Data Retention & Deletion Policy

Last Updated: September 7, 2026

This Data Retention & Deletion Policy (“Policy”) explains how Cry-Fi (“Cry-Fi”, “Platform”, “we”, “our”, or “us”) retains, manages, archives, and deletes user and Listener information.

This Policy should be read together with the Cry-Fi Privacy Policy and other applicable Platform policies.


1. Purpose

Cry-Fi retains information only for as long as reasonably necessary for legitimate purposes, including:

  • Operating the Platform

  • Managing user accounts

  • Processing bookings and payments

  • Managing Listener payouts

  • Providing and administering sessions

  • Providing video-session functionality

  • Resolving disputes

  • Investigating misconduct

  • Preventing fraud and abuse

  • Maintaining Platform security

  • Enforcing Platform policies

  • Complying with legal and regulatory obligations

Cry-Fi does not intentionally retain personal data indefinitely without a legitimate purpose.

Retention periods may vary depending on the type of information, the purpose for which it is used, applicable legal requirements, and technical considerations.


2. Types of Data Retained

Depending on how the Platform is used, Cry-Fi may retain or process the following categories of information.

a. Account Data

Including:

  • Name

  • Email address

  • Phone number where provided

  • Profile information

  • Account settings

  • Account history

  • Registration information


b. Listener Verification Data

Including:

  • Identity verification information

  • Identity documents where collected

  • Verification records

  • Vetting records

  • Interview or onboarding records

  • Listener approval or rejection records

  • Relevant compliance records

Certain verification information may require extended retention for fraud prevention, safety, legal, or regulatory purposes.


c. Booking & Session Data

Including:

  • Booking history

  • Session date and time

  • Session duration

  • Session type

  • Booking status

  • Cancellation information

  • Refund information

  • Payment-related information

  • Payout information

  • Dispute information


d. Video Session & Meeting Data

Where Cry-Fi provides video-session functionality, the Platform or its relevant service providers may process technical or booking-related information required to provide and secure the meeting.

Depending on the technical implementation, this may include:

  • Meeting identifiers

  • Meeting access information

  • Participant identifiers

  • Session start and end information

  • Join or access information

  • Technical connection information

  • Device or browser information

  • Security information

  • Session status

  • Meeting expiration information

Cry-Fi does not represent that live video or audio sessions are recorded, permanently stored, or continuously monitored unless expressly stated in an applicable Cry-Fi policy or otherwise presented to users.

The availability and retention of technical video-session information may also depend on the third-party technology provider used to provide the session.


e. Communications, Reports & Evidence

Cry-Fi may retain:

  • Support tickets

  • Safety reports

  • Complaint records

  • Platform messages where applicable

  • Submitted screenshots

  • Evidence files

  • Dispute submissions

  • Investigation records

  • Moderation records

  • Relevant internal investigation records


f. Technical & Security Data

Cry-Fi may retain technical information such as:

  • IP addresses

  • Device information

  • Browser information

  • Operating-system information

  • Log files

  • Cookie-related information

  • Authentication information

  • Security logs

  • Fraud-prevention information

  • Access and activity information


3. Standard Retention Principles

Cry-Fi may retain different categories of information for different periods.

Generally:

  • Active account data may be retained while an account remains active or for as long as reasonably necessary for legitimate Platform purposes.

  • Booking and financial records may be retained for periods reasonably necessary for accounting, tax, payment, dispute, fraud-prevention, or legal purposes.

  • Safety and complaint records may be retained for as long as reasonably necessary to review reports, enforce policies, protect users, and comply with legal obligations.

  • Fraud and security records may be retained for as long as reasonably necessary to prevent repeated abuse, investigate incidents, or protect the Platform.

  • Technical and session-related information may be retained according to its purpose, technical requirements, security needs, and applicable third-party service retention periods.

Retention periods may vary depending on the nature and sensitivity of the information and the circumstances in which it was collected.


4. Extended Retention for Serious Cases

Cry-Fi may retain relevant information for longer periods where reasonably necessary in connection with:

  • Serious safety incidents

  • Sexual misconduct allegations

  • Physical harm allegations

  • Fraud investigations

  • Chargeback or payment disputes

  • Repeated policy violations

  • Serious abuse reports

  • Legal claims

  • Court proceedings

  • Government or law-enforcement requests

  • Regulatory obligations

  • Protection of users, Listeners, or Platform integrity

Extended retention does not mean that all account information will necessarily be retained indefinitely.

Where reasonably possible, Cry-Fi may limit extended retention to information relevant to the applicable matter.


5. Account Deletion Requests

Users and Listeners may request deletion of eligible personal information associated with their account.

