Data Retention and Deletion Policy

1. Scope and Purpose

This Data Retention and Deletion Policy (“Policy”) applies to all personal information and user-generated content collected and processed by RestAssured LLC (“RestAssured,” “we,” “us,” or “our”) through the RestAssured platform, including the website and web application at www.restassured.life, Remy (our AI assistant), EasyVault, Trust Network, and all associated features and APIs.

This Policy is incorporated into and should be read alongside our Privacy Policy and Data Processing & Security Statement. For Enterprise customers, the applicable Data Processing Addendum (DPA) may establish different or additional retention obligations that take precedence over this Policy.

This Policy governs:

• What data we retain — the categories of information stored by RestAssured.
• How long we retain it — the retention period for each data category.
• Why we retain it — the legal basis and business purpose for each period.
• How we delete it — the deletion methods we use and what “deletion” means.
• Your rights — how to get a copy of your data, how to delete it, and what exceptions may apply.

2. Guiding Principles

• Data Minimization. We collect only the data necessary to provide and improve the RestAssured platform. We do not retain data beyond what is needed for the purposes for which it was collected.
• Purpose Limitation. Data retained for one purpose (e.g., service delivery) is not repurposed for an incompatible purpose (e.g., advertising) without your separate consent.
• Storage Limitation. We set a retention period for every category of data. Most of what you give us is deleted the moment you delete your account; the few records we must keep longer are listed in Section 3 with the reason.
• Security of Retained Data. Data retained under this Policy is subject to the same technical and organizational security controls described in our Data Processing & Security Statement, including encryption at rest and TLS 1.2+ in transit.
• Transparency. We publish this Policy so you always know what data we hold and for how long. We will notify you of material changes in accordance with our Terms of Service.
• User Control. You can download a complete copy of your data at any time, and deleting your account always gives you that copy first.

3. Master Data Retention Schedule

The table below sets out how long RestAssured keeps each category of data, when it is deleted, why, and how.

4. Legal Bases for Retention

Every retention period in the schedule above is justified by one or more of the following legal bases. We do not retain data without a valid basis.

• Contract Performance. Data needed to deliver the RestAssured platform to you — your account profile, EasyVault documents, Life Readiness Assessment responses, reports, Trust Network contacts — is kept while your account is open and deleted when you delete it.
• Legal Obligation. Some data must be retained regardless of your preferences because law requires it. Financial records (transactions, invoices, refunds) must be kept for 7 years under IRS regulations and Minnesota tax law. Security incident records must be kept under applicable breach notification laws. We cannot honor deletion requests for data in this category.
• Legitimate Interest. We keep some data because we have a legitimate interest in: (a) detecting and preventing fraud and abuse (access-code attempt records, security records); (b) resolving disputes and defending legal claims (support records); and (c) improving the platform (aggregated, anonymized usage analytics). We weigh our legitimate interest against your privacy rights and retain only the minimum data necessary.
• Consent. Data collected on the basis of your consent (analytics cookies, marketing emails) is retained only while your consent remains valid. Withdrawing consent (unsubscribing, revoking cookie preferences) stops new collection immediately and triggers deletion within thirty (30) days for marketing data.

5. Account Closure and Post-Closure Data Handling

5.1 Voluntary Account Closure

You can delete your account yourself from Profile › Account & security › Delete your account, or by writing to support@restassured.life. When you do:

• A copy first. We download a complete copy of your data to your device before anything else happens. If we can’t make the copy, nothing is deleted. You can also download this copy at any time, without deleting anything, from Profile › Account & security › Export your data.
• Your subscription ends. If you have Protect, it ends immediately, with no refund for the rest of the year (see the Refund and Cancellation Policy in our Terms of Service).
• Everything else is deleted straight away. Your account, profile, answers, Life Profile, reports, Action Plan notes, Trust Network contacts, Remy records and vault document list are permanently deleted in one step, and you are signed out. There is no waiting period, and it cannot be undone.
• If your vault holds documents, your account can’t be deleted in one step. Our team closes it for you: we make sure you have downloaded what you need, then delete your documents from our document-storage provider and delete the rest of your account as above. Until then, your account stays as it is.
• What we keep afterwards: payment records, for 7 years, as the law requires, with the link to your account removed; records of access-code attempts, for one day; and anything already delivered, like emails in your contacts’ inboxes. Truly anonymized aggregate data (e.g., “X% of users completed the Life Readiness Assessment in 2026”) is retained indefinitely; it cannot identify you.

