Data Deletion Instructions

1. Who receives your request

We act in two distinct roles, and which one applies determines who decides on deletion:

• Controller — when the data is ours: B2B prospects we contact, people who fill in our forms, visitors to our sites, vendors and staff. Here the decision is ours and we execute directly.
• Processor — when we operate data on behalf of a client (their CRM, their store, their ad account, their support channel). Here the decision is not ours: we forward your request to the client who controls the data and tell you who they are. See section 11.

2. What "delete my data" means

When you request deletion, we look for your data and erase it across every system where we might hold it, not just the one that contacted you:

• Our central contact database (identification, contact details, company, job title, source of the record and its usage history).
• The Mautic email marketing instances we operate.
• Our Chatwoot conversation system (website chat, WhatsApp, Messenger and Instagram Direct).
• Working spreadsheets, exports and internal reports where your data appears.
• Audiences and lists uploaded to advertising platforms, where we were the ones who uploaded them.

What we cannot delete for you: your Instagram, Facebook, WhatsApp, Google or Apple account; the messages stored on your own phone; or the data those platforms keep on their own behalf. Those deletions are requested from each platform. Section 12 tells you exactly where.

3. How to request deletion — step by step

There is no charge, no special form, and no need to justify your decision. We will not ask you why.

1. Email datos@herihe.digital with the subject "Delete my personal data". This is the official channel and the one that creates a record.
2. Tell us how to find you. The email address or phone number we used to contact you is enough. If you remember where the contact happened (an email, a WhatsApp message, a form), mention it — it speeds up the search.
3. Tell us what you want. You can ask for full deletion, or only to stop receiving commercial communications (objection), which is faster and does not erase your contract history if you are a client.
4. You will receive an acknowledgement within 48 hours with a reference number in the format ARCO-YYYY-NNN. Keep it: with that number you can ask for the status of your request at any time by replying to the same email.
5. We confirm in writing once it is done, within the legal deadline that applies to your country (section 6), stating what was deleted and what — if anything — was retained under a legal obligation, and on what grounds.

If you would rather copy and paste, this message is enough:

4. Every available channel

5. What happens after your request

1. Day 0 — Receipt. We log the request with its reference number and send you the acknowledgement within 48 hours.
2. Days 1 to 5 — Search and verification. We verify your identity (section 7) and locate your data in the central database, in each Mautic instance, in the conversation system and in internal reports.
3. Days 5 to 10 — Execution. We delete the record; where referential integrity prevents that, we irreversibly anonymise it. We add your minimum identifier to the suppression list (section 9) so you are not re-imported. All commercial communication stops immediately.
4. Day 10 through the legal deadline — Response. We confirm the outcome in writing, stating what was deleted, what was kept, and on what legal ground.

6. Response times by jurisdiction

The deadline that applies to you is the one from your own jurisdiction. Where a person could be covered by more than one law, we apply the shortest deadline.

About the platforms: Meta requires developers to act "promptly" but sets no number of days. That is why the deadline we give you always comes from the law that protects you, not from the platform.

7. How we verify it is really you

We verify identity so that we never hand over or erase one person's data at another person's request. It protects you; it is not a delaying tactic.

Anything you send us to verify your identity is used only for that purpose and is deleted when the request is closed, except for the minimum record we are legally required to keep as evidence that we handled it.

8. What gets deleted and what we must keep

Deletion is the rule. Retention is the exception, and only applies where there is a legal obligation or a right to exercise or defend. When we keep something, we tell you exactly what and why.

9. The suppression list (why we keep a minimum)

This one tends to surprise people, so here it is without euphemism.

If we erase absolutely every trace of you, nothing stops you from entering our database again tomorrow from a public source — a business directory, a corporate website, a list handed to us by a client — and receiving another email from us. The only way to guarantee that does not happen is to keep a marker saying "this person must not be contacted".

So when we carry out your deletion, we keep on a suppression list:

• Your email address and/or phone number, as a cryptographic hash wherever technically possible.
• The date of your request and the reason (objection or deletion).

