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Data Processing Addendum

  1. TERMS AND DEFINITIONS

"Website (Portal)" — a collection of files posted online, united by the domain name space PRAVDALIST.AI, the Contractor’s official website at https://pravdalist.ai, https://www.pravdalist.ai, https://private.pravdalist.ai.

"Website User (User)" — any person who communicates or performs actions on the Website and thereby automatically confirms full Addendum with the provisions of this Addendum

“Audio Recording” (or “Voice Data”) — a digital voice recording uploaded by the User to the Site for cognitive-acoustic analysis. If the User uploads a video file (multi-channel media file), the Audio Recording refers exclusively to the audio track extracted from it. The Site does not process, analyze, or store the visual (video) portion of uploaded files.

“Audio File” — an electronic (digital) file in a specialized audio format (including, but not limited to, MP3, WAV, M4A, FLAC) uploaded by the User to the Site. The audio file serves exclusively as a digital container storing the Audio Recording for its subsequent cognitive-acoustic analysis and does not contain visual (video) data.

  1. GENERAL PROVISIONS

This Data Processing Addendum (hereinafter, the “Addendum”) governs the terms and conditions under which a user consents to the collection, storage, use, analysis, transfer, and other processing of their personal data by the Pravdalist.ai platform (hereinafter, the “Service,” “Site,” or “We”).

By using the Site, registering on the Site, logging in via third-party services, uploading audio files or voice messages, making payments, or otherwise providing data through the Site, the user confirms that they have read this Addendum and consent to the processing of their personal data under the terms set forth below.

If the user does not agree to the terms of this Addendum, they must cease using the Site and its services.

  1. DATA SUBJECT

The data subject is a user of the Pravdalist.ai Website who provides their personal data voluntarily and knowingly.

In cases where the user uploads audio recordings to the Site containing the voice, speech, or other data of third parties, the user confirms that they have obtained all necessary permissions, consents, and legal grounds for such transfer and processing of third-party data.

  1. OWNER AND CONTROLLER OF PERSONAL DATA

The owner and controller of users’ personal data is Pravdalist.ai.

In certain cases, to ensure the operation of the Site, Pravdalist.ai may engage technical partners, payment providers, hosting providers, cloud services, DDoS protection services, analytics, and other infrastructure services, which may act as personal data processors.

  1. CONSENT TO THE PROCESSING OF PERSONAL DATA

The user grants Pravdalist.ai consent to process their personal data in accordance with applicable law, including but not limited to:

  • The Law of Ukraine “On the Protection of Personal Data”;

  • The European Union’s General Data Protection Regulation (GDPR), if the user is located in the European Union or if the processing falls under the scope of the GDPR;

  • applicable U.S. laws on personal data protection, including the CCPA/CPRA for users in California, if such laws apply;

  • other applicable laws and regulations in the field of personal data protection.

Consent is provided by the user voluntarily, knowingly, and for the purpose of using the Site’s services.

The act of providing personal data through the Site, uploading audio recordings, using analytics features, registering, logging in via third-party services, or paying for services is deemed to constitute the user’s consent to the processing of such data in accordance with the terms of this Addendum.

  1. SPECIAL CONSENT FOR THE PROCESSING OF VOICE AND BIOMETRIC DATA

The User separately confirms and agrees that the functionality of Pravdalist.ai may involve the analysis of audio recordings, voice messages, voice samples, and other acoustic data.

The User understands that voice, speech characteristics, acoustic parameters, and other derived indicators may constitute biometric data or data that allows for the direct or indirect identification of a natural person.

By uploading audio files, voice messages, or other recordings, the user provides Pravdalist.ai with explicit consent to process such data, including:

  • receiving and uploading audio files;

  • storing audio files for the period necessary to provide the service;

  • technical processing of audio recordings;

  • extracting acoustic, speech, cognitive, and other parameters;

  • conducting cognitive-acoustic analysis;

  • generating analysis results;

  • creation of derived metrics, assessments, reports, and other processing results;

  • displaying analysis results to the user;

  • using anonymized or aggregated data to improve the quality of the Service, if permitted by applicable law.

The user confirms that they are aware of the nature of the data being transmitted and understand that audio recordings and voice data may constitute sensitive personal data.

