Concerning Windows, the help page about the factory reset states "You'll be asked to choose whether you want to erase data quickly or thoroughly. If you choose to erase data quickly, some data might be recoverable using special software. If you choose to erase data thoroughly, this will take longer but it makes recovering data less likely." [1]

Of course deleting data on an SSD is tricky due to wear-leveling, anything short of telling the drive to erase the entire disk with the secure erase command isn't guaranteed to work.

1: https://support.microsoft.com/en-us/windows/how-to-refresh-r...