Data Deletion

MyHublet Data Deletion Process and Instructions (Site Records)
Updated 8/4/2024

1. Introduction

This page outlines the process for the deletion of website records to ensure compliance with data privacy regulations, such as GDPR, CCPA, and other relevant laws. The process ensures that data is securely and completely removed from all systems.

2. Scope
This process applies to all personal data collected, processed, and stored by the website, including but not limited to user accounts, transaction records, logs, and backups.

3. Roles and Responsibilities
MyHublet’s IT and DBA (teams) are responsible to ensure compliance with data privacy laws and oversees the data deletion process. MyHublet teams collectively ensures compliance with data privacy laws and oversees the data deletion process.

4. Data Inventory
MyHublet stores information from all data categories, including:
– User profiles
– Transaction history
– Communication logs
– Backup copies
– Third-party data processors

5. Deletion Request Handling (User Data Deletion Instruction)
The steps provide instructions for user / account holder’s user data deletion request:

1.**Request Submission**: Submit request to Support@MyHublet.com and provide following context:
– Subject line: ‘Delete User Data, [Requester’s FNAME]’.
– Email body: Include Account Holder’s full name and email address associated with user account

2. **Verification**: If require, MyHublet may request for additional information to verify the identity of the requester to ensure they have the right to request data deletion. Allow 3-10 business days to receive acknowledge.

3. **Assessment**: Evaluate the data subject’s request to determine the scope and impact on business operations.

4. **Acknowledgment**: Acknowledge the receipt of the request within a specified timeframe (e.g., 7 days). Allow up to 10 business days to receive acknowledge from MyHublet, MyHublet may request for additional verification if necessary

5. **Confirmation**: Allow up to 30 business days to receive Confirmation of Deletion from MyHublet

6. Data Deletion Process
The section below provides information about MyHublet’s process to data deletion.

6.1. Primary Systems

1. **User Accounts**:
– Deactivate the user account immediately upon request.
– Remove all personally identifiable information (PII) from the user profile.
– Anonymize remaining data if necessary for statistical purposes.

2. **Transaction Records**:
– Identify all transactions associated with the user.
– Delete or anonymize transaction records based on retention policies.

3. **Logs**:
– Search and delete log entries related to the user.
– Ensure that logs do not retain any PII after deletion.

6.2. Backups

1. **Immediate Deletion**:
– When applicable, locate and delete the user data from all active backups.
– Deletion and purge from backup is not available at this time.

2. **Scheduled Backups**:
– When applicable, ensure that deleted data is purged in the next backup cycle.
– Implement a process to exclude deleted data from future backups – pending.
– Deletion and purge from backup is not available at this time.

6.3. Third-Party Data Processors

1. **Notification**:
– Notify third-party data processors of the deletion request.
– Follow up on third-party’s compliance with the deletion within the agreed timeframe.

2. **Confirmation**:
– Obtain confirmation from third-party processors that data has been deleted.

7. Data Deletion Confirmation

1. **Internal Confirmation**:
– IT and DBA teams confirm the completion of the deletion process.
– Document the deletion process, including the data categories deleted and the date of deletion.

2. **User Notification**:
– Notify the requester of the completion of their data deletion request.
– Provide a summary of the actions taken and confirm compliance.

8. Record Keeping
Maintain records of all data deletion requests and actions taken for a specified period (as per MyHublet record keeping process and compliant period) to demonstrate compliance with data protection regulations.

9. Auditing and Monitoring
1. **Regular Audits**:
– Conduct regular audits to ensure the data deletion process is followed correctly.
– Address any discrepancies or process failures promptly.

2. **Continuous Monitoring**:
– Implement monitoring tools to detect and prevent unauthorized access to deleted data.
– Deletion and purge not applicable at this time.

10. Training and Awareness
Conduct onboarding and training sessions for all relevant staff on the data deletion process and the importance of data privacy compliance.

11. Policy Review
Review and update the data deletion process annually or whenever there are changes in data protection laws or business processes.

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This data deletion process ensures that personal data is handled securely and in compliance with relevant regulations, thereby protecting user privacy and maintaining trust in the website’s data handling practices.