1. Your Right to Data Deletion
At Verriflo, we respect your right to control your personal information. This Data Deletion Policy outlines the process through which you can request the deletion of your personal data from our systems in accordance with applicable data protection regulations, including:
- GDPR (General Data Protection Regulation) - European Union
- UK GDPR - United Kingdom
- CCPA (California Consumer Privacy Act) - United States
- PIPEDA (Personal Information Protection and Electronic Documents Act) - Canada
- LGPD (Lei Geral de Proteção de Dados) - Brazil
- Other applicable international and local privacy laws
This policy is designed to comply with the "right to erasure" (also known as "right to be forgotten") provisions under these regulations, ensuring that individuals can request and obtain deletion of their personal data under applicable circumstances.
Jurisdictional Notice: If you do not reside in a jurisdiction covered by the regulations listed above (European Union, United Kingdom, California/United States, Canada, or Brazil), your personal data and data deletion rights will be protected and governed under the laws and regulations of the People's Republic of Bangladesh, where Verriflo is operated. We are committed to honoring data deletion requests from all users regardless of their jurisdiction, in accordance with applicable legal requirements.
2. Scope of Data Deletion
When you request data deletion, we will remove the following types of personal information from our active systems:
- Account information (name, email address, phone number)
- Profile data and preferences
- Usage data and activity logs
- Communication records
- Any other personally identifiable information linked to your account
3. How to Request Data Deletion
To request deletion of your personal data, please follow these steps:
Step 1: Submit Your Request
Send an email to our legal team at:
Step 2: Include Required Information
Your deletion request must include the following information to help us identify your data:
- Full name associated with the account
- Email address registered with Verriflo
- Phone number (if provided during registration)
- Any additional details that can help us identify your account
- Subject line: "Data Deletion Request"
Step 3: Identity Verification
To protect your privacy and prevent unauthorized deletion requests, we may require additional verification to confirm that you are authorized to request deletion of the data. This may include:
- Responding from the email address associated with your account
- Providing answers to security questions
- Submitting government-issued identification (if necessary via secure method)
- Completing any other verification steps we deem necessary
Security Notice: If government-issued identification is required for verification, we will provide you with a secure, one-time upload link. Please do not email sensitive identification documents (such as passports or national IDs) directly, as standard email is not a secure transmission method.
4. Processing Timeline
Once we receive and verify your data deletion request:
- Acknowledgment: We will acknowledge receipt of your request within 48 hours
- Verification: Identity verification may take up to 5 business days
- Review: We will review your request to determine if there are any legal obligations preventing deletion
- Deletion: If approved, your data will be permanently deleted within thirty (30) calendar days from the date of verification
- Confirmation: You will receive an email confirmation once the deletion is complete
Total Processing Time: The entire process will be completed within thirty (30) calendar days from the date we receive your request, in compliance with GDPR and other international data protection regulations. In most cases, we aim to complete deletion within 7-10 business days, but we allow up to 30 days to ensure thorough verification and handle complex cases or high request volumes.
5. Exceptions and Legal Obligations
We may be unable to delete your data immediately or at all if:
- Legal Requirements: We are required by law to retain certain information for tax, accounting, or regulatory purposes
- Ongoing Investigations: Your data is subject to an ongoing legal investigation or dispute
- Court Orders: A court order or legal authority has mandated data retention
- Fraud Prevention: Retention is necessary to detect and prevent fraudulent activities
- Security Purposes: Data is needed to maintain system security or investigate security incidents
- Contractual Obligations: Active subscriptions or outstanding financial obligations exist
If we cannot delete your data due to any of these exceptions, we will notify you via email with a detailed explanation of the reason and the expected retention period.
6. What Happens After Deletion
Once your data deletion request is processed:
- Your account will be permanently deactivated and cannot be recovered
- All personal information will be removed from our active databases
- You will no longer receive communications from Verriflo
- Access to any Verriflo services associated with your account will be terminated
- Any content created by you may be anonymized for statistical, analytical, or operational purposes
Important: Data deletion is permanent and irreversible. Once deleted, we cannot recover your account or any associated data. Please ensure you have downloaded any important information before submitting a deletion request.
Anonymized Data
Please note that once data is anonymized (meaning it can no longer be linked to you as an individual), it is no longer considered "personal data" under GDPR, CCPA, and other data protection regulations. Anonymized aggregate statistics (such as total number of classes attended, average session duration, etc.) may be retained for business analytics, research, and service improvement purposes. This anonymized data cannot be used to identify you and is not subject to deletion requests.