5.2 Involuntary Account Closure (Terminated for Cause)

If RestAssured terminates your account for violation of the Terms of Service or Acceptable Use Policy, the same process applies with one exception: records relevant to the violation (e.g., support communications, AUP breach evidence, security logs) may be retained for up to five (5) years to protect RestAssured’s legitimate interest in defending legal claims.

5.3 Enterprise Account Closure

Enterprise account closure is governed by the applicable Enterprise Subscription Agreement and any executed Data Processing Addendum. The DPA may specify shorter or longer retention windows than this Policy. Where the DPA conflicts with this Policy, the DPA controls. Enterprise customers may request certified deletion confirmation upon request to support@restassured.life.

6. Deletion Methods and Standards

When RestAssured deletes data, “deletion” means the data cannot be recovered by RestAssured or any third party through ordinary means.

• Permanent Database Deletion: When your account is deleted, your records are deleted from our database in the same step — they are removed, not hidden or marked as deleted.
• Files: Profile photos are removed from storage when your account is deleted. EasyVault documents are deleted from our document-storage provider when you remove them, or when our team closes an account that holds them.
• Retained Records: Payment records we must keep are kept with the link to your account removed, under restricted access, and deleted at the end of their retention period.
• Anonymization: Where technically feasible, personal information is stripped and replaced with non-identifying tokens before aggregate data is retained for analytics. Anonymized data is not “personal information” under CCPA and is not subject to deletion requests.
• Backups: If a backup holds data you have deleted, that data is gone when the backup expires. We never restore a backup to recover data you asked us to delete.

7. Legal Holds

Scheduled deletion may be suspended for specific data if RestAssured receives or anticipates a legal hold requirement. A legal hold preserves data beyond its normal retention period when:

• RestAssured receives a valid legal process (subpoena, court order, government request) requiring preservation of specific data.
• RestAssured reasonably anticipates litigation, regulatory investigation, or audit in which the data may be relevant.
• A user or Enterprise customer asserts a claim or initiates a dispute in which the data may be material.

Legal holds are managed by RestAssured’s legal team and are released as soon as the legal or regulatory requirement is resolved. Data subject to a legal hold is not accessible to general platform operations — it is stored in a restricted environment with access limited to authorized legal personnel.

8. Your Data Rights and Deletion Requests

Depending on where you live, you may have the right to request that RestAssured delete personal information we hold about you. This section explains what you can request, how to submit a request, and what exceptions apply.

8.1 Who Can Submit a Deletion Request

• Account holders: Any registered RestAssured user may delete their own account, or submit a deletion request for their account data.
• Authorized representatives: You may authorize another person to submit a deletion request on your behalf. We may require written proof of authorization.
• California residents: Under CCPA/CPRA, California residents have a statutory right to request deletion of personal information RestAssured has collected about them, subject to the exceptions in Section 8.3.
• Enterprise Authorized Users: Authorized Users of an Enterprise account should direct deletion requests to their organization’s account administrator. Enterprise administrators may submit requests on behalf of their organization to support@restassured.life.

8.2 How to Submit a Deletion Request

• Option 1 — In-app: Profile › Account & security › Delete your account. You get a complete copy of your data first. (To get a copy without deleting anything: Profile › Account & security › Export your data.)
• Option 2 — Email: support@restassured.life (subject: “Data Deletion Request”)
• Option 3 — Mail: RestAssured LLC, 985 Lake Street, #1024, Wayzata, MN 55391
• Response time: An in-app deletion takes effect immediately (Section 5.1). For requests by email or mail, we will acknowledge your request within 5 business days and complete it within 45 days (extendable by 45 days with notice).
• Verification: We will verify your identity before processing any deletion request we receive by email or mail. Typically this means confirming access to the registered email address.

