Account Deletion Policy
1. Overview
Acena Education - FZCO (doing business as "Componi") is committed to respecting user privacy and data rights. This policy outlines how users can request account deletion, what data is deleted, what is retained and why, and the timeline for deletion.
This policy complies with:
- California Consumer Privacy Act (CCPA/CPRA) right to delete
- Apple App Store requirement to provide account deletion functionality
- General data protection principles of minimization and retention
2. Right to Delete
2.1 Your Right
You have the right to request deletion of your Componi account and associated personal information. Deletion is free and can be requested at any time.
2.2 Your Request Is Binding
Once you submit a deletion request:
- The deletion process cannot be canceled or reversed
- Your account will be permanently inaccessible
- Your game progress, virtual currency, and account data will be lost
- This is a permanent, irreversible action
3. How to Request Account Deletion
3.1 In-App Deletion Request
Steps:
- Open the Componi app
- Tap Settings (gear icon)
- Scroll to Account
- Select Delete Account
- Read the warning and confirmation prompt
- Enter your account password or confirm via biometric authentication
- Tap Confirm Deletion
- A confirmation will be sent to your registered email
3.2 Email-Based Deletion Request
If you cannot access the app or prefer email, contact:
Email: admin@acena.cc
Subject: "Account Deletion Request"
Include:
- Your full name
- Email address associated with your Componi account
- Confirmation statement: "I request permanent deletion of my Componi account"
We will verify your identity and process your request within 30 days.
3.3 Age-Based Account Deletions (COPPA)
If your account is associated with a child under 13 and you are the parent/guardian:
- You may request deletion on the child's behalf
- Provide proof of parental authority
- We will delete the account within 30 days
4. What Data Is Deleted
4.1 Personal Data Deleted Immediately (Within 30 Days)
The following personal information will be deleted from active systems:
| Data Category | What Gets Deleted | Timeline |
|---|---|---|
| Account Profile | Name, email, password hash, account creation date | Within 30 days |
| Authentication | Apple ID / Google account linking (if applicable) | Within 30 days |
| Device Info | Device identifiers, IDFA, Advertising ID mappings | Within 30 days |
| Push Tokens | Device push notification tokens | Within 30 days |
| Preferences | Settings, language, notification preferences | Within 30 days |
| Gameplay Progress | All puzzle completion history, game state, progress | Within 30 days |
| Virtual Currency | All Crystal balance (forfeited) | Within 30 days |
| League Data | League membership, ranking, season history | Within 30 days |
| Lounge Data | Lounge match history, win/loss records | Within 30 days |
| Session Data | Active login sessions and refresh tokens | Immediately |
4.2 Data Retained and Why
The following data will be retained beyond the 30-day deletion period for the reasons listed:
| Data Category | What Is Retained | Retention Period | Why It's Retained |
|---|---|---|---|
| Transaction Ledger | Crystal pack and Lifetime Ad-Free purchase records | 7 years | Tax compliance, financial auditing, chargeback defense |
| Payment Information | Payment method used, transaction IDs | 7 years | Tax compliance, chargeback defense, regulatory reporting |
| Account Suspension Log | Records if account was flagged for fraud/cheating | 2 years | Fraud prevention, pattern detection for multi-accounting |
| Immutable Crystal Ledger | Append-only record of all Crystal transactions | Permanent | Audit trail, dispute resolution, fraud prevention |
| Backup Data | Encrypted database backups | 90 days | Disaster recovery, data integrity verification |
| Legal Holds | Data subject to legal investigation or dispute | Until legal case resolved | Legal compliance, preservation of evidence |
| Law Enforcement Request | Data provided to government/law enforcement | As requested by legal authority | Compliance with court orders or warrants |
4.3 Why Certain Data Is Retained
Tax Compliance: Tax authorities require us to retain transaction records (Crystal purchases and the Lifetime Ad-Free Purchase) for the periods specified by applicable law, typically 7 years. These records are needed for tax filings, financial audits, and chargeback defense.
Fraud Prevention: Account suspension records and the immutable Crystal ledger are retained to detect multi-accounting schemes, collusion, and fraud patterns. Analyzing historical data helps us identify suspicious accounts and protect the integrity of our rewards system.
Financial Audits: Payment records are retained for internal and external audits, chargebacks, and reconciliation with payment processors (Apple, Google).
Disaster Recovery: Database backups are retained for 90 days in case of data loss or system failure, but are deleted after this period.
Legal Holds: If your account is involved in a legal dispute, investigation, or court order, data may be preserved longer per legal requirements.