7. Backup and Archival Systems
While we will delete your data from active systems within the specified timeframe, please note:
- Data may persist in backup systems for up to 90 days as part of our disaster recovery procedures
- Backup data is not accessible or used for any operational purposes
- All backup copies containing your data will be permanently deleted during the next backup cycle
- Anonymized or aggregated data that cannot be linked back to you may be retained for analytics
8. Third-Party Services
Verriflo uses certain third-party service providers for various operational functions. While we will request deletion of your data from these providers, please note:
- Third-party deletion timelines may vary based on their respective policies
- Some providers may retain data for their own legal or operational requirements
- We will provide reasonable assistance in ensuring third parties comply with deletion requests
- You may need to contact certain third-party services directly for complete deletion
9. Organization Owner Data Deletion
If you are the owner of an organization registered with Verriflo, your data deletion request will have additional implications:
Organization Owner Deletion Process
When an organization owner requests data deletion, the following will occur:
- Organization Data Deletion: All data associated with your organization, including recordings, user accounts, settings, and configurations, will also be permanently deleted
- Nomination Option: To prevent organization deletion, you must nominate another person as the new organization owner in your deletion request email
- Transfer Requirements: The nominated person must be an existing member of the organization with appropriate permissions
- Consent Verification: We will contact the nominated individual to confirm their acceptance of ownership before proceeding with your data deletion
- Transfer Timeline: Ownership transfer must be completed before your personal data deletion can proceed
Important: If you do not nominate a new owner, your organization and all associated data will be permanently deleted along with your personal account.
Transfer Rejection Fallback
If the nominated individual rejects or does not confirm ownership transfer within 7 business days, you will be notified and given the following options:
- Nominate a different person as the new owner
- Withdraw your data deletion request to retain your organization
- Proceed with deletion of both your personal account and the entire organization
If no response is received within 14 calendar days after the initial nomination rejection, we will assume you wish to proceed with full deletion of your account and organization.
10. Indirect Users and Platform-Mediated Deletion
If you are not directly registered with Verriflo but your data exists in our system (for example, as a student who participated in a class through an organization's platform):
Platform-Mediated Deletion Requirements
- Request Source: Data deletion requests for indirect users must come from the platform/organization that provided your data to Verriflo
- Direct Requests Not Accepted: We cannot process deletion requests directly from indirect users, as we have a data processing agreement with the platform/organization that controls your data
- Contact Your Platform: Please contact the educational institution, organization, or platform through which you accessed Verriflo services
- Platform Responsibility: Your platform is responsible for managing your data rights and submitting authorized deletion requests on your behalf
Billing Period Requirements
For indirect users whose data is necessary for billing purposes:
- Billing Cycle Completion: Your data will only be deleted after the current/last billing period has ended
- Payment Settlement: All outstanding bills must be paid by the organization before deletion can proceed
- Billing Documentation: If your participation data (class attendance, usage metrics, etc.) is required to generate or validate invoices, deletion will be delayed until billing is finalized
- Timeline: Deletion typically occurs within one (1) business week after the billing period ends and payment is confirmed
- Legal Retention: Some billing-related data may need to be retained for tax and accounting purposes as required by law, even after deletion of other personal information
Example: If you joined a class on December 10th and the organization's billing period ends on December 31st, your data deletion request (submitted by your platform) will be processed in early January after the December invoice is paid.
This approach ensures compliance with financial regulations and prevents disputes over billing while still honoring your right to data deletion under applicable data protection laws.
11. Data Retention for Organizational Members
If you are a member (but not the owner) of an organization using Verriflo:
- Your organization's administrator may have control over your data
- You may need to contact your organization's administrator for deletion requests
- Certain organizational data may be retained even after individual account deletion
- We will work with your organization to fulfill deletion requests where appropriate
- Personal data will be deleted while organizational audit trails may be anonymized
12. Appeals and Complaints
If your data deletion request is denied or you are not satisfied with our response:
- You may appeal the decision by replying to our response email
- We will review your appeal within 5 business days
- You have the right to lodge a complaint with your local data protection authority
- You may seek legal advice or pursue other remedies available under applicable law
13. International Data Transfers and Compliance
For users in the European Economic Area (EEA), United Kingdom, and other jurisdictions with specific data protection requirements:
- Your data may be processed in Bangladesh or other jurisdictions where our service providers operate
- We implement appropriate safeguards to protect your data in accordance with applicable laws
- Data deletion requests will be honored in compliance with your local data protection regulations
- You maintain all rights granted under your local jurisdiction's data protection laws
- We comply with GDPR requirements for data subjects in the EU/EEA, including the one-month response deadline for deletion requests (extendable by two months in complex cases)
14. Updates to This Policy
We may update this Data Deletion Policy from time to time to reflect changes in our practices or legal requirements. We will notify users of any material changes by posting the updated policy on our website and updating the "Last updated" date. Continued use of Verriflo services after such changes constitutes acceptance of the updated policy.
15. Contact Information
For all data deletion requests or questions about this policy, please contact:
Email: legal@verriflo.com
Please allow up to 48 hours for initial response during business days (Saturday-Thursday, excluding public holidays in Bangladesh).
Related Policies
For more information about how we handle your data, please review: