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PROFITILITY – ACCOUNT DELETION & DATA RETENTION POLICY

Effective Date: May 1, 2026
Application: Profitility
Company: Grindstone Holdings LLC
Governing Law: State of Tennessee, United States
Version: 1.1

This Account Deletion & Data Retention Policy (“Policy”) governs the handling, retention, and deletion of user data for the Profitility mobile application and related services (collectively, the “Service”).

By using the Service, you agree to this Policy.

1. Purpose

This Policy is designed to:
• Ensure proper management of user data
• Maintain compliance with legal and regulatory obligations
• Protect sensitive user information
• Define retention and deletion procedures
• Provide an in-app account deletion process compliant with platform requirements

2. Data Collected

Account Information

• Email address
• Encrypted authentication credentials
• Subscription status
• Account creation date

Financial & Operational Data

• Earnings, tips, and expenses
• Mileage and route data
• Order and transaction history
• Profit and loss entries
• Platform source identifiers for recordkeeping

Screenshot & OCR Data

• Screenshots remain stored on the user’s device
• OCR extracts text for analytics and recordkeeping
• Extracted data may be stored within the Service
• Original images are not stored on Company servers unless explicitly stated

Device & Usage Data

• Device type and operating system
• App version
• Log data and error reports
• Session and usage analytics

3. Data Retention

The Service retains user data only as necessary to operate the Service, comply with legal obligations, and maintain system integrity.

Active Accounts

All user data is retained while the account remains active.

Inactive Accounts

Accounts that remain inactive for twelve (12) consecutive months may be scheduled for deletion.

We will provide at least thirty (30) days’ prior notice before deletion.

Users may restore or maintain their account during this period.

We recommend maintaining independent copies of all financial records.

4. Account Deletion (Standard Process)

Users may request deletion of their account at any time through the App or by contacting support at support@profitility.app.

When a deletion request is submitted:
• The account is immediately deactivated
• Access to the account is suspended
• The account enters the deletion lifecycle process

5. Thirty (30) Day Deactivation Period (Soft Delete)

By default, accounts enter a thirty (30) day deactivation period before permanent deletion.

During this period:
• Users may restore access by logging in
• No permanent deletion occurs
• Data remains recoverable

If the account is not restored within thirty (30) days:
• The account and associated data shall be permanently deleted from active systems

6. Immediate Deletion Option

Users may request immediate permanent deletion in lieu of the thirty (30) day deactivation period.

If selected:
• The account shall be permanently deleted without a recovery period
• Data cannot be restored once deletion is completed

7. Permanent Deletion

Upon completion of the deletion lifecycle, the following is permanently deleted from active systems:
• Account profile information
• Financial and operational records
• User-generated content
• Authentication credentials
• Associated account identifiers

Once deleted, data cannot be recovered.

8. Data Retention After Deletion

Certain data may be retained where required for:
• Legal compliance
• Tax and financial recordkeeping obligations
• Fraud prevention and security
• Enforcement of agreements
• System backup integrity

Retained data is:
• Limited to what is strictly required
• Not used for marketing
• Not accessible to the user
• Protected under security controls

Where possible, retained data is anonymized or de-identified.

9. Subscription Management

Account deletion does not automatically cancel subscriptions.

Subscriptions must be managed through:
• Apple App Store
• Google Play Billing

Refunds are governed solely by platform provider policies.

10. Support-Based Deletion Requests

Users who cannot access the App may request deletion by contacting support at support@profitility.app.

Identity verification may be required.

Requests are typically processed within 48 hours.

11. Data Security

The Company implements reasonable safeguards including:
• Encryption in transit and at rest
• Access controls
• Authentication protections
• Monitoring systems

No system is fully secure. Users remain responsible for maintaining independent records.

12. Third-Party Services

The Service relies on third-party providers for infrastructure, analytics, OCR processing, and related services.

We are not responsible for third-party service failures, data loss, or disruptions.

13. Policy Updates

The Company may modify this Policy at any time. Continued use of the Service constitutes acceptance of the revised Policy.

Material changes may be communicated through:
• In-app notification
• Email (if available)
• Updated Effective Date

Where required, at least thirty (30) days’ prior notice will be provided.

14. Arbitration

Any dispute arising out of or relating to this Policy shall be resolved by binding arbitration in Hamilton County, Tennessee, except where prohibited by law. You waive the right to participate in class actions or class-wide proceedings.

15. Limitation of Liability

To the fullest extent permitted by law, Grindstone Holdings LLC shall not be liable for indirect, incidental, special, consequential, or punitive damages, including loss of data or financial loss.

Total liability shall not exceed fifty dollars ($50).

16. Governing Law

This Agreement is governed by the laws of the State of Tennessee, United States, with venue and jurisdiction in Hamilton County, Tennessee.

17. Contact Information

Grindstone Holdings LLC
PO Box 492
Collegedale, TN 37363
support@profitility.app