The User acts as the Data Controller and guarantees that they have obtained all necessary consents from the subjects of speech (speakers) for the collection, transfer to the Contractor, and biometric analysis of their voice data. The User undertakes to indemnify the Contractor from any third-party claims related to the lack of such consent.

  1. PERSONAL DATA FOR WHICH CONSENT IS GIVEN

The User consents to the processing of the following categories of personal data.

7.1. Registration and contact information

  • first and last name;

  • username;

  • password or other authentication data;

  • email address;

  • contact phone number;

  • information provided when filling out registration forms;

  • data provided while using the Site’s services.

7.2. Technical data

  • IP address;

  • cookies;

  • Internet browser parameters and settings;

  • User-Agent;

  • Device type;

  • operating system;

  • interface language;

  • date, time, and duration of use of the Site;

  • data on the user’s actions on the Site;

  • event logs, error logs, and technical logs.

7.3. Voice, audio, and biometric data

  • audio recordings;

  • voice messages;

  • audio files uploaded by the user;

  • voice samples;

  • speech fragments;

  • acoustic characteristics of the voice;

  • speech parameters;

  • results of cognitive-acoustic analysis;

  • derived metrics, assessments, reports, and other analysis results;

  • other data obtained as a result of technical processing of audio recordings.

7.4. Data Received from Third-Party Authentication Services

If a user logs in via third-party authentication services, including Google, Apple ID, or other similar services, Pravdalist.ai may receive and process:

  • the user’s ID in the relevant service;

  • email address;

  • username;

  • public profile;

  • avatar or profile picture, if provided by the authorization service;

  • access tokens or other technical data required for authorization;

  • data that the user has authorized to be transferred via the relevant third-party service.

Pravdalist.ai does not control the amount of data collected by third-party authorization services on their own. Users are advised to review the privacy policies of the relevant services.

7.5. Payment and Transaction Data

When paying for services, Pravdalist.ai may process data related to payments and transactions, including:

  • the selected plan or service;

  • payment amount;

  • payment currency;

  • payment status;

  • the date and time of the payment;

  • payment ID;

  • order ID;

  • payment provider details;

  • Masked payment method details, if provided by the payment provider;

  • cryptocurrency transaction identifiers;

  • addresses or identifiers of crypto wallets, if used for payment;

  • information about refunds, cancellations, or disputed payments.

Pravdalist.ai does not store users’ full bank card details, including the full card number, CVV/CVC code, and other sensitive payment details. Such data is processed by payment providers, payment gateways, or financial institutions, including LiqPay, Plisio, and other services, if they are used for payment.

  1. AGE RESTRICTIONS

The Service is intended only for users who have reached the age of 18 or the age of majority established by the laws of the user’s country of residence.

By using the Site, the user confirms and warrants that:

  • they are at least 18 years old or have reached the age of majority under the laws of their country;

  • they have full legal capacity and legal competence to accept the terms of this Addendum;

  • they do not upload audio recordings containing the voices of minors to the Site;

  • they will not use the Service to process personal, voice, or biometric data of minors.

If Pravdalist.ai becomes aware that a user has not reached the required age or has uploaded data of a minor without proper legal grounds, such data may be deleted, and the user’s access to the Service may be restricted or terminated.

  1. THIRD-PARTY RIGHTS IN AUDIO RECORDINGS

The user is solely responsible for the legality of obtaining, storing, transmitting, and uploading audio recordings to the Site.

By uploading an audio recording, the user confirms and warrants that:

  • they are a participant in the relevant recording or have the legal right to use such a recording;

  • they have obtained the consent of all persons whose voices, speech, or personal data are contained in the audio recording, if such consent is required by law;

  • the upload and processing of such a recording do not infringe upon the rights of third parties;

  • the upload of the recording does not violate laws regarding the secrecy of communications, confidentiality, personal data protection, intellectual property, or other applicable regulations;

  • he assumes full responsibility for any claims, complaints, demands, losses, or disputes related to the audio recordings he uploads.

Pravdalist.ai is not obligated to verify the legality of the user’s acquisition of each audio recording and is not liable for any infringement of third-party rights by the user when uploading audio files.

