DRAFT — for counsel review. Not legal advice, and not yet in effect.
Data Deletion Request
Version 0.1 (draft) · Effective [Effective Date] · [Neivan Legal Entity, Inc.]
This page explains how to request deletion of personal data held by [Neivan Legal Entity, Inc.] ('Neivan', 'we', 'us') in connection with the Synapse platform (the 'Service'), including data obtained when you sign in with or connect a third-party account such as Facebook or Instagram. It complements our Privacy Policy.
NOTE TO COUNSEL: Confirm the request channel, verification method, and statutory response windows before publication. Bracketed items are organizational blanks.
1. Who controls your data
- If you use Synapse as part of your employer's workspace, your employer (the 'Customer') is the controller of that workspace data and Neivan is its processor. Send deletion requests to your employer first; we will act on the Customer's documented instructions under our Data Processing Agreement.
- Neivan is the controller for data about our own website visitors, prospects, and account-administration contacts, and for data we obtain directly from a third-party login you authorize (for example, your Facebook profile or the pages/accounts you connect). This page covers that controller data.
2. How to request deletion
Choose whichever is easiest:
- Email: send a request to [[email protected]] from the email address associated with your account, with the subject line "Data Deletion Request."
- In-app: if you have a Synapse account, open Settings → Privacy → Delete my data and follow the prompts.
To protect your account we may ask you to verify your identity (for example, by confirming control of the account email) before we act.
3. Deleting data connected via Facebook or Instagram
If you authorized Synapse to access a Facebook or Instagram account (for example, to connect a Facebook Page or an Instagram professional account), you can have that data removed in either of two ways:
- Remove the app from Facebook. Go to Facebook → Settings & privacy → Settings → Apps and Websites, select Synapse, and choose Remove. This revokes our access. Removing the app signals us to delete the data we obtained through that connection.
- Ask us directly using the request channels in Section 2, naming the Facebook/Instagram connection you want deleted.
Either way, we delete the tokens and the profile, page, and content data we obtained through that connection, except where we must retain limited records as described in Section 5.
4. What we delete and when
Once your identity is confirmed, we will delete or de-identify the personal data we hold as controller — including account and contact data, connection tokens, and data obtained through third-party logins you connected — within [30] days, and we will instruct our subprocessors to do the same.
5. What we may retain
We may retain limited data where the law requires it or to resolve disputes and enforce our agreements — for example, minimal billing and transaction records, security and audit logs, and records needed to comply with legal obligations. Retained data is kept only as long as necessary and then deleted or de-identified.
6. Contact
Questions about this process: [[email protected]] · [Neivan Legal Entity, Inc.] · [Registered Address].