Privacy Policy

1. General Provisions
This Privacy Policy (hereinafter – the “Policy”) has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the “Personal Data Law”) and defines the procedures for processing personal data as well as the measures taken by Voicepons LLC (hereinafter – the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy, personal and family secrecy, as a primary objective and condition for its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://voiceponce.ru/, as well as through feedback forms located on the domains https://voiceponce.ru/ and through the personal account https://client.voiceponce.ru/.

2. Basic Definitions Used in this Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://voiceponce.ru/.
2.4. Personal data information system – a set of personal data contained in databases, as well as information technologies and technical means that enable their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state or municipal authority, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://voiceponce.ru/.
2.9. Personal data permitted by the personal data subject for dissemination – personal data access to which is provided by the personal data subject by giving consent for the processing of such data for dissemination in accordance with the procedure provided by the Personal Data Law.
2.10. User – any visitor to the website https://voiceponce.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an indefinite number of persons with personal data, including publication in the media, placement in information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Rights and Obligations of the Operator
3.1. The Operator has the right to:

receive from the personal data subject accurate information and/or documents containing personal data;
in the event that the personal data subject withdraws their consent to the processing of personal data or submits a request to cease processing, continue processing personal data without the subject’s consent where there are legal grounds as provided for by the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted pursuant to it, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

provide the personal data subject, upon their request, with information regarding the processing of their personal data;
organize the processing of personal data in accordance with the current legislation of the Russian Federation;
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days of receiving such a request;
publish or otherwise ensure unrestricted access to this Privacy Policy on the processing of personal data;
take legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions;
cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
fulfill other obligations established by the Personal Data Law.

4. Fundamental Rights and Obligations of Personal Data Subjects
4.1. The personal data subject has the right to:

obtain information relating to the processing of their personal data, except as provided by federal law. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
stipulate a condition of prior consent when processing personal data for the purposes of promoting goods, works, and services on the market;
withdraw consent to the processing of personal data and submit a request to cease processing;
appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator during the processing of their personal data;
exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate data about themselves;
notify the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or with information about another personal data subject without their consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. The processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. The combination of databases containing personal data that are processed for incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of processing is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of their processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless a personal data retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event that the necessity to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Processing and Categories of Personal DataPurposes of Processing:

providing Clients of Voicepons LLC with access to feedback submitted by their customers through the personal account;
providing Users with access to the services, information, and/or materials available on the website;
storing and analyzing feedback;
complying with legal requirements.

Categories of Data:

name;
telephone number;
e-mail address;
biometric personal data — voice messages processed for the purposes of transcription and speech content analysis.

7. Conditions for the Processing of Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and for the exercise of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court judgment, or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant objectives, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out in relation to personal data that has been made publicly available by the personal data subject or at their request (hereinafter – publicly available personal data).
7.7. Processing is carried out in relation to personal data that must be published or disclosed under federal law.

8. Collection, Storage, Transfer, and Other Types of Personal Data Processing
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.
8.2. Personal data may be transferred to third parties:

Clients of Voicepons LLC (both legal entities and individuals) who own specific feedback forms;
Contractors of the Operator with whom agreements have been concluded ensuring compliance with Federal Law No. 152-FZ (e.g., hosting providers and analytical services);
OpenAI – for the purpose of speech transcription;
Government authorities in cases provided for by law.

8.2.1. The Operator transfers personal data to third parties as follows:
8.2.1.1. Transfer of data to clients and contractors is carried out under strict confidentiality and with the adoption of appropriate data protection measures. These obligations are set out in agreements between the Operator and the third parties.
8.2.1.2. The transfer of biometric data (voice messages) to OpenAI for transcription is carried out on the basis of separate consent from the personal data subject. The subject is informed that OpenAI is not a party to any agreement that would ensure compliance with Russian personal data protection legislation.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@voiceponce.ru with the subject “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email to info@voiceponce.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their own Terms of Use and Privacy Policies. The personal data subject and/or user is obliged to independently review these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data for state, public, and other public interests as determined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of personal data processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of processing, the expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator carries out the following actions with the personal data it collects: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (including provision and access), depersonalization, blocking, deletion, and destruction.
9.2. The Operator performs automated processing of personal data, with the receipt and/or transfer of the obtained information through information and telecommunications networks or without such transfer.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. The Operator carries out the cross-border transfer of voice messages to the United States (to OpenAI) for the purpose of transcribing voice feedback and obtaining textual information. Data transfer is carried out with the consent of the personal data subject, obtained in a simple written form, including, but not limited to, by the user checking a consent box before submitting feedback.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose such data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final Provisions
12.1. The User may obtain any clarification on matters relating to the processing of their personal data by contacting the Operator via email at info@voiceponce.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is published on the Operator’s website: https://voiceponce.ru/privacy/en.