Right to Erasure
In accordance with Article 17 of the General Data Protection Regulation (GDPR), users have the right to request the deletion of their personal data (“right to be forgotten”). GLOBALCELL.chat will honor and fulfill all data erasure requests where there is no overriding legal basis for retaining the data.
Submitting a Data Deletion Request
Users may submit a request to delete their personal data by contacting GLOBALCELL.chat at support@globalsoft.ge. In order to protect user privacy, we may request verification of identity from users before we proceed with data deletion.
Response Timeframe
GLOBALCELL.chat will respond to all verified data deletion requests no later than thirty (30) calendar days from the date the request is received, in compliance with the GDPR.
Scope of Deletion
- Erase personal data that directly or indirectly identifies the user from our systems;
- Ensure the data is also removed from backup systems within a reasonable timeframe;
Legal Grounds for Retention
- Some personal data may not be immediately deleted if it is retained:
- For compliance purposes based on legal obligations;
- For the establishment, exercise, or defense of legal claims;
- To complete a transaction or service the user initiated prior to the request;
- As required for legitimate business, detailed in clause 9 herein, interests that override the request, in accordance with GDPR limitations.
Methods of Deletion
Personal data stored electronically will be deleted using secure erasure techniques that prevent recovery. Where data cannot be fully erased (e.g., due to technical limitations), it will be permanently anonymized so that it can no longer be linked to an identifiable individual.
Exceptions
This policy does not apply to anonymized or aggregated data that cannot be linked to a specific individual. Deletion requests do not apply retroactively to data already anonymized or processed for statistical purposes in compliance with Article 89 of the GDPR.
Legitimate Business Interests That Could Override a Deletion Request
In accordance with Article 17(3) of the General Data Protection Regulation (GDPR), GLOBALCELL.chat may retain certain personal data despite receiving a request for erasure, where such retention is necessary to pursue legitimate business interests that are not overridden by the data subject’s rights and freedoms. Such interests may include, but are not limited to:
- Fraud Prevention and Detection: GLOBALCELL.chat may retain personal data to identify, investigate, and prevent fraudulent activity, abuse of services, or other malicious conduct (e.g. the retention of transaction records for pattern analysis and fraud detection purposes).
- Information Security: Data may be retained to ensure the ongoing integrity, availability, and confidentiality of GLOBALCELL.chat’s systems, including through the preservation of access logs and security incident data for investigation and risk mitigation purposes.
- Accounting and Audit Compliance: Personal data necessary for fulfilling accounting obligations or for supporting internal and external audit processes may be retained in accordance with applicable financial and regulatory requirements.
- Contractual Dispute Resolution: GLOBALCELL.chat may retain personal data required for the resolution of contractual disputes, claims enforcement, or customer service-related complaints.
- Legal or Regulatory Obligations: Where a deletion request would interfere with the fulfillment of a legal obligation or the handling of ongoing regulatory or law enforcement matters, GLOBALCELL.chat may defer or deny deletion accordingly.
- Service Improvement and Maintenance: Certain anonymized or pseudonymized data may be retained to analyze service usage trends, ensure system performance, and improve service delivery. In such cases, data shall be processed in a manner that does not permit identification of the data subject.
- Compliance Documentation: GLOBALCELL.chat may retain records of consent, deletion requests, and related communications for the purpose of demonstrating compliance with data protection obligations, including audit or regulatory inquiries.
All retained data under the grounds specified above shall be limited to what is strictly necessary, and GLOBALCELL.chat shall perform a balancing test to ensure that the retention does not disproportionately affect the rights and interests of the data subject.
Account Deletion Requests
- Requesting Account Deletion: Users may request the deletion of their GLOBALCELL.chat account at any time by clicking the Delete Account Button in the GLOBALCELL.chat app.
- Consequences of Account Deletion: Upon account deletion:
- The user's access credentials will be deactivated.
- All associated personal data will be deleted or anonymized unless retention is required under Clause 8 (Legitimate Business Interests) of this Policy or by applicable laws and regulations.
- Data stored on backups will be scheduled for deletion in the next regular backup purge cycle.
- The user will lose access to all stored data, usage history, and services linked to the account.
- Grace Period: In some cases, a grace period of 14 calendar days may be provided during which the user may reactivate the account. During this period, the data is flagged for deletion but not yet removed. After the grace period, deletion becomes irreversible.
- Data Retention Review and Schedule: GLOBALCELL.chat regularly reviews its data retention schedules to ensure that personal data is not held longer than necessary. The review process includes:
- Periodic audits of data storage systems;
- Flagging of dormant or inactive accounts;
- Automatic triggers for deletion or anonymization where appropriate.