User Data Deletion Policy

1 — PURPOSE

NxtStps is committed to protecting the privacy, dignity, and autonomy of every person who uses the platform — particularly victims of crime accessing sensitive support services at a difficult time in their lives.

This User Data Deletion Policy explains:

• what data NxtStps holds about you
• how you can request deletion of your account and data
• how deletion is executed and confirmed
• what data may be retained and why
• what happens to retained data after a deletion request

This Policy applies to all registered NxtStps users. It is published on the platform so that every user can understand their rights before, during, and after using the platform. It is part of a broader set of privacy commitments described in the NxtStps Privacy Policy, which governs how data is collected, used, and protected. This Policy and the Privacy Policy should be read together.

2 — SCOPE

This Policy covers all personal data collected and stored by NxtStps, including:

• Conversational intake responses and application form data
• Uploaded documents and attachments — police reports, medical records, financial records, and supporting evidence
• Account profile information — name, contact details, login credentials
• Application drafts, completed applications, and submission records
• Communication logs between the user and the platform
• AI interaction logs and completeness assessment records
• Consent and compliance records
• Technical session metadata

This Policy applies to all systems operated by NxtStps, including production databases, backup systems, AI processing environments, and third-party service providers acting as data subprocessors.

3 — WHO CAN REQUEST DELETION

3.1 Applicants

Applicants — victims or survivors who access the platform directly — may request deletion of their personal account and all associated data at any time. No justification is required. Deletion is a right, not a privilege.

Deletion requests may be submitted through:

• The in-platform account settings — "Delete My Account" — available from any screen
• Written request to NxtStps at legal@nxtstps.org from the email address registered to the account
• Assisted deletion facilitated by an authorized advocate who has documented written consent from the Applicant

3.2 Provider users

Provider users — advocates, case managers, and administrative staff — may request deletion of their own individual staff account and credentials at any time. A Provider user's account deletion does not delete the Applicant case data associated with their caseload. That data belongs to the Applicants they served and can only be deleted by those Applicants or by the Organization's designated administrator acting with documented Applicant consent.

An Organization's designated administrator may submit bulk deletion requests on behalf of the Organization in the event the Organization terminates its licensing agreement with NxtStps. Bulk organizational deletion requests are governed by the Organization's licensing agreement and are processed under the same timelines as individual requests.

3.3 Authorized Representatives

A parent, legal guardian, executor, or other authorized representative may submit a deletion request on behalf of an Applicant who is a minor, incapacitated, or deceased. Authorized representatives must provide documentation of their authority — such as guardianship papers, power of attorney, or letters testamentary — before NxtStps will process a deletion request on another person's behalf.

NxtStps recognizes that many Applicants on this platform are trauma survivors who may not have standard forms of identification. NxtStps will make reasonable accommodations for identity verification and will not automatically deny deletion requests because a user cannot provide standard documentation. If you are unable to complete standard verification, contact NxtStps at legal@nxtstps.org to discuss alternative verification methods.

4 — TYPES OF DELETION

4.1 Standard Account Deletion

Upon confirmation of identity and absence of any legal hold, NxtStps will permanently delete:

• User profile information including name, contact details, and demographic data
• All conversational intake responses and form data
• All uploaded documents and associated derived artifacts — OCR extractions, previews, and metadata
• Application drafts and incomplete submissions
• Completed application records, subject to the retention exceptions in Section 5
• Communication logs between the user and the platform
• AI interaction logs, subject to the minimum audit retention requirement in Section 5

NxtStps will also revoke all authentication credentials, invalidate all active sessions, and permanently disable access to the account.

Deletion is irreversible once completed. Accounts cannot be restored. Data cannot be recovered after deletion is finalized. If you return to the platform after deleting your account, you must create a new account.

4.2 Immediate Safety Deletion

If a user expresses fear, distress, or safety concerns — including concern that an abusive partner or other unauthorized person may attempt to access their account or data — NxtStps will process deletion immediately without requiring standard verification procedures or waiting periods, subject only to the minimum technical requirements of the deletion process.

Immediate Safety Deletion includes:

• No retention of data beyond the minimum technically required to complete the deletion process
• No follow-up contact from NxtStps after deletion unless explicitly requested by the user
• No attempt by NxtStps to persuade the user to retain their account or reconsider
• Immediate session invalidation and authentication revocation

The Exit Safely button available on every platform screen initiates session clearing and immediate navigation away from the platform. For complete account and data deletion, submit a deletion request through account settings or by email as described in Section 3.1.

4.3 Partial Deletion

Where a legal hold prevents full deletion of all data, NxtStps will execute maximum deletion — deleting everything that can legally be deleted — and anonymize or restrict access to the minimum data that must be retained. The legal hold decision process is described in Appendix A.

