EFFECTIVE DATE: 28 AUGUST 2023

Privacy Policy

VEZI VARIANTA ÎN ROMâNĂ

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation.

VATIS TECH S.R.L., having its headquarters at STR. LUCIAN PRICOP, NR.50, Vădăstrița, Olt, tax code 43155475, registered with the Trade Registry under no. J28/696/2021 ("VATIS TECH S.R.L.", "us") processes, as data controller, your personal data („Personal Data”). The purpose of this privacy policy („Policy”) is to explain how your Personal Data is processed by VATIS TECH S.R.L.

1. CATEGORIES OF PERSONAL DATA, PROCESSING PURPOSES AND LEGAL GROUNDS

SECTION APPLICABLE TO USERS

If you use our platform available at https://vatis.tech (“Platform”) to transcribe video / audio files (“User”), this Section A applies to you. Please also check Section B, where you will find other processing of your Personal Data.

Creating the User account and authentication

Personal Data: first name, last name, e-mail address, username.

PURPOSE OF PROCESSING

LEGAL GROUND

Creating the User account and authentication

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR) 

Editing the User account

Personal Data: first name, last name, e-mail address, username.

PURPOSE OF PROCESSING

LEGAL GROUND

Editing the User account

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR)

Anonymization of audio / video files

Personal Data: first name, last name, e-mail address, username, any other data about the User appearing in the uploaded files.

PURPOSE OF PROCESSING

LEGAL GROUND

Anonymization of audio / video files uploaded by the User, for the purpose of training artificial intelligence algorithms

Data subject's consent (art. 6, para. 1, let. a of GDPR).

Sharing data regarding changes / improvements to transcription results

Personal Data: first name, last name, e-mail address, username, any other data about the User appearing in the shared information.

PURPOSE OF PROCESSING

LEGAL GROUND

Sharing fragments and changes / improvements to these with Vatis Tech, for the purpose of training artificial intelligence algorithms

Data subject's consent (art. 6, para. 1, let. a of GDPR)

Payment

Personal Data: first name, last name, payment amount, IP, e-mail address.

PURPOSE OF PROCESSING

LEGAL GROUND

Making payments for subscriptions or individual / additional transcription hours purchased

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR) 

Invoicing

Personal Data: first name, last name, payment amount, purchased services, address, e-mail address, bank details.

PURPOSE OF PROCESSING

LEGAL GROUND

Issuing the invoices for the purchased services

Compliance with a legal obligation to which the Company is subject (art. 6, para. 1, let. c of GDPR)

Details: fulfilling the tax obligations 

Feedback

Personal Data: first name, last name, e-mail address, username, any other information provided by the User.

PURPOSE OF PROCESSING

LEGAL GROUND

Requesting and analyzing opinions in order to improve the services

Data subject's consent (art. 6, para. 1, let. a of GDPR) 

Dispute resolution

Personal Data: first name, last name, e-mail address, username.

PURPOSE OF PROCESSING

LEGAL GROUND

Defending the legal rights and the legitimate interests and filing any claims before the judicial bodies or any other public authority

Legitimate interest of the Company (art. 6, para. 1, let. f of GDPR)

Details: the legitimate interest of the Company in defending the legal rights or legitimate interests or in filing the claims arising out of or in close connection with the conclusion or performance of the contract or in order to exercise the right of defense in the event of any dispute against the Company

B. SECTION APPLICABLE TO VISITORS AND USERS

This Section B applies to you if you are a visitor to our Platform or you if are a User.

Browsing Data

Computer systems and software procedures used for the operation of the Platform generally acquire some Personal Data (so-called "log files"), the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified persons, but due to its nature, can, through processing and integration with certain data held by third parties, allow the identification of visitors / users.

Such information includes IP addresses, the time of the request, the method used to send the request to the server, the size of the file obtained in reply, data about gender, age, preferences regarding the Platform, as well as other parameters related to the visitor’s / user's operating system. Insofar such information leads to the identification of a user, the provisions of this Policy become applicable.

PURPOSE OF PROCESSING

LEGAL GROUND

We use this data for the sole purpose of obtaining anonymous statistical information concerning the use of the Platform and to check its correct operation

Our legitimate interest in the improvement of our Platform and in managing the server capacities, and in the bug-free preservation of our Platform (art. 6 para. 1, let. f GDPR);

Compliance with our legal duties concerning the security aspects of our systems, including without limitation those resulting from the Vatis Tech obligation to take appropriate technical and organizational measures for the processing of Personal Data (art. 6 para. 1, let. c GDPR)

Communication with the visitor / User

Personal Data: first name, last name, e-mail address, username.

PURPOSE OF PROCESSING

LEGAL GROUND

Communication with the visitor / User in relation to their requests / claims

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR) 

Marketing (Newsletter, promotions, offers, marketing communications)

Personal Data: first name, last name, e-mail address, username.

PURPOSE OF PROCESSING

LEGAL GROUND

Sending marketing messages in order to advertise the Company's services 

Data subject's consent (art. 6, para. 1, let. a of GDPR) 

2. PROVIDING YOUR PERSONAL DATA

You may refuse to provide certain Personal Data but in such a case you may not be able to benefit from certain services specific to the relationship described in this Policy.

3. ABOUT LEGAL GROUNDS

The legal ground for processing the personal data differs depending on the specific situation and the Personal Data processed.

When we process your Personal Data based on your consent, we will seek your free, informed, specific and unequivocal consent for the respective processing. By expressing your consent, you will agree that we may collect, use, disclose, process and transfer Personal Data in accordance with this Policy.

4. AUTOMATED INDIVIDUAL DECISION-MAKING

Your Personal Data shall not be processed in order to be subject to decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, pursuant art. 22 para. (1) of GDPR.  

5. PROCESSING DURATION

The duration of processing of Personal Data varies depending on the specific processing operation:

OPERATION

DURATION

Creating the User account and authentication

as long as the account exists

Editing the User account

as long as the account exists

Anonymization of audio / video files

until the data subject withdraws the consent

Payment

until the payment is made

Invoicing

10 years

Feedback

until the feedback is analysed

Dispute resolution

as long as it takes to solve the legal dispute

Browsing Data

26 months

Communication with the visitor / User 

as long as it takes to solve the request

Marketing messages

until the data subject withdraws the consent

In certain circumstances, we may retain your Personal Data for longer periods of time in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a prospect of a litigation.

6. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the necessary extent, to the following categories of recipients: IT services suppliers, e-mail services suppliers, payment services providers, accountants, marketing services suppliers, public authorities.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law. In this respect, we rely on several guarantees, such as the standard contractual clauses issued by the European Commission. You may request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data.

7. SECURITY OF PERSONAL DATA

The security of your Personal Data is important for us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time. 

8. RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA

Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, the source of Personal Data, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) the Personal Data have been unlawfully processed; (iv) you exercise the right to object to the processing. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defence of legal claims or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically, and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, VATIS TECH is entitled to continue processing Personal Data. You also have the right to object to the processing of your Personal Data for marketing purposes.

Withdrawal of consent: Insofar you consented to the processing of your Personal Data, you can at all times withdraw your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: anspdcp@dataprotection.ro

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at the e-mail below.

9. CONTACT

If you have any questions or concerns about this Policy or its implementation, you may contact us at: adrian@vatis.tech.