Consent to Personal Data Processing

I, a User of the Whisper Summary AI Bot service in the Telegram messenger (@WhisperSummaryAI_bot) (hereinafter referred to as the "Service", "Bot"), acting freely, of my own will and in my own interest, give Individual Entrepreneur Lyashch Maxim Mikhailovich (INN 770302130747, OGRNIP 324508100365725, address: 143082, Russia, Moscow Region, Odintsovo, Odintsovo, Zhukovka village, ter. Zhukovka-21, bldg. 1B; hereinafter referred to as the "Operator") consent to the processing of my personal data under the terms of this document.

1. Terms

1.1. The terms "Service", "Bot", "User", "Content", "Result", "User Agreement" are used in the meanings established by the User Agreement posted in the Bot interface.

1.2. UUID — a technical identifier of a request/session used by the Operator to exclude the transfer to external providers of direct identifiers of my Telegram profile (Telegram ID, username/nickname, profile name).

2. Form of Consent and Confirmation

2.1. Consent is provided in electronic form by performing conclusive actions in the Bot, including pressing "Start/Begin" and/or using Bot functions after displaying links to the User Agreement, Personal Data Processing Policy, and this Consent.

2.2. Confirmation of consent provision is the Operator's log records (including date/time, Telegram ID, document version).

3. List of Personal Data

3.1. The Operator processes:

1. Telegram ID, username/nickname, profile name (if available through Telegram API);
2. Content that I transmit to the Bot;
3. Processing results (transcript/summary and other text results);
4. Technical data and event logs (request times, message/session identifiers, security events, errors, and performance metrics).

3.2. Content/Result may contain personal data of third parties if I myself transmit such information to the Bot.

4. Processing Purposes

4.1. Processing is carried out for:

1. performance of the User Agreement and provision of Service functionality (Content processing and Result provision);
2. User support and handling of inquiries;
3. ensuring security, preventing abuse and violations;
4. improving the quality of the Service (including improving the accuracy and stability of transcription and speech recognition algorithms/models) based on aggregated and (if necessary) depersonalized technical metrics and error statistics (for example: frequency and types of recognition errors, quality indicators, processing delays, failures, performance telemetry), without transferring User Content for training/fine-tuning third-party AI models and without using User Content for training/fine-tuning third-party AI models.

5. Processing Operations

5.1. I give consent to: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction; processing may be automated and/or non-automated.

6. Entrusting Processing to Third Parties

6.1. The Operator has the right to entrust processing to contractors (including AI/ML and infrastructure providers) exclusively for the purposes specified in the Consent, subject to confidentiality and security.

7. Cross-Border Transfer

7.1. I give explicit consent to the cross-border transfer of my personal data (including Content and/or Result and technical request data) to providers outside the Russian Federation, including the USA, for the performance of the User Agreement and provision of Service functionality.

7.2. Providers (USA):

1. OpenAI, Inc.;
2. Anthropic, PBC;
3. Fireworks.ai, Inc.;
4. Groq, Inc.;
5. Deepgram, Inc.

7.3. I am aware that the USA is not included in the list of states with adequate protection; I accept the risks of such transfer and confirm the provision of explicit consent.

7.4. During transfer, the Operator uses UUID and does not transfer direct identifiers of my Telegram profile to providers; the correspondence between UUID and my account record is stored in the Operator's infrastructure.

8. Restrictions (Special Categories/Biometrics)

8.1. I am informed that the Service is not intended for biometric identification. I undertake not to transmit to the Bot special categories of personal data and biometric personal data, as well as other prohibited information. In case of violation, I bear responsibility and undertake to compensate the Operator for losses/expenses on claims of third parties.

9. Term and Withdrawal

9.1. Consent is valid until withdrawal.

9.2. Withdrawal is carried out by sending an application to info@whispersummary.com indicating Telegram ID/username and the essence of the request.

9.3. Withdrawal may make the use of the Service impossible. The Operator ceases processing and/or destroys data within the time limits established by law, if there are no other legal grounds for storage.

10. Operator Details

Individual Entrepreneur Lyashch Maxim Mikhailovich

INN 770302130747

OGRNIP 324508100365725

Address: 143082, RUSSIA, MOSCOW REGION, ODINTSOVO, ODINTSOVO, ZHUKOVKA VILLAGE, TER ZHUKOVKA-21, BLDG 1B

Email for inquiries: info@whispersummary.com