8.3 Exceptions — When We Cannot Delete Your Data

We may decline to delete, or may be unable to delete, data in the following circumstances:

8.4 Additional Rights (California Residents)

Under CCPA/CPRA, California residents also have the right to:

• Know what personal information RestAssured has collected about you, the categories of sources, the business purpose, and the categories of third parties it is shared with.
• Correct inaccurate personal information we hold about you.
• Opt out of the “sale” or “sharing” of your personal information. RestAssured does not sell or share personal information for cross-context behavioral advertising.
• Non-discrimination for exercising any of these rights. We will not deny you service, charge different prices, or provide a different level of service because you exercised a privacy right.

To exercise any CCPA right, contact support@restassured.life. You can download a copy of your data yourself at any time from Profile › Account & security › Export your data. We will respond to requests within 45 days.

9. Data Associated with Deceased Users

RestAssured is a life readiness and estate organization platform, and we recognize that some of our users’ accounts will contain sensitive information that matters deeply after a user’s passing. We handle data associated with deceased users as follows:

• Account access: RestAssured does not automatically grant third parties access to a deceased user’s account. Access may be granted to a legal representative (executor, administrator of the estate) who provides: (a) a copy of the death certificate; and (b) documentation of their authority to act on behalf of the estate (letters testamentary, letters of administration, or equivalent).
• Retention: We keep a deceased user’s account as it is until their legal representative asks us to close it. It is then deleted as described in Section 5.1.
• EasyVault documents: Documents uploaded by a deceased user to EasyVault represent the user’s estate planning materials. We will provide an authorized legal representative with a complete export of the account, including EasyVault contents, before closing the account, at no charge.
• Deletion requests: A legal representative with appropriate authority may request deletion of a deceased user’s account data. The standard exceptions in Section 8.3 apply.
• Trust Network: Named contacts in the deceased user’s Trust Network are not separately notified by RestAssured. The estate’s legal representative is responsible for communicating with Trust Network contacts.

10. Third-Party and Sub-Processor Data Retention

RestAssured uses a limited number of third-party sub-processors to deliver the platform. Each sub-processor may retain data in accordance with its own policies. We contractually require all sub-processors to: (a) retain data only as long as necessary; (b) delete or return data upon termination of their agreement with us; and (c) provide at least the same level of data protection as described in this Policy.

A current list of sub-processors is available on request at support@restassured.life.

11. Retention Review and Internal Governance

RestAssured reviews this Policy and its associated retention schedules at least annually or when there is a material change to the platform, applicable law, or business operations. Reviews are conducted by the privacy, legal, engineering, and security functions.

• Annual review: Full policy and schedule review every June, coordinated with the Privacy Policy and Data Processing & Security Statement review cycle.
• Triggered review: Any new data collection, new sub-processor, or new regulatory requirement triggers an out-of-cycle review of the relevant retention categories.
• Deletion testing: Account deletion and the data export are covered by automated tests that run before every release. Manual review of legal hold lists occurs quarterly by the legal team.
• Employee training: All employees with access to user data receive annual training on data retention obligations and deletion procedures.
• Audit trail: Deletion events for legal and financial records are logged with timestamp, record category, and authorized approver. Deletion logs are retained for 3 years.

12. Changes to This Policy

We may update this Policy to reflect changes in our data practices, applicable law, or platform features. If we make a material change — such as extending a retention period, changing a deletion method, or adding a new data category — we will:

• Notify you by email to your registered address at least 30 days before the change takes effect.
• Post the updated Policy at www.restassured.life/legal with a new Effective Date.
• For material changes, require active re-acceptance before continued use of the platform.

This Policy was last revised on September 28, 2026.

13. Contact and Requests

For questions about this Policy, to submit a deletion request, or to request a record of what data RestAssured holds about you, please contact:

• Support, Privacy, Deletion and Security Requests: support@restassured.life
• Legal: legal@restassured.life
• Legal Hub: www.restassured.life/legal
• Mailing Address: RestAssured LLC, 985 Lake Street, #1024, Wayzata, MN 55391
• Response Time: 5 business days (acknowledgment); 45 days (completion)

© 2026 RestAssured LLC · 985 Lake Street, #1024, Wayzata, MN 55391 · www.restassured.life · support@restassured.life