GDPR Right to Erasure (Data Deletion)
MonetizeNow supports the GDPR right to erasure (Article 17) through a formal, auditable process. As a processor, we act on deletion requests submitted by the customer (controller). This document explains what information we require, how we verify and process requests, timelines/SLAs, and what evidence we provide.
Submitting a Request
- Who can submit: Authorized customer admin, Legal/Privacy, or Security.
- Where to submit: Send email to: [email protected]
- What to include (minimum):
- Controller company name
- Authorized requester (name, title, work email, phone)
- Data subject identifiers: primary email used in MonetizeNow, all known aliases, user id (if available), account/tenant ID
- Scope: CPQ, Billing, Metering, Self-Serve, Support artifacts (as applicable)
- Acknowledgments: legal-retention, backups rotation, and suppression (see below)
Processing Workflow
- Authorize & Verify
We verify controller authorization and confirm subject identifiers (email(s), user/seat ID, tenant). - Locate & Scope
We enumerate the subject’s records across:- CPQ: users/contacts, quotes, drafts, order forms
- Billing: billing contacts, subscription records, invoices/credit memos (subject to legal retention), payment tokens we control
- Metering: usage records linked to the identity
- Ancillary: logs/analytics (where feasible), attachments, support artifacts
- Delete / Pseudonymize
- Hard delete where possible.
- Irreversible pseudonymization where references are required for data integrity or legal retention (e.g., keep invoice number and amounts; remove personal fields not legally required).
- Documents: delete drafts if permissible; executed commercial records are retained as required by law with PII minimized and access restricted.
- Sub-Processor Propagation
We notify/invoke deletion with approved sub-processors (e.g., e-signature, email delivery, observability) and track confirmations. - Backups & DR
We do not modify historical backups. Deletions are enforced by backup rotation (typ. 7–35 days, service-dependent). If a restore occurs, automated jobs re-apply the erasure. - Suppression
We add a non-reversible token/hash to a suppression register to prevent accidental re-creation of the identity via future imports/integrations. - Attestation & Closure
We deliver a completion report listing systems affected and sub-processor confirmations. All actions are logged (timestamp, actor, systems) and are reviewed under SOC 2 Type II.
Timelines & SLAs
- Standard completion: 7–10 business days
- Regulatory maximum: ≤ 30 days from verified request (GDPR Article 12)
- Complex, multi-system requests are communicated proactively with interim updates.
Updated 2 days ago