That list is never used to send you anything. It does the exact opposite: every new batch of contacts is checked against it and matches are discarded before import.

If you still want us to erase even that minimum, ask and we will. But you should know the consequence: we lose the ability to recognise you, and you could be contacted again if your details reappear in a public source. We will warn you of this in writing before executing it.

10. What happens with backups

Backups exist so systems can be recovered after an incident. They are encrypted and are not consulted in day-to-day operations.

• Your deletion is carried out immediately in production systems, which are the only ones that send communications or drive decisions.
• Backup copies are never restored in order to undo a deletion. They are overwritten on their own rotation cycle.
• While a copy still exists, your data inside it is frozen: it is not used for any purpose.
• If we ever had to restore a backup after an incident, we re-apply the suppression list before returning the system to service, so your deletion is automatically re-executed.

The maximum length of the backup rotation cycle still has to be fixed and published: see the corresponding item under Pending human decision.

11. If we handle your data on a client's behalf

A large part of our work consists of operating other companies' data infrastructure: their CRM, their online store, their ad account, their support channel. In those cases the client company is the controller and we act on their instructions.

If your request falls into that category:

1. We tell you within the same 48-hour acknowledgement window, rather than leaving you waiting.
2. We identify which company is the controller and give you their contact channel, so you can go to them directly if you prefer.
3. We forward your request to them anyway and assist them in executing it within the legal deadline. We do not use the handover as an excuse to do nothing.
4. If that company instructs us to carry out the deletion, we execute it in the systems we operate and confirm it to you.

When a client contract ends, their data is returned or deleted as agreed in the data processing agreement, and we do not reuse it for any purpose of our own.

12. Platforms: where the data comes from and how to erase it

This section exists because data does not always arrive through a form. Sometimes it arrives from a platform, and each platform has its own deletion route alongside ours.

12.1 Meta — Facebook, Instagram, Messenger and WhatsApp

What data we may receive from Meta platforms:

Limits we expressly accept for this data:

• We do not sell, license or purchase data obtained from Meta platforms.
• Message content never feeds commercial prospecting, marketing lists or database enrichment. It is used only to support the conversation you started with us.
• One client's advertising data is never combined with another's and is used for nothing other than assessing the performance of that advertiser's campaigns.
• We only process the platform data described here and in our privacy policy. If we ever needed another type of data, we would update these documents first.

How to request deletion of this data — two routes, either one works:

1. Write to us directly at datos@herihe.digital, telling us the Instagram handle, Facebook page or WhatsApp number we spoke through. This is the fastest route: it enters the flow described in section 5.
2. From your own Meta account, if you ever logged into an application of ours: Settings & Privacy → Settings → Apps and Websites → remove the app → View Removed Apps and Websites → select the app → Send Request. Meta delivers those requests to us in batches on a periodic basis, so if you want us to act right away, email us as well.

Remember that erasing your data from our systems does not delete your account or your messages on Facebook, Instagram or WhatsApp: that copy lives on the platform and on your phone, and is deleted from within the app itself.

12.2 Google — Ads, Analytics, Search Console, Tag Manager and Merchant Center

Here the data almost always belongs to a client company that granted us access to its own accounts through Google OAuth. We do not access anyone's personal Google account.

How to cut off access and request deletion:

1. Revoke the access yourself at myaccount.google.com/permissions. It is immediate and does not depend on us: from that moment we can no longer access anything.
2. Email datos@herihe.digital so we also delete the data already extracted (reports, metric tables, exports) and the stored credentials.

When access is revoked or the contract ends, authorisation tokens are deleted immediately. Data already extracted is deleted or anonymised at the end of the relationship, within the term set in the data processing agreement with each client (see pending item 6). We do not use Google user data for our own advertising, to train general-purpose artificial intelligence models, or for creditworthiness assessment, and we do not sell it.

12.3 Apple — App Store and Sign in with Apple

Current status: HERIHE DIGITAL LTDA. does not currently publish any app of its own on the App Store. This section applies when we build or operate an iOS app on a client's behalf, and states what we guarantee in that case.

