Data Deletion Policy

1. Overview

Fieseros, Inc. ("Fieseros," "we," "us," or "our") is committed to protecting your privacy and respecting your right to control your personal data. This Data Deletion Policy explains how you can request the deletion of your personal data held by Fieseros and outlines our obligations in processing such requests.

This policy applies to all individuals whose personal data is processed by Fieseros, including:

• Fieseros Account Holders — businesses and professionals who use the Fieseros CRM platform to manage their operations.
• End Customers of Fieseros Users — individuals whose data is entered into Fieseros by our account holders (e.g., customers, leads, contacts).
• Meta Platform Users — individuals who interact with Fieseros through Facebook integrations.

We comply with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Meta Platform Terms regarding data deletion. We will honor all valid data deletion requests in accordance with applicable law.

2. Your Rights

You have the right to request the deletion of your personal data under the following legal frameworks:

2.1 GDPR — Right to Erasure (Article 17)

Under the General Data Protection Regulation, you have the right to obtain the erasure of your personal data ("right to be forgotten") when:

• Your personal data is no longer necessary for the purpose for which it was collected.
• You withdraw your consent and there is no other legal basis for processing.
• You object to processing and there are no overriding legitimate grounds.
• Your personal data has been unlawfully processed.
• Erasure is required to comply with a legal obligation.

2.2 CCPA — Right to Delete

Under the California Consumer Privacy Act, California residents have the right to request the deletion of their personal information. We are required to delete your personal information upon receipt of a verifiable request, subject to certain exceptions outlined in this policy.

2.3 Meta Platform Terms

If you interact with Fieseros through Meta integrations (Facebook Login), you have the right to request deletion of the data we receive from Meta. We provide a data deletion callback URL and honor all deletion requests received through the Meta Platform in compliance with their developer policies.

3. How to Request Data Deletion

We provide multiple channels for submitting data deletion requests, depending on your relationship with Fieseros.

3.1 For Fieseros Account Holders

If you have an active Fieseros account, you can request data deletion through:

• In-App Settings: Navigate to Settings → Account → Delete Account. This will initiate a full account deletion, including all associated business data. You will be asked to confirm your identity and acknowledge that this action is irreversible.
• Email Request: Send an email to privacy@fieseros.com with the subject line "Account Deletion Request." Include your registered email address and a clear statement requesting deletion. We will verify your identity before processing.

3.2 For End Customers of Fieseros Users

If your data has been entered into Fieseros by one of our account holders (e.g., as a customer, lead, or contact), you can request deletion through:

• Dedicated Request Form: Visit our data deletion request form at fieseros.com/contact-us and select "Data Deletion Request." You will need to provide your name, email address, and the name of the business that may have entered your data.
• Email Request: Send an email to privacy@fieseros.com with the subject line "Customer Data Deletion Request." Include your full name and any identifying information that may help us locate your records.

Please note: If you are an end customer, we may need to coordinate with the Fieseros account holder who entered your data. We will make every reasonable effort to process your request directly and will notify the account holder as required by law.

3.3 For Meta Platform Users

If you interact with Fieseros through Facebook integrations, you can request deletion through:

• Data Deletion Callback: Use the data deletion functionality provided within the Facebook app settings. When you remove the Fieseros app from your Facebook account, a deletion request is automatically sent to our callback URL.
• Email Request: Send an email to privacy@fieseros.com with the subject line "Meta Data Deletion Request." Include your Facebook User ID so we can locate and delete your data.

4. What Data We Delete

Upon receiving a valid data deletion request, we will delete all personal data associated with your identity, including but not limited to the following categories:

4.1 Account Data

• Profile information (name, email, phone number, avatar)
• Login credentials and authentication data
• Account preferences and settings
• Role assignments and team memberships
• Subscription and plan details

4.2 Business Data

• Customer records and contact information
• Lead data and sales pipeline entries
• Booking and appointment records
• Job assignments, dispatch records, and completion proofs
• Invoices, quotes, and payment records
• Notes, tags, custom fields, and activity history
• Workflow and automation configurations

4.3 Communication Data

• Email logs and correspondence records
• Chat transcripts and support ticket communications
• Notification history and delivery records
• Voice call logs (if applicable)

4.4 Payment Data

• Billing address and invoicing records
• Payment method references (tokenized identifiers)
• Transaction history and receipts
• Subscription billing records

Note on Card Numbers: Fieseros does not store full credit/debit card numbers. Card data is processed and stored by our payment processors (Stripe and PayPal) in compliance with PCI-DSS standards. When you request data deletion, we will remove all tokenized references from our systems and request deletion of your payment data from our payment processors.