5. Effect of Deletion
5.1 What Happens to Your Account
| Aspect | Effect |
|---|---|
| Access | App access is revoked; login is impossible |
| Data | Personal data deleted; transactional data retained (see 4.2) |
| Progress | All game progress lost permanently |
| Virtual Currency | All Crystals forfeited; no refund possible |
| League Participation | Removed from current league; no season rewards |
| Lounge Status | All match history deleted; withdrawals from ongoing matches |
| Lifetime Ad-Free Purchase | Tied to your store account (Apple ID / Google account), not your Componi account; not affected by Componi account deletion. The entitlement can be restored on a new account via Restore Purchase. |
5.2 Lifetime Ad-Free Purchase Is Not Affected
Componi does not offer recurring subscriptions. The optional Lifetime Ad-Free in-app purchase is a one-time transaction processed through Apple App Store or Google Play. It is tied to your store account (Apple ID or Google account), not your Componi account.
Deleting your Componi account does not charge or refund the Lifetime Ad-Free Purchase. Because there is no subscription, there is nothing to cancel.
If you create a new Componi account in the future and sign in with the same Apple ID or Google account, you can restore your Lifetime Ad-Free entitlement via Settings > Restore Purchase.
5.3 No Compensation
Deletion of your account results in:
- Loss of all virtual currency (no refund)
- Loss of all game progress
- Loss of any pending rewards or prizes
- The Company provides no compensation for these losses
6. Deletion Timeline
| Stage | Timeline | What Happens |
|---|---|---|
| Request Submission | Immediate | Your request is logged in our system |
| Identity Verification | Immediate to 24 hours | We verify your identity if requesting by email |
| Deletion Processing | Within 30 days | Personal data is deleted from active systems |
| Backup Deletion | Up to 90 days | Data is removed from encrypted backups |
| Retention Data | Permanent (if applicable) | Tax, fraud, and legal records are retained per law |
6.1 Accelerated Deletion
We aim to delete personal data within 7-14 business days of receiving a verified request. The 30-day timeline is the maximum; most deletions occur faster.
6.2 Confirmation
Once deletion is complete:
- You will receive a confirmation email stating "Your Componi account has been permanently deleted"
- This email is your proof of deletion for CCPA/privacy purposes
- Keep this email for your records
7. Cannot Reverse Deletion
Once an account is deleted, it cannot be recovered. There is no grace period or recovery option. If you delete your account by mistake:
- You must create a new account
- All previous progress is permanently lost
- You cannot transfer virtual currency or progress to the new account
8. Exceptions to Deletion
We cannot delete data in the following circumstances:
8.1 Active Legal Hold
If your account is subject to:
- A court order or subpoena
- An active legal investigation
- A law enforcement request
- A dispute or lawsuit
Data will be retained until the legal matter is resolved.
8.2 Active Payment Disputes
If there is:
- A pending chargeback with your payment provider
- A fraudulent payment claim
- An unresolved billing issue
Data will be retained until the dispute is resolved (typically 180 days).
8.3 Fraud Investigation
If your account is flagged for:
- Multi-accounting or collusion
- Cheating or exploitation
- Unauthorized access or compromise
- Payment fraud or chargeback abuse
We may retain data longer to complete our investigation and prevent future fraud.
9. Data Processor Deletions
9.1 Supabase Deletion
We use Supabase (Postgres + AWS S3) as our cloud infrastructure provider. When we delete your data:
- Personal data is deleted from Supabase databases immediately (within 30 days)
- Backups in AWS are deleted after 90 days per our backup retention policy
- We do not have direct control over AWS backup schedules, so deletion may take up to 90 days
9.2 Third-Party Service Deletions
Third parties may retain data separately:
- Apple: Apple may retain records of your Apple Sign-In access; contact Apple directly for Apple ID data deletion
- Google: Google may retain records of your Google Sign-In access; contact Google for Google account data deletion
- Google AdMob: Advertising IDs and engagement data may be retained separately; see Google's privacy policy
- Payment Processors: Apple and Google may retain payment records for 7 years; contact them directly
We will send deletion requests to these services, but we cannot guarantee they will comply or delete data on the same timeline.
10. Your Rights and Responsibilities
10.1 Your Right to Verification
You have the right to request verification that your data has been deleted:
- Email admin@acena.cc with subject: "Account Deletion Verification"
- We will confirm that your account has been deleted from our active systems
- We cannot confirm deletion of retained data (taxes, fraud records) per privacy laws
10.2 Account Deletion Is Permanent
By deleting your account, you acknowledge that:
- Deletion is irreversible
- All progress and currency will be lost
- No compensation is provided
- You understand and accept these consequences
11. Contact and Support
For questions about account deletion:
Email: admin@acena.cc
Subject: "Account Deletion Question" or "Deletion Status"
Include: Your registered email and account email
We will respond within 7-14 business days with clarification on your specific situation.