• In-app account deletion. Every app that lets you create an account also offers, inside the app itself and in an easily accessible way, the option to delete that account and its associated data — not merely deactivate it.
• Sign in with Apple. If you signed in with Apple and chose to hide your email address, we only ever receive Apple's private relay address. You can sever the link in Settings → your name → Sign-In & Security → Sign in with Apple; that stops the relay, and to erase data already stored, email us at datos@herihe.digital as well.
• Policy link. Each app's privacy policy is linked from its App Store product page and from inside the app itself, and its App Privacy labels declare the data collected.

12.4 Other platforms

This table grows as we add channels. In every case, the general route remains datos@herihe.digital.

13. Your rights by jurisdiction

Deletion is one of several rights. They are all exercised through the same channel and all free of charge.

Chile — Law 21.719

Access, rectification, cancellation (erasure), objection, portability and blocking. Objection to direct marketing is absolute: you do not need to justify it and we cannot refuse it. Deadline: 15 business days. Complaints go to the Agencia de Protección de Datos Personales.

Brazil — LGPD

Confirmation that processing exists, access, correction, anonymisation, blocking or deletion of unnecessary or excessive data, portability, deletion of data processed on the basis of consent, information about who we share data with, information about the option not to consent, withdrawal of consent, and review of automated decisions. Deadline: immediate in simplified format, 15 days for the full response. Complaints go to the ANPD.

European Union / EEA and United Kingdom — GDPR

Access, rectification, erasure ("right to be forgotten"), restriction of processing, portability, objection — including the absolute right to object to direct marketing — and the right not to be subject to solely automated decisions producing legal effects. Deadline: 1 month, extendable by 2 further months. Complaints go to your national supervisory authority, and you also have the right to an effective judicial remedy.

California — CCPA / CPRA

The right to know what personal information we collect, use and share; the right to delete it; the right to correct it; the right to limit the use of sensitive personal information; and the right not to be discriminated against for exercising any of these rights — we will not charge you more or give you a worse service.

We do not sell or share your personal information as those terms are defined under the CCPA/CPRA, and we do not use it for cross-context behavioural advertising. Deadline: acknowledgement within 10 business days and a response within 45 calendar days, extendable by 45 more. You may appoint an authorised agent to exercise your rights; we will ask them for proof of that authorisation.

14. Vendors and international transfers

To deliver our services we work with vendors that process data on our instructions. When we carry out a deletion, we propagate it to those concerned.

Part of this infrastructure sits outside Chile, mainly in the United States. For those transfers we adopt the safeguards required by articles 27 and 28 of Law 21.719 and, where applicable, the GDPR standard contractual clauses. An up-to-date vendor list is available on request.

15. If we cannot delete your data

Some of your data may have to be retained. If that happens we will not go silent or answer with boilerplate. We send you, in writing:

• What was actually deleted and what was not.
• The specific reason for the retention and the rule that requires it (for example, the tax obligation to keep invoicing records).
• The date after which that portion will also be deleted.
• Confirmation that what is retained is not used for any other purpose, and in particular is never used to contact you.

If you disagree with our answer, you can complain to the authority for your country listed in section 6. You can also reply to the same email asking for a review, and we will carry one out.

16. Contact and related documents

• Data privacy channel: datos@herihe.digital
• Phone: +56 9 4043 5095
• Postal address: Cochrane 639, of. 54, Valparaíso, 2361806, Chile
• Website: https://herihe.digital/

The other two documents in this same package (also under review):

Until this package is published, the versions in force on the site are the current privacy policy and terms.

17. Pending human decision

This block is deliberately visible. It lists what cannot be settled in the drafting and requires a decision from HERIHE DIGITAL LTDA.'s management, its accountant or its attorney.

Drafted as version 1.0 on September 6, 2026 for review by MisAbogados (case 25762). It does not constitute legal advice. If you are the professional reviewing it, write to datos@herihe.digital.