  1. PURPOSES OF PERSONAL DATA PROCESSING

The user’s personal data may be processed by Pravdalist.ai for the following purposes:

  • providing access to the Site’s services;

  • user registration and authorization;

  • creating and maintaining a user account;

  • user identification;

  • ensuring the operation of the Site;

  • receiving, storing, and technically processing audio files;

  • conducting cognitive-acoustic analysis;

  • generating analysis results, reports, evaluations, and derived metrics;

  • displaying analysis results to the user;

  • processing payments and managing rates;

  • checking payment status;

  • providing technical support;

  • sharing information and news;

  • communicating with the user;

  • processing user requests, inquiries, and messages;

  • improving the quality of the Site’s services;

  • analyzing statistics on visits to and use of the Site;

  • ensuring the security of the Site;

  • preventing abuse, fraud, and unauthorized access;

  • complying with legal requirements;

  • protecting the rights and legitimate interests of Pravdalist.ai;

  • conducting advertising, informational, and communication activities, provided such activities are permitted by law and the user’s settings.

  1. METHODS OF PROCESSING PERSONAL DATA

The user consents to the following actions being performed with their personal data:

  • collection;

  • receipt;

  • recording;

  • registration;

  • systematization;

  • accumulation;

  • storage;

  • adaptation;

  • modification;

  • updating;

  • retrieval;

  • use;

  • analysis;

  • technical processing of audio recordings;

  • generation of derived data and metrics;

  • transfer to processors and technical partners in cases provided for in this Addendum;

  • anonymization;

  • aggregation;

  • blocking;

  • deletion;

  • destruction;

  • other actions necessary to achieve the purposes of personal data processing.

The processing of personal data may be carried out using automated systems, analysis algorithms, and software for audio processing, including tools for converting and analyzing audio files, as well as without the use of such systems.

  1. STORAGE OF PERSONAL DATA

Personal data is stored in data centers, with hosting providers, cloud providers, or other technical partners that ensure the functioning of the Site’s services.

The retention period for personal data does not exceed the time necessary to achieve the purposes of its processing, unless a longer retention period is required or permitted by law.

Audio recordings, voice data, and analysis results are stored for the period necessary to provide the user with the relevant service, ensure the operation of the account, fulfill contractual obligations, resolve disputes, protect the rights of Pravdalist.ai, or comply with legal requirements.

Once the purposes of processing have been achieved, personal data may be deleted, anonymized, or aggregated.

  1. TRANSFER OF PERSONAL DATA TO THIRD PARTIES AND PROCESSORS

Pravdalist.ai does not sell users’ personal data to third parties.

However, the user agrees that, to ensure the operation of the Service, personal data may be transferred to or made available to the following categories of third parties and technical partners:

  • hosting providers;

  • data centers;

  • cloud providers;

  • computing power providers;

  • services protecting against DDoS attacks and network threats, including Cloudflare or similar services;

  • payment providers and payment gateways, including LiqPay, Plisio, or similar services;

  • authorization services, including Google, Facebook, Microsoft, Apple ID, and similar services;

  • analytics services;

  • technical support services;

  • contractors ensuring the operation, security, and development of the Site;

  • government authorities, if disclosure is required by law.

Such third parties may act as data processors and are required to process data only for the purposes necessary to provide the relevant services, as well as to comply with data privacy and security requirements.

The transfer of personal data is also permitted in cases where:

  • such transfer is required by law;

  • the transfer is made at the user’s request;

  • the user has consented to such a transfer;

  • the transfer is necessary to fulfill obligations to the user;

  • the transfer is necessary to protect the rights and legitimate interests of Pravdalist.ai;

  • the transfer is necessary to prevent fraud, abuse, or security threats.

  1. INTERNATIONAL DATA TRANSFER

The user understands and agrees that Pravdalist.ai may use technical infrastructure and services located in different countries.

Accordingly, personal data may be transferred, stored, or processed outside the user’s country of residence.

When transferring data internationally, Pravdalist.ai takes reasonable measures to ensure an adequate level of data protection in accordance with applicable law.

For users from the European Economic Area, international transfers of personal data are carried out in accordance with the requirements of the GDPR, including the use of appropriate legal mechanisms for data transfer, if required by law.

  1. USE OF COOKIES AND TECHNICAL DATA

The user agrees that when using the Site, Pravdalist.ai may use cookies and other similar technologies.