Cry-Fi may review deletion requests and may be unable to immediately delete certain information where retention is reasonably necessary for:

  • Legal obligations

  • Financial or tax requirements

  • Active disputes

  • Fraud prevention

  • Security investigations

  • Safety investigations

  • Policy enforcement

  • Legal claims

  • Lawful requests from authorities

Where deletion is appropriate and technically feasible, Cry-Fi will take reasonable steps to process eligible deletion requests.

Deletion of an account does not necessarily mean that every record associated with that account will be immediately deleted.


6. Information That May Not Be Immediately Deleted

Certain information may need to be retained after account closure, including:

  • Financial records

  • Transaction records

  • Payout records

  • Fraud-prevention records

  • Serious misconduct records

  • Safety investigation records

  • Legal compliance records

  • Records required for disputes

  • Evidence associated with serious policy violations

  • Information required to prevent repeated abuse

Where possible, retained information may be limited to what is reasonably necessary for the applicable purpose.


7. Inactive Accounts

Cry-Fi may archive, restrict, or remove inactive accounts after an extended period of inactivity, subject to applicable law and Platform requirements.

Account inactivity does not automatically mean that all associated information will be immediately deleted.

Certain records may continue to be retained where reasonably necessary for legal, financial, safety, security, or fraud-prevention purposes.


8. Data Deletion Limitations

Deletion requests may not result in immediate or complete deletion where:

  • Backup systems contain copies that have not yet reached their normal deletion cycle

  • Legal obligations require continued retention

  • A dispute or investigation is ongoing

  • Security or fraud prevention requires preservation

  • Records are required for legal claims

  • Third-party service providers have separate retention schedules

  • Technical limitations temporarily prevent immediate deletion

Cry-Fi will take reasonable steps to delete or anonymize eligible information when retention is no longer reasonably necessary, subject to applicable legal, technical, and operational limitations.

Information retained in backups may be isolated from ordinary use and deleted or overwritten according to applicable backup and recovery processes.


9. Third-Party Data Handling

Cry-Fi may use third-party providers for services including:

  • Payments

  • Hosting

  • Analytics

  • Security

  • Email and communications

  • Video sessions

  • Authentication

  • Fraud prevention

  • Other Platform infrastructure

Information processed or retained by third-party providers may be subject to their own privacy, security, and retention policies.

Cry-Fi does not control the independent retention practices of third-party providers, although Cry-Fi may take reasonable steps to select and work with service providers consistent with its operational and legal requirements.


10. Video-Service Provider Retention

Video sessions may rely on third-party technology.

Where applicable, the relevant provider may independently process certain technical information required to operate, secure, troubleshoot, or administer the video service.

The retention of such information may depend on:

  • The provider’s systems

  • Service configuration

  • Security requirements

  • Technical logs

  • Applicable law

  • The provider’s own retention policies

Cry-Fi does not claim ownership or control over information independently retained by a third-party video-service provider.


11. Security of Retained Data

Cry-Fi uses reasonable administrative, technical, and organizational safeguards to protect retained information.

However:

  • No storage system is completely secure.

  • No internet-based service can guarantee absolute security.

  • Security risks may arise from unauthorized access, technical failures, third-party systems, or other circumstances beyond Cry-Fi’s reasonable control.

Cry-Fi will respond to applicable security incidents in accordance with its Security & Breach Response Policy and applicable law.


12. Legal Requests & Disclosure

Cry-Fi may preserve, access, or disclose relevant information where reasonably necessary or legally required for:

  • Court orders

  • Government requests

  • Law-enforcement inquiries

  • Regulatory requirements

  • Legal claims

  • Fraud investigations

  • Safety investigations

  • Protection of users or Platform security

Cry-Fi may comply with lawful requests in accordance with applicable law.

Where legally permitted, Cry-Fi may take reasonable steps to protect the confidentiality of information when responding to such requests.


13. Retention & Deletion of Session Access Information

Video meeting access information may remain associated with a booking for the period reasonably necessary to:

  • Provide access to the scheduled session

  • Verify booking status

  • Maintain Platform security

  • Investigate disputes

  • Prevent unauthorized access

  • Support technical troubleshooting

  • Enforce session expiration

Once the information is no longer reasonably necessary, it may be deleted, anonymized, or otherwise handled according to applicable retention practices.


14. Data Minimization

Cry-Fi may take reasonable steps to avoid retaining information that is no longer necessary for the purpose for which it was collected.

Where appropriate and technically feasible, information may be:

  • Deleted

  • Anonymized

  • Aggregated

  • De-identified

  • Restricted from further ordinary use

The availability of these measures may depend on the type of information, technical systems, legal requirements, and legitimate retention needs.


15. Policy Changes

Cry-Fi may update this Policy from time to time.

The updated version will be published on the Platform with a revised “Last Updated” date.

Where required by applicable law, Cry-Fi may provide additional notice regarding material changes.

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