4.5 Usage Data

• Analytics and usage statistics
• Application logs and error reports
• Session data and device information
• IP address records and geolocation data
• Feature usage patterns and interaction data

5. What Data We Retain

In certain limited circumstances, we may retain some of your data even after a deletion request. These exceptions are permitted under GDPR, CCPA, and other applicable laws:

5.1 Legally Required Retention

We may retain data where required by law, including:

• Tax records and financial documents (retained for up to 7 years as required by tax regulations)
• Transaction records required for accounting compliance
• Records required for ongoing legal proceedings or disputes
• Data required to fulfill contractual obligations to other users

5.2 Anonymized or Aggregated Data

Data that has been anonymized or aggregated in such a way that it can no longer be used to identify you may be retained for analytical and statistical purposes. This data is not considered personal data under applicable law.

5.3 Data in Backups

Your data may exist in encrypted backup systems for a limited period. We will delete your data from all active systems promptly upon completion of a deletion request. Backup data is automatically purged within 30 days of the deletion request. Backups are encrypted and cannot be accessed or restored without authorized administrative procedures.

5.4 Data Shared with Third Parties

If your data has been shared with third parties (e.g., Meta, payment processors, sub-processors), we will notify those third parties of your deletion request and instruct them to delete your data in accordance with their own data retention policies. We cannot guarantee deletion by third parties but will make commercially reasonable efforts to ensure your data is removed from their systems.

6. Deletion Timeline

We are committed to processing data deletion requests promptly and within the timeframes required by law. The following timelines apply:

Under GDPR, we are required to confirm deletion "without undue delay" and in any event within one month of receipt of the request. Under CCPA, we must respond within 45 days (with one 45-day extension if necessary). We aim to complete all deletion requests well within these statutory timeframes.

7. Data Deletion for Meta Platform

Fieseros integrates with Meta platforms (Facebook Login) to provide authentication and business management features. This section describes how we handle data deletion requests originating from Meta in compliance with the Meta Platform Terms.

7.1 Facebook App Integration

• Facebook App ID: Our Fieseros Facebook App is registered with Meta and has a designated App ID.
• Data Deletion Callback URL: We provide a data deletion callback URL that Meta uses to send deletion requests when a user removes the Fieseros app from their Facebook account.
• Callback Processing: When we receive a deletion callback from Meta, we locate all data associated with the provided Facebook User ID and initiate deletion within 24 hours.

7.2 What Data We Receive from Meta

When you use Fieseros through Meta integrations, we may receive and store the following data:

• Facebook User ID
• Facebook profile name and email (if authorized)
• Contact lists synced from Facebook (if authorized)

7.3 How Meta Data Is Deleted

When a deletion request is received via the Meta callback:

1. We verify the authenticity of the signed request from Meta.
2. We locate all data associated with the Facebook User ID in our systems.
3. We permanently delete the data from our primary databases.
4. We generate a unique confirmation code for the deletion.
5. The data is removed from backups within 30 days through our automated backup rotation.

7.4 Confirmation Code Process

After processing a Meta-initiated data deletion request, we provide a confirmation code that serves as proof of deletion. This code is returned to Meta via the callback response and can also be provided to you upon request. If you need your confirmation code, please contact us at privacy@fieseros.com.

8. Third-Party Data

Fieseros integrates with several third-party services. When you request data deletion, we take the following actions with respect to data held by our partners:

8.1 Meta (Facebook)

We request deletion of your data from Meta via their API. This includes removing Facebook Login profile associations and requesting deletion of account metadata. Please note that Meta may retain certain data in accordance with their own data policies and legal obligations. We encourage you to review Meta's data policy at facebook.com/policy.php.

8.2 Stripe/PayPal

Payment data processed through Stripe and PayPal is subject to their respective data retention policies. Full credit/debit card numbers are never stored on Fieseros servers. When you request data deletion:

• We remove all tokenized payment references and billing records from our systems.
• We request deletion of your customer records from Stripe and PayPal.
• Certain financial records may be retained by our payment processors for up to 7 years as required by financial regulations (e.g., anti-money laundering laws, tax compliance).
• Stripe and PayPal handle data deletion in accordance with their own privacy policies and legal obligations.

8.3 AWS (Amazon Web Services)

Fieseros uses AWS for infrastructure and data storage. When your account is deleted, all data stored on AWS infrastructure is deleted along with your account. This includes database records, file uploads, and application logs. AWS infrastructure-level metadata (e.g., CloudWatch logs, S3 access logs) is automatically purged according to AWS retention policies, typically within 90 days.

9. Verification & Confirmation

To protect against unauthorized deletion requests, we verify the identity of the requester before processing any data deletion. The verification process may include:

• Confirming the request was sent from the email address associated with the account
• Requiring login to the Fieseros account for in-app deletion requests
• Verifying identity through a government-issued ID (in rare cases where identity cannot be confirmed through other means)
• Verifying the signed request from Meta for callback-based deletion

9.1 Deletion Confirmation Email

Once your data deletion has been completed, we will send a confirmation email to the address associated with your account (or the address you provided in your deletion request). This email will include:

• A summary of the data categories that were deleted
• The date of deletion
• A unique deletion confirmation code
• Information about any data that was retained (with the legal basis for retention)

9.2 Deletion Certificate

Upon request, we can provide a formal Deletion Certificate that serves as official documentation of the data deletion. This certificate includes your name, the date of deletion, the categories of data deleted, and our authorized signature. To request a Deletion Certificate, please contact privacy@fieseros.com after receiving your deletion confirmation.

10. Withdrawal of Consent

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

You can withdraw consent for the following processing activities:

• Marketing Communications: Unsubscribe from promotional emails using the link in any marketing email, or update your preferences in Account Settings.
• SMS Communications: Opt out of SMS messages by replying "STOP" to any message, or contact us to update your communication preferences.
• Analytics & Tracking: Disable analytics tracking in your Account Settings or through your browser's cookie preferences.
• Third-Party Data Sharing: Revoke permissions for third-party integrations (e.g., Facebook, Google) in your Account Settings.

To withdraw consent more broadly or for processing activities not listed above, please contact us at privacy@fieseros.com.

11. Data Portability

Before requesting data deletion, you have the right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format. This right is guaranteed under GDPR Article 20 and is also available to CCPA-covered individuals.

Fieseros provides the following data export options:

• JSON Export: A comprehensive export of all your data in JSON format, suitable for importing into other systems or for your personal records.
• CSV Export: Tabular data exports in CSV format for easy viewing in spreadsheet applications. Available for contacts, customers, invoices, bookings, and job records.

To export your data:

1. Log in to your Fieseros account.
2. Navigate to Settings → Data Management → Export Data.
3. Select the data categories you wish to export and your preferred format (JSON or CSV).
4. Click "Generate Export." You will receive a download link via email once the export is ready.

If you do not have access to your account or are an end customer, please contact privacy@fieseros.com to request a data export. We will verify your identity and provide your data in your preferred format within 30 days.

12. Children's Data

Fieseros is not intended for use by individuals under the age of 16. We do not knowingly collect or process personal data from children under 16 years of age.

If we discover that we have inadvertently collected personal data from a child under the age of 16, we will take immediate steps to delete that information from our servers. If you become aware that a child under 16 has provided personal data to Fieseros, please contact us immediately at privacy@fieseros.com so that we can take appropriate action.

13. Contact Us

If you have any questions, concerns, or requests regarding this Data Deletion Policy or our data practices, please contact us through the following channels:

We aim to respond to all data deletion requests and privacy inquiries within 30 days. For urgent matters or if you believe your data is at risk, please indicate "URGENT" in your email subject line and we will prioritize your request.