Cookies may be used to:

  • ensuring the proper functioning of the Site;

  • user authentication;

  • saving user settings;

  • analyzing visitor statistics;

  • improving service quality;

  • ensuring security;

  • preventing fraud;

  • providing relevant content.

Users can change their cookie settings in their browser.

Disabling cookies may result in limited access to certain features of the Site or cause services to function incorrectly.

  1. USER RIGHTS AS A DATA SUBJECT

The user has the rights provided for by applicable data protection laws, including the right to:

  • to know the sources of collection, the location of their personal data, and the purposes of its processing;

  • to receive information about the conditions for granting access to personal data;

  • to access their personal data;

  • to request the correction of inaccurate or outdated data;

  • to request the deletion of their personal data if there are legal grounds for doing so;

  • withdraw consent to the processing of personal data;

  • restrict the processing of personal data in cases provided for by law;

  • object to the processing of personal data in cases provided for by law;

  • receive your data in a structured, commonly used, and machine-readable format, if such a right applies;

  • file complaints regarding the processing of personal data with the competent authorities or a court.

For users in the European Union, these rights may include those provided for under the GDPR.

For users in California, these rights may include those provided by the CCPA/CPRA, if applicable.

  1. WITHDRAWAL OF CONSENT

The user has the right to withdraw their consent to the processing of personal data.

Withdrawal of consent may result in the inability to continue using certain features or services of the Site if the processing of the relevant data is necessary for their provision.

In particular, withdrawing consent to the processing of voice, audio, or biometric data may make it impossible to use audio recording analysis features.

Upon receiving the withdrawal of consent, Pravdalist.ai ceases processing the user’s relevant personal data, except in cases where further processing is required or permitted by law, necessary to protect Pravdalist.ai’s rights, fulfill contractual obligations, resolve disputes, or prevent abuse.

  1. PROTECTION OF PERSONAL DATA

Pravdalist.ai takes the necessary organizational and technical measures to protect the user’s personal data from:

  • unlawful processing;

  • unauthorized access;

  • accidental loss;

  • destruction;

  • damage;

  • alteration;

  • dissemination without legal grounds;

  • other unlawful actions.

Such measures may include technical safeguards, access restrictions, the use of secure communication channels, system access controls, security monitoring, and other reasonable measures appropriate to the nature of the data being processed.

  1. LIMITATION OF LIABILITY REGARDING DATA UPLOADED BY THE USER

The User independently determines what data, audio files, and materials they upload to the Site.

Pravdalist.ai is not liable for:

  • the user’s illegal recording of conversations;

  • uploading audio recordings without the consent of the individuals whose voices are contained in the recording;

  • the user’s violation of third-party rights;

  • the user providing inaccurate data;

  • the user’s use of analysis results for illegal, discriminatory, harmful, or other unlawful purposes.

The user agrees to indemnify Pravdalist.ai for any losses, expenses, claims, or demands from third parties arising from the user’s breach of this Addendum or the rights of third parties.

  1. CONFIRMATION OF CONSENT

The User confirms that:

  • the personal data provided by them is accurate;

  • the personal data has been provided voluntarily;

  • the User is familiar with the purposes of processing personal data;

  • the User is aware that audio recordings and voice data may constitute biometric or sensitive personal data;

  • the user gives explicit consent to the processing of voice, audio, and derived data;

  • the user is at least 18 years old or has reached the age of majority under the laws of their country;

  • The user does not upload audio recordings of minors;

  • The user has the legal right to upload audio recordings containing the voices of third parties;

  • The user is familiar with their rights;

  • The user agrees to the terms of this Addendum;

  • The user agrees to the Pravdalist.ai Privacy Policy.

  1. TERM OF THE CONSENT

This consent is effective from the moment the user provides personal data, registers, logs in, uploads an audio recording, uses the Service, or performs any other action related to data transfer.

The consent remains in effect until the purposes of processing personal data are achieved or until the user revokes it, unless otherwise provided by law.

  1. AMENDMENTS TO THE Addendum

Pravdalist.ai may amend this Addendum, including in the event of changes to legislation, the functionality of the Site, the procedure for processing personal data, the composition of technical partners, or the services used.

Users are advised to periodically review the current version of this Addendum.

Continued use of the Site after changes are made constitutes the user’s acceptance of the updated version of the Addendum.