In view of Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation; GDPR), we would like to inform you as follows about certain matters associated with our data processing operations.

Data subjects	Deepting APP users
The purpose of processing	For registration purpose to use the Deepting APP service. Email or Google ID or Apple ID is used as account login ID, and if the data subjects forgot his or her login password, it is convenient to retrieve password by email.
Data processed	Email address, user-defined password，Google ID, Apple ID
Legal basis	Consent of the data subject.
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn the data will be deleted. otherwise the data controller will store and process his or her data until the existence of the registration.
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	Data subjects will not be able to use the product/manage his or her files/receive service-related notification through his or her personal account.
Data processors	VerbaLink Europe Kft. and its server supplier in EU, Google, Apple

Data subjects	Deepting APP users
The purpose of processing	Using the main function of Deepting APP service – record and convert the voice data into text format.
Data processed	Voice data
Legal basis	Consent of the data subject
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn the data will be deleted. Otherwise the data controller will store and process his or her data until the existence of the registration.
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	Data subjects will not be able to use the main function of the product which is voice-to-text transcription.
Data processors	VerbaLink Europe Kft. and its cloud service supplier and speech-to-text service supplier in EU

Data subjects	Deepting APP users
The purpose of processing	Using the auto-name function to recognize the recorded files by users' current location information
Data processed	Location information
Legal basis	Consent of the data subject
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn the data will be deleted. Otherwise the data controller will store and process his or her data until the existence of the registration.
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	If the data subjects turned down the permission for granting their location information, the recorded files will be unanimously named Note.
Data processors	VerbaLink Europe Kft. and its server supplier in EU

Data subjects	Deepting APP users
The purpose of processing	Using the Deepting APP service - editing, inserting images to transcribed files.
Data processed	Images, transcription text
Legal basis	Consent of the data subject.
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn the data will be deleted. Otherwise the data controller will store and process his or her data until the existence of the registration.
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	Data subjects will not be able to edit or insert images to transcribed files.
Data processors	VerbaLink Europe Kft. and its server supplier in EU

Data subjects	Deepting APP users
The purpose of processing	Subscribe to Deepting Pro in order to get more transcription minutes.
Data processed	Account(email), payment time, status of subscription, subscription start time, records of minutes distribution, subscription end time
Legal basis	Consent of the data subject.
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn the data will be deleted. Otherwise the data controller will store and process his or her data until the existence of the registration.
Mandatory or voluntary provision of data	Mandatory if the users choose to subscribe to Deepting Pro
Consequences of failing to provide data	Data subjects will not be able to subscribe to Deepting Pro and get more transcription minutes.
Data processors	VerbaLink Europe Kft. and its server supplier in EU, third-party payment suppliers such as Google and Apple Pay

Data subjects	Deepting APP users and everyone who contacts the Customer Service.
The purpose of processing	Providing Customer Service for the data subject. (To gain a detailed understanding of your feedback and needs, and to respond accordingly)
Data processed	Email address, Audio ID
Legal basis	Consent of the data subject.
Duration of processing	The data subject may withdraw his or her consent to the data processing at any time, when the consent is withdrawn, the data will be deleted; otherwise the data controller will store and process his or her data until it is necessary to deal with data subject enquiries and feedback
Mandatory or voluntary provision of data	Mandatory, but if you only make a simple consultation or feedback to us, you can anonymously give feedback in this scenario and we do not need to collect your relevant information, so this scenario is Voluntary.
Consequences of failing to provide data	If data subjects have question/comment/suggestion, they may use the customer feedback section on the APP and send a letter to the customer support email address. He or she might be asked to provide Email address, Audio ID for the customer service representative to locate the problem. Audio ID is string of characters generated randomly by the system. Audio ID can be found on upper right corner of the transcription results page (click More – Audio ID – Audio ID copied). Data subjects may be asked to provide this id when they report an issue with the transcription results. Failing to provide the data subject will not be able to receive appropriate customer services
Data processors	VerbaLink Europe Kft. and its server supplier in EU, Lenovo (Slovakia) as customer service supplier

Data subjects	Deepting APP users
The purpose of processing	IT troubleshooting
Data processed	IP address, phone model, phone system version, phone screen, App version, uid, audio id, audio file names, duration of audio files, way of registration, start time of registration, available transcription minutes, redeem records, available transcription minutes, session id, start/exit records, search records, payment records, subscription records
Legal basis	Consent of the data subject
Duration of processing	90 days from the data subject's trouble reporting.
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	Data controller will not be able to provide system investigation/IT troubleshooting/rectification of product's problems.
Data processors	VerbaLink Europe Kft. and its server supplier in EU

