Account and Data Deletion Policy — draft

Prepared for review by licensed counsel. Not legal advice. Part B is the proposed public text; Parts A and C are internal.

Part A — Drafting brief (internal)

Item	Value
Question presented	How can a user delete an account or data, what is deleted, what is kept and why, and how long does it take?
Platform drivers	Apple Guideline 5.1.1(v) (in-app account deletion); Google Play User Data policy (in-app path and a web link that works without reinstalling the app; data-deletion requests without deleting the account) [VERIFY: EV-233]
Legal drivers	GDPR Art. 17; CCPA right to delete (if applicable); retention for tax and fraud prevention (RSK-027)
Engineering inputs	Deletion runbook across backend, Stripe, email provider, analytics, advertising and support tools (RSK-026); web deletion page; guest-data deletion [ENGINEERING]
Retention source	POL-RET-000 (proposed, not implemented)

Part B — Proposed public text

Account and Data Deletion

Version: 1.0 [OPEN] · Effective: [OPEN: date]

This notice explains how to delete your account in the HidzoVPN app and your personal information. It is issued by HidzoVPN, Inc., a Florida corporation, and supplements our Privacy Policy. [OPEN: the app and developer name shown here must match the Google Play listing — Google Play Help 13327111]

1. Your subscription

If you bought Premium on our website, deleting your account also cancels its renewal, and you will not be charged again [ENGINEERING: automatic cancellation of the Stripe subscription when the account is deleted]. Deletion does not by itself give a refund for the current period; see our Refund and Cancellation Policy.
If you pay through Apple or Google, deleting your account does not cancel your subscription. Cancel it first in your Apple or Google account, as explained in our Refund and Cancellation Policy; otherwise Apple or Google will continue to charge you. [ENGINEERING: the in-app deletion flow shows this warning and a link to the store's subscription page]

2. How to delete your account

Where	How
In the app	[ENGINEERING: Settings → Account → Delete account]
On the web (you do not need the app)	[ENGINEERING: https://hidzovpn.com/delete-account] — sign in with a one-time code sent to your account email and confirm
By email	Email [OPEN: [email protected]] from your account email with the subject "Delete Account"

We may ask you to confirm the request from your account email, or while signed in to the app, before we delete anything. We will email you when the deletion is complete. [ENGINEERING: revoke Sign in with Apple tokens and disconnect Google sign-in on deletion]

3. Deleting data without deleting your account

You can ask us to delete particular information, such as support conversations or diagnostic reports, without closing your account. Email [OPEN: [email protected]] and tell us what you want deleted. [ENGINEERING: confirm which categories can be deleted separately]

4. If you use HidzoVPN without an account

Information linked to your installation is removed from our active systems [ENGINEERING: when — e.g. after X days of inactivity or when you delete the app and the installation identifier expires]. You can also ask us to delete it by emailing [OPEN: [email protected]] with the installation identifier shown in [ENGINEERING: Settings → About]. We may ask you to confirm the request from the app on that device [ENGINEERING].

5. What we delete and what we keep

Information	What happens
Account information (email, account identifier, linked devices, settings)	Deleted from our active systems within 30 days after we receive your request, or after you confirm it if we ask you to [ENGINEERING]
Connection information	Deleted on the schedule in Section 11 of our Privacy Policy; any that still exists when you delete your account is deleted within [ENGINEERING]
Support messages	Deleted when you delete your account, unless needed for an open refund, dispute or legal matter
Analytics and advertising measurement linked to your account or device	Deleted or de-identified in our systems; we send deletion requests to our service providers [ENGINEERING: list]
Purchase, refund, tax and accounting records	Kept for the period tax and accounting law requires [VERIFY and tax counsel: U.S. and Florida periods; EU VAT records for digital services may require up to 10 years]
Records needed to prevent fraud or abuse, including device and payment identifiers blocked under our Acceptable Use Policy	Kept for up to 24 months, or longer only for a documented incident or legal claim [ENGINEERING and COUNSEL]
Information covered by a legal hold, a preservation request or an open dispute	Kept until the hold or dispute ends, then deleted
A record of your deletion request	Kept up to 5 years to show that we handled it [COUNSEL]
Backups	Deleted information is removed when backups expire, within [ENGINEERING: 90 days]

Information held by Apple and Google [COUNSEL: and our payment processor, for its own purposes — POL-SUB-001 A.1] [OPEN — BRF-2026-001 D4: and advertising providers in the Free Service], acting as independent businesses, is not deleted by us. You can contact them directly.

6. After deletion

Deletion cannot be undone. You will lose your linked devices and settings. If you still have an Apple or Google subscription, it continues until you cancel it with them [ENGINEERING: whether it can be restored to a new account]. You can create a new account later, unless we closed your account under our Acceptable Use Policy.

7. Questions

Email [OPEN: [email protected]]. See our Privacy Policy for your other rights.

Part C — Drafting notes (internal)

C.1 Basis

Element	Basis	Label
In-app deletion; tell users billing continues through Apple; revoke Sign in with Apple tokens; confirm completion	Apple Guideline 5.1.1(v); Apple "Offering account deletion in your app"	Reported (EV-236)
Preservation after a CSAM report	18 U.S.C. §2258A(h) (1 year)	Reported (EV-236); applicability [COUNSEL]
Web deletion link naming the app/developer as on the listing; steps before deletion (e.g. cancelling a subscription) clearly outlined; retention disclosed	Google Play Help 13327111	Reported (EV-236). Deleting data without deleting the account is not stated as mandatory by Google; required where GDPR Art. 17 / CCPA §1798.105 apply [VERIFY: EV-233]
Erasure and exceptions	GDPR Art. 17(3)(b), (e) (legal obligation; legal claims); CCPA §1798.105 exceptions (if applicable)	[VERIFY: EV-233]
Retention periods	POL-RET-000 (proposed; not implemented)	Internal — [ENGINEERING]

C.2 Operational prerequisites

Deletion runbook covering: backend database; Stripe customer object [COUNSEL: retain transaction records; delete profile data where possible]; email/OTP provider; analytics and attribution tools (deletion APIs); advertising partners; support/helpdesk; backups. Web deletion page live and linked in Google Play Console [ENGINEERING].

C.3 Limits of this analysis

No law verified first-hand for this document; all items pending EV-233. Facts unknown: every retention period and deletion mechanism (C.2). Counsel required: privacy.

C.4 Review log

Date	Reviewer	Verdict	Notes
2026-09-25	Drafted	—	v0.1
2026-09-25	hidzo-counsel-reviewer (AI)	BLOCK (DEL-01) + 10 Majors	v0.2: web subscriptions cancelled on deletion (Blocker fixed; conforming edits in ToS §§12.3, 14, REF §1, PP §12); restore wording; legal holds; connection-data wording; fraud and tax retention; third-party deletion; Apple token revocation and completion email; Google listing name; guest confirmation; timing from receipt
2026-09-25	hidzo-counsel-reviewer (AI) — cross-document final audit; research memos EV-232–235	REVISE (set: 1 Blocker, 8 Majors)	v0.3: cross-document redlines X-01–X-31 applied where they concern this document; authority labels updated from first-hand and research-memo checks (EV-238–264)