5 — DATA THAT MAY BE RETAINED AFTER A DELETION REQUEST

NxtStps retains only the minimum data required by law or operational necessity. The following table defines what may be retained, why, and for how long. All retention periods are consistent with the NxtStps Privacy Policy retention schedule.

Key principle: Retained data is held in restricted, access-logged storage and is never used for secondary purposes — no analytics, no AI training, no commercial use of any kind. NxtStps will notify the user in plain language of exactly what was retained and why at the time of deletion confirmation.

6 — ANONYMIZATION STANDARDS

Where deletion of specific data is not legally permissible, NxtStps will anonymize that data to the maximum extent permitted by applicable law. Anonymization means:

• Removal of all direct identifiers — name, address, phone number, email, government-issued identifiers
• Replacement of all unique identifiers with non-reversible cryptographic hashes
• Removal of all uploaded documents and narrative content
• Stripping of all metadata from remaining records — timestamps, file names, EXIF data
• Verification that remaining data cannot be re-linked to the individual through any reasonable means

Anonymized data is used solely for:

• Platform performance evaluation and system reliability monitoring
• Aggregate, non-individualized compliance reporting
• Statistical analysis to improve the accuracy of the rules engine and completeness validation

Anonymization is not a substitute for deletion. NxtStps treats anonymization as the last resort when deletion is legally prohibited and applies it as aggressively as the law permits.

7 — PROCESSING TIMELINE

The 30-day standard satisfies NxtStps's 45-day data rights response commitment stated in the Privacy Policy. NxtStps will notify the user within the initial 30-day period if additional time is required and will provide a plain-language explanation of the reason for any delay.

8 — THIRD-PARTY SUBPROCESSORS

NxtStps requires all subprocessors — cloud hosting providers, document processing services, AI service providers, security monitoring services, and communication providers — to:

• Adhere to deletion standards equivalent to or more stringent than those described in this Policy
• Receive and process deletion propagation requests within the 30-day timeline
• Provide written confirmation to NxtStps that deletion has been completed
• Be contractually prohibited from retaining deleted user data for any purpose after receiving a deletion request

If a subprocessor fails to confirm deletion within the required timeline, NxtStps will treat this as a security incident, escalate within 24 hours, and notify the user of the delay and the steps being taken to resolve it.

9 — ACCOUNT RECOVERY AFTER DELETION

Once deletion is completed and confirmed:

• The account cannot be restored under any circumstances
• Deleted data cannot be recovered by NxtStps, the user, or any third party
• The email address associated with the deleted account may be reused to create a new account if the user returns to the platform
• Prior application data, case history, and document uploads will not be available in a new account

If you need access to documents you previously uploaded — for example, to share them with another service provider — please download and save copies before requesting deletion. NxtStps cannot provide access to deleted data after deletion is confirmed.

10 — ORGANIZATIONAL ACCOUNT CLOSURE

When an Organization terminates its licensing agreement with NxtStps, the following process applies:

10.1 Staff Account Deletion

All Provider user accounts — advocate logins, administrator access, staff credentials — are deactivated immediately upon agreement termination and permanently deleted within 30 days.

10.2 Applicant Case Data

Applicant case data held within an Organization's account is not automatically deleted when the Organization terminates. Applicants retain their data rights regardless of the Organization's status. NxtStps will:

• (a) notify affected Applicants that the Organization has ended its relationship with NxtStps;
• (b) provide Applicants with a 90-day window to download their data or transfer it;
• (c) process deletion requests from Applicants received during that window under the standard timeline; and
• (d) retain or delete remaining data in accordance with the retention schedule in Section 5 after the 90-day window closes.

10.3 Organizational Data

Organizational-level data — billing records, licensing agreements, administrator contact information, and compliance records — is retained for 7 years after agreement termination for legal and audit purposes, then permanently destroyed.

11 — CHANGES TO THIS POLICY

NxtStps may update this Policy to reflect changes in applicable law, platform architecture, or data governance best practices. We will notify users of material changes by posting a notice through the platform and by email to registered addresses at least 15 days before changes take effect. This notification standard is consistent with the amendment mechanism described in the NxtStps Terms of Use and Privacy Policy.

12 — CONTACT INFORMATION

For deletion requests, questions about this Policy, or to check the status of a pending deletion request:

NxtStps, LLC
Attention: Privacy
Correspondence address available upon request via the privacy email below.
Chicago, Illinois
Email: legal@nxtstps.org
Website: nxtstps.com

NxtStps will acknowledge all deletion requests within 5 business days of receipt.