@fitform.life