Consent to the Processing of Personal Data
Acting freely, of their own will and in their own interest, and pursuant to Articles 6 and 9 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”, the User hereby grants Shakhbanov Zurab Mukhtarovich, sole trader (INN 054203786124, OGRNIP 326050000099429, e-mail: support@whisperer.one; the “Controller”), consent to process their personal data on the terms set out below.
1. Categories of personal data
Consent is granted for the processing of the following personal data of the User:
- e-mail address;
- name (display name), avatar;
- phone number (if provided);
- password (stored solely as an irreversible bcrypt cryptographic hash);
- interface language, gender (if provided);
- audio stream from the device microphone and system audio during an active session (processed in real time; raw audio files are not retained);
- meeting transcripts, notes, context materials and files uploaded by the User to the Service;
- the content of requests made to the Service’s AI assistant;
- calendar event data where the User connects integrations with external calendars;
- subscription and payment transaction records (amount, date, status; bank card details are neither transmitted to nor processed by the Controller);
- IP address, User-Agent, technical device and session data;
- cookies and session identifiers;
- records of interaction with the Service interface (event and error logs).
2. Purposes of processing
- registration and identification of the User, provision of access to the personal account;
- delivery of the Service’s core function: speech recognition, meeting transcription, and generation of text suggestions and notes using AI models;
- provision of supporting functionality: file storage, video meetings, calendar, task tracker, integrations;
- sending transactional notifications relating to the operation of the Service and the account;
- performance of obligations in respect of paid services and compliance with tax and accounting legislation;
- ensuring information security and preventing abuse and fraud;
- internal statistics and improvement of the Service.
3. Operations performed on personal data
The Controller may carry out the following operations on the personal data listed in clause 1:
- collection, recording, systematisation, accumulation, storage, updating (renewal, alteration), extraction, use;
- blocking, erasure, destruction, anonymisation;
- transfer (provision, access) to the processors listed in the Privacy Policy, to the extent necessary to perform the contract with the User.
4. Methods of processing
Processing is carried out by mixed means:
- by automated means within the Controller’s information systems;
- by non-automated means when handling User enquiries.
5. Cross-border transfer
The User is informed of, and agrees to, the fact that the Service’s core function cannot technically be delivered without transferring data to external AI and API platforms for speech recognition and text generation whose servers are located outside the Russian Federation.
The User hereby consents to the cross-border transfer of the personal data listed in clause 1 (audio stream, transcripts, requests to the AI assistant, uploaded files) for the purposes set out in clause 2. Only the volume of data necessary to deliver the service is transferred. The current list of processors is set out in the Privacy Policy.
The User may decline cross-border transfer by ceasing to use those functions of the Service that require speech processing and text generation, or by deleting their account.
6. Term of consent
This consent takes effect when granted by the User at registration and remains in force until any of the following occurs:
- withdrawal of consent by the User;
- deletion of the account by the User;
- achievement of the purposes of processing.
Upon expiry of these periods the personal data is destroyed or anonymised in accordance with the Privacy Policy.
7. Withdrawal of consent
The User may withdraw this consent at any time by one of the following means:
- by sending a request to support@whisperer.one;
- by deleting the account in the “Settings” section of the personal account.
Withdrawal of consent terminates the processing of personal data and results in its erasure or anonymisation within no more than 30 (thirty) calendar days, save where further retention is required by law (in particular, statutory retention periods for accounting records). Because processing of the data listed above is necessary to deliver the service, withdrawal of consent makes further use of the Service impossible.
8. Confirmation
By ticking the corresponding box in the registration form, the User confirms that they:
- have read this Consent, the Privacy Policy and the Terms of Use (public offer);
- have received exhaustive information about the Controller, the purposes, scope and procedure of processing of their personal data, and about their rights as a data subject;
- grant this consent knowingly and voluntarily.
The Controller records the fact that consent was granted — the date and time, the revision of this document, and the IP address and User-Agent of the User’s device — in its own information systems in order to demonstrate the lawfulness of processing.
9. Contact
Shakhbanov Zurab Mukhtarovich (sole trader)
INN 054203786124, OGRNIP 326050000099429
Email: support@whisperer.one