Data subjects	Deepting APP users
The purpose of processing	Marketing campaign and user engagement attribution and analytics
Data processed	Technical information such as browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier. Technical Identifiers such as IP address, user agent, IDFA, Android ID, Google Advertiser ID, user ID. Engagement Information such as clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the URL from the referring website, downloads and installations of Applications, and other in-app events to measure user engagement within the Application or website.
Legal basis	Consent of the data subject
Duration of processing	24 months
Mandatory or voluntary provision of data	Mandatory
Consequences of failing to provide data	The data controller will not be able to record the performance of its marketing and promotion campaigns, nor will they be able to improve the acquisition and engagement strategies to provide its data subjects with better service and experiences. There are no consequences for the data subject if he or she does not give consent, and he or she can use the application even in the absence of data processing.
Data processors	AppsFlyer Please note that the data controller does not collect the above information directly from the data subjects during this process; AppsFlyer collects them and generates aggregated Dashboard for the data controller to view and evaluate the performance of its marketing campaign and in-app events. You can find information regarding AppsFlyer's data processing on the following page: https://www.appsflyer.com/legal/privacy-policy/

The data controller will transfer your personal data to its service providers when it is relevant for the performance of processing purposes as described in Section 5 of this privacy notice. The data controller may transfer your personal data to parties that cooperate with it under contract, exclusively for the purpose of performing a contract concluded with you or with your company. Your personal data may also be transferred on an ad hoc basis (if absolutely necessary, for example in connection with a legal dispute or for the determination of the correct financial or accounting treatment of a transaction) to service providers engaged by the data controller, such as lawyers, auditors or financial advisors, who are subject to professional or contractual confidentiality obligations.

Recipients / categories of recipients:

Recipients	Purpose of data transfer
Data processors
VerbaLink Europe Kft. In Hungary	Purchase cloud service, deploy engines to the servers, and conduct server-side data processing and IT troubleshooting
Google in EU	3rd party SDK Deepting used to process Google email address sign-up and login; payment and subscriptions on Google Play Store; data statistics by Google Firebase.
Apple in EU	3rd party SDK Deepting used to process Apple ID sign-up and login; payment and subscriptions on App Store.
Customer Service supplier in EU	Data processor, provide customer service support
AppsFlyer in EU	Marketing attribution and analytic supplier
Sub-processors (processors of VerbaLink Europe Kft.)
Cloud services suppliers in Germany and Ireland	Data storage and processing
Speech-to-text service supplier in EU	3rd party supplier the data processor purchased licence from to process speech to text transcription for some source languages
Translation service supplier in Singapore	3rd party supplier the data processor purchased licence from to process translation transcription for some source languages

Right to information: You can use the above contact details to contact the controller at any time and request information about processing involving your personal data; request the controller to rectify or erase your data or restrict the processing of your data; or object to such processing.

Right of access: At your request, the controller will inform you whether your data is being processed. If yes, you will be entitled to gain access to your personal data that are processed by the controller, and to information concerning the recipients or categories of recipient to whom the personal data have been or will be disclosed, the proposed period of the processing or the criteria used to determine that period, and the sources of the data.

At your request, the controller will provide to you a copy of the personal data undergoing processing. The controller may charge a reasonable fee, based on administrative costs, for any further copies you request. If you make the request by electronic means, the information will be provided in a commonly used electronic form, unless you request otherwise.

Right to rectification: You have the right to request rectification of any inaccurate data and completion of any incomplete data.

Right to withdraw consent: You have the right to withdraw your consent to the future processing of your personal data. The withdrawal of your consent will not affect the lawfulness of processing that is performed on the basis of your consent before its withdrawal.

Right to erasure: You can request the erasure of your personal data from the controller if:

• a) the personal data are no longer necessary in relation to the purposes for which they were processed;
• b) you withdraw your consent and there is no other legal ground for the processing;
• c) the conditions for making an objection apply;
• d) the data processing is unlawful;
• e) the erasure is necessary for compliance with a legal obligation to which the controller is subject;
• f) you are a minor under the specific age as defined by applicable laws.

The controller will erase your data on the basis of such request, except if further processing is necessary

• a) to ensure compliance with a relevant legal obligation to which the controller is subject, or
• b) for the establishment, exercise or defence of legal claims.

• a) you contest the accuracy of the personal data, in that case the restriction will apply for a period while the accuracy of the data can be verified,
• b) the processing is unlawful but you oppose the erasure of the personal data and request the restriction of their use instead,
• c) the controller no longer requires the data for processing, but you need them for the establishment, exercise or defence of legal claims,
• d) you have objected to the processing, in which case the restriction will apply for a period while it is verified whether the legitimate grounds of the controller override yours.

If the processing is subject to restriction in accordance with the above, the relevant personal data may, with the exception of storage, only be processed with your consent, or for the establishment, exercise or defence of legal claims, for the protection of the rights of another person or for reasons of important public interest of the European Union or of a Member State. The controller will inform you before the restriction of processing is lifted.

You and all other persons to whom your data have been transferred will be informed about any rectification, erasure or restriction. The controller will not provide such information if this is impossible or involves a substantial effort. If the controller has made the personal data public and is obliged to erase the personal data, it will, in the light of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers that are processing the personal data about your request that they should erase any links to, or copy or replication of, those personal data.

