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If you are returning the device to Dell for warranty purposes, they will most likely just do a systematic wipe of all data right away so they can work on refurbishing the unit, if possible. As jnev said, it's unlikely Dell would work too hard to check out someone's data. However, having said that, if it is data of a very sensitive nature, I'd do more than just a hard reset to make it as inaccessible as possible. If it's just personal, but not sensitive info, then a hard reset should suffice.
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