PRIVACY POLICY

[For Deepting.ai web]

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.

1 The data controller: [DanuTech Europe Korlátolt Felelősségű Társaság] (registered office: [1112 Budapest, Gulyás utca 24/1], registered number: [01-09-415688], tax number: [32277584-2-43], telephone: [+36 30 1227368], e-mail address: [service@danutecheu.com]) (hereinafter: “[DanuTech]” or “data controller).

2 The contact details of our data protection officer: BDO Legal Jókay Ügyvédi Iroda [HU-1124 Budapest, Apor Vilmos tér 11-12., e-mail: adatvedelem@bdolegal.hu, telephone: +3617661906].

3 The data controller will process your personal data for the purposes listed in this statement and to the extent necessary to achieve such purposes. The data controller will process your data in full compliance with the applicable regulations, it will treat all data confidentially and it will not transfer the data to unauthorised persons or entities. Your personal data that are processed under this statement will only be accessible to the data controller's authorised employees who are bound by confidentiality obligations. Employees will only be authorised to access the personal data if they need to perform a task in connection with specific personal data on the basis of their job. The data controller does not make decisions on the basis of automated processing and does not carry out profiling.

4 Information about the cookies used by the website is not provided in this notice, but in our separate notice on the processing of data relating to online interfaces [https://www.deepting.ai/].

5 As a general rule, no personal data for minors under the specific age as defined by applicable laws will be processed, we will not knowingly collect or solicit personal data via our product and service from minors. If you believe a minor has provided personal data to us without parental/legal guardian consent, please contact us.

6 The following key information apply to the data processing:

Data subjects Deepting.ai web users
The purpose of processing For registration purpose to use the Deepting.ai 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.ai web users
The purpose of processing Using the main function of Deepting.ai web service - uploading audio or video files to the website 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 website 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.ai web users
The purpose of processing Using the Deepting.ai web service - editing, inserting images to transcribed files and sharing of the files
Data processed Images, transcription text, 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 edit or insert images to transcribed files.
Data processors VerbaLink Europe Kft. and its server supplier in EU
Data subjects Deepting.ai web users
The purpose of processing Subscribe to Deepting Pro in order to get paid service (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 Stripe
Data subjects Deepting.ai web 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 web 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 next to the processed files (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 Lenovo (Slovakia)
Data subjects Deepting.ai web users
The purpose of processing IT troubleshooting
Data processed IP address, type of browser, uid, audio id, audio file names, duration of audio files, start time of registration, available transcription minutes, redeem records, available transcription minutes, session id, start/exit records, browse and search 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.ai web 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, Google Ads
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/

7 Information on data transfers

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, as well as clicks on Google Ads
Apple in EU 3rd party SDK Deepting used to process Apple ID sign-up and login
Payment Supplier in EU 3rd party SDK Deepting used to process payment and subscription on deepting.ai website.
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

The data processor may transfer your personal data to third countries (i.e. countries that do not qualify as EU Member States). When processor do the data transfer, according to the instructions of the controller, processor is committed to ensuring that the transferring of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Controller has asked processor, and the processor will also ask those recipients to handle it in accordance with GDPR and reasonable safeguards. All such recipients are contractually bound by controller to keep the personal data confidential.

The European Commission published its decision on adequate protection of personal data, when data is transmitted to the country belongs to decision on adequate protection of personal data, the processor will sign a data processing agreement with the recipient to ask the recipient to process the data based on the controller's purpose and take sufficient organizational and technical measures to protect the security of your personal data. Besides, it should be noted that, for the country/region which are not included in the adequacy decision of the European Commission, when the data is transmitted to these places, the processor will ask recipient to sign the data processing agreement and the EU Standard Contractual Clause (SCC) to require the recipient to comply with the GDPR. A copy of the relevant mechanism can be obtained for your review on request by using the contact details included herein.

8 Your rights

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:

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

Right to restriction of processing: At your request, the controller will restrict processing, if:

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.

Right to object: You can object to the processing of your personal data if:

Right to data portability: You can request the controller to provide your data to you in a structured, commonly used and machine-readable format, if this is technically feasible, so that you can transmit such data to another controller, or you can request the controller to perform such transmission directly.

Right to lodge a complaint: If you believe that your rights associated with your personal data have been violated, please inform the controller or the data protection officer about your complaint by using any of the contact details stated above.

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.

9 Review of requests

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: April 25th, 2024

[DanuTech]

COUNTRY SPECIFIC TERMS FOR SPAIN

[For Deepting Web 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 Web 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 Web 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 Web User’s in France]

Your rights

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.