• a) it is done on the basis of a legitimate interest; in that case the processing may not be continued, unless there are compelling and legitimate reasons for the processing that override your interests, rights and freedoms, or reasons that are related to the establishment, exercise or defence of legal claims;
• b) it is done for, or is related to, direct marketing purposes; in that case the processing may not be continued for such purpose.

You can also file your complaint with the competent authority. If you choose this option, please contact:

Nemzeti Adatvédelmi és Információszabadság Hatóság (National Data Protection and Freedom of Infromation Authority)

Address: Budapest, Falk Miksa u. 9-11, 1055

Mailing address: 1363 Budapest, Postafiók: 9.

Telephone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

If you believe that the processing of your data is unlawful, you may also file a lawsuit in a civil court. The court will have the authority to adjudicate the lawsuit. You may file the lawsuit in the court that has jurisdiction over your residential address (please follow the link below to see a list of the courts and their contact details: http://birosag.hu/torvenyszekek).

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with your local competent authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.You can find a list of contact details from the country specific terms attached at the bottom of this notice or from the official website of your local competent authority.

The controller will, within one month of the receipt of your request made in accordance with the above, inform you about the actions taken pursuant to the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The controller will inform you about the extension within one month of the receipt of your request, together with the reasons for the delay. If the controller receives the request electronically, the information will also be provided electronically if possible and unless you have requested otherwise. If, in in our judgment, no action is needed pursuant to your request, we will inform you without delay but in no event later than within one month after the receipt of your request about the reasons for not taking any action and about your option of lodging a complaint with the data protection authority and seeking a judicial remedy.

Requests are performed free of charge; however, if a request is manifestly unfounded or excessive, in particular because of its repetitive character, the controller may charge a reasonable fee in view of the administrative costs incurred due to the request or may refuse to act on it.

If there is any doubt about the identity of a person who submits a request, additional information may be requested from them as required for their identification.

In effect from: October 20, 2024

[DanuTech]

COUNTRY SPECIFIC TERMS FOR SPAIN

[For Deepting App User’s in Spain]

Your rights

If we fail to adhere to applicable data protection laws in Spain, you also have a right to file a complaint before the Spanish Data Protection Authority, which is the competent data protection authority in Spain, established under the Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD).

You can also file your complaint with the competent authority. If you choose this option, please contact:

Agencia Españoña de Protección de Datos

Address: Jorge Juan, 6. Madrid (28001)

Telephone: +34 900 293 183

Sede electrónica: https://sedeagpd.gob.es/sede-electronica-web/

Amendments

With respect to the privacy of minors, as per the applicable laws in Spain, a minor is anyone under the age of 14 years.

COUNTRY SPECIFIC TERMS FOR GERMANY

[For Deepting App User’s in Germany]

Your rights

If we fail to adhere to applicable data protection laws in Germany, you also have a right to file a complaint before the German data protection authority. If you choose this option, please contact the relevant local data protection authority: https://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden.html.

Amendments

With respect to the privacy of minors, as per the applicable laws in Germany, a minor is anyone under the age of 16 years.

COUNTRY SPECIFIC TERMS FOR UK

[For Deepting App User’s in UK]

Your rights

If we fail to adhere to applicable data protection laws in UK, you also have a right to file a complaint before the Information Commissioner’s Office which is the competent data protection authority in UK, established under the UK GDPR and UK Data Protection Act.

You can also file your complaint with the competent authority. If you choose this option, please contact:

Information Commissioner’s Office

Address: Wycliffe House,Water Lane, Wilmslow,Cheshire SK9 5AF

Telephone: 0303 123 1113

Website: https://ico.org.uk/

Amendments

The first paragraph of this PRIVACY POLICY is replaced with “In view of Articles 13 and 14 of Regulation (EU) 2016/679 as it forms part of the law of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 as modified by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (as amended) ("UK GDPR"), we would like to inform you as follows about certain matters associated with our data processing operations.”

Relevant references to the “GDPR” in the PRIVACY POLICY are replaced with “UK GDPR”.

With respect to the privacy of minors, as per the applicable laws in UK, a minor is anyone under the age of 13 years.

COUNTRY SPECIFIC TERMS FOR FRANCE

[For Deepting App User’s in France]

Your rights

• In accordance with Articles 48 and 85 of the French Data Protection Act, you also have the right to give directives on the storage, erasure and communication of your data after your death. These rights will be exercised by your successors in title or by the person you wish to specifically designate for the execution of your post-mortem rights.
• Right to lodge a complaint with the CNIL: If you believe that we failed to comply with the requirements of the GDPR with regard to your personal data, you also have the right to lodge a complaint with the French Data Protection Authority, the Commission Nationale Informatique et Libertés (CNIL). If you decide to lodge a complaint with the CNIL, you can contact the authority:

  o Online through this form: https://www.cnil.fr/fr/plaintes

  o By letter addressed to the following address:

  CNIL - Service des Plaintes

  3 Place de Fontenoy - TSA 80715

  75334 PARIS CEDEX 07

• You also have the right to register on the Bloctel opt-out list to opt-out from marketing calls.

Amendments

With respect to the privacy of minors, as per the applicable laws in France, a minor is anyone under the age of 15 years.