1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by LLC "Voiceponce" (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy, personal and family secrets, to be its most important goal and condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://voiceponce.ru/, as well as through feedback forms posted on the domains https://voiceponce.ru/, and through the personal account at https://client.voiceponce.ru/.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://voiceponce.ru/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalisation of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that independently or jointly with others organises and/or carries out the processing of personal data, and also determines the purposes of processing personal data, 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 a specific or identifiable User of the website https://voiceponce.ru/.
2.9. Personal data permitted by the data subject for distribution — personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data permitted by the data subject for distribution in the manner provided for by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
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. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarising an unlimited number of persons with personal data, including publishing personal data in the media, placing it in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Destruction of personal data — any actions as a result of which personal data is destroyed irreversibly with no possibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

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

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

3.2. The Operator is obliged to:

• provide the data subject, upon request, with information relating to the processing of their personal data;
• organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to requests and enquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• communicate to the authorised body for the protection of the rights of personal data subjects, upon request, the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
• take legal, organisational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data;
• cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfil other obligations provided for by the Personal Data Law.

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

• receive information relating to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand that the Operator clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and also to take measures provided for by law to protect their rights;
• set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data, and to submit a request to cease the processing of personal data;
• appeal to the authorised body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in 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 information about themselves;
• inform the Operator of any clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data whose processing is carried out for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of personal data being processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing is ensured. The Operator takes the necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the data subject to be identified for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Personal data being processed is destroyed or depersonalised upon achieving the purposes of processing or upon the loss of the need to achieve those purposes, unless otherwise provided by federal law.
6. Purposes of Processing and Categories of Personal Data
6.1. Purposes of processing:

• providing clients of LLC "Voiceponce" with access through their personal account to feedback left by their customers;
• providing the User with access to services, information, and/or materials contained on the website;
• storage and analysis of feedback;
• compliance with legal requirements.

6.2. Categories of data:

• name;
• phone number;
• email address;
• audio recordings of voice messages submitted by users through feedback forms, processed solely for the purposes of automatic text transcription and content analysis in order to provide the service; such data is not used to identify the data subject.

7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not thereby violated.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. Personal data may be transferred to third parties:

• Clients of LLC "VOICEPONCE" (both legal entities and individuals) who are the owners of specific feedback forms.
• Contractors of the Operator — providers of technical infrastructure (hosting, cloud services, analytics) acting under data processing agreements in accordance with Article 6 of Federal Law No. 152-FZ.
• Government authorities in cases provided for by law.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to info@voiceponce.ru with the subject line "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 a different period is provided for by a contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to info@voiceponce.ru with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. When processing personal data, the Operator may engage third parties — providers of technical infrastructure (hosting, cloud services, analytics) acting under data processing agreements in accordance with Article 6 of Federal Law No. 152-FZ. All engaged providers are obliged to maintain confidentiality and ensure the protection of personal data to a standard no lower than the requirements of this Policy. The Operator takes the necessary organisational and technical measures to ensure that such persons duly comply with personal data legislation.
8.6. Prohibitions established by the data subject on the transfer (other than access provision), as well as on the processing or conditions of processing (other than access) of personal data permitted for distribution, do not apply in cases where personal data is processed in the state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the data subject's consent, withdrawal of consent by the data subject, or a request to cease processing, as well as upon identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (including provision and access), depersonalisation, blocking, deletion, and destruction.
9.2. The Operator performs automated processing of personal data with or without the receipt and/or transfer of information received via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data
The Operator does not carry out cross-border transfer of personal data.

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

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