1. General provisions
This Privacy Policy (the "Policy") defines the procedure for processing and protection of personal data of users carried out in connection with the use of the Hintsage website and desktop application (the "Service").
2. Definitions
For the purposes of this Policy, the following terms are used:
- Personal data — any information relating to a directly or indirectly identified individual (data subject), including email address, password, voice data and text obtained as a result of speech recognition.
- Processing of personal data — any action or set of actions performed with personal data, including collection, recording, systematisation, storage, use, transfer, anonymisation, blocking, deletion and destruction.
- Operator — The entity organising and carrying out the processing of personal data (Hintsage Service).
- Anonymisation of personal data — actions as a result of which it is impossible to determine the identity of the data without additional information.
3. Data we process
In the course of the Service's operation, the following types of data are processed:
- User personal data — information provided by the user when registering: email address; password (in encrypted form); the user's IP address; information about certain components of the user's computer (for anti-abuse). These data are not transferred to other services and are used solely for creating and managing the account, providing access to the Service and for support.
- Data obtained during use of the application — information processed when using the Service: voice fragments from the device microphone or speakers; text obtained as a result of speech recognition; technical data such as application settings, user preferences, interaction data with the Service, IP address, browser type, device data and anonymised usage information. These data may be transferred to external services for speech recognition and answer generation. User personal data are not transferred, except where they were spoken by the user during speech recognition. The site also uses analytics (e.g. Yandex.Metrika) to collect anonymised visit statistics.
If the user records voice data of third parties (e.g. during a conversation) for subsequent processing in the Service, they must:
- inform such persons of the recording and use of the Service;
- obtain their consent to the processing of personal data in accordance with this Policy.
The Operator is not responsible for the user's failure to obtain consent from third parties.
4. Principles of processing
- Processing of personal data is carried out on a lawful and fair basis.
- Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with these purposes is not permitted.
- The volume and content of processed data correspond to the stated purposes and are not excessive.
- Accuracy, adequacy and relevance of personal data are ensured. When inaccuracies are identified, the Operator takes measures to correct or delete them.
- Data are stored no longer than required for the processing purposes, unless otherwise provided by law.
5. Purposes of processing
User personal data are used solely for:
- registration and identification of the user;
- providing access to the Service;
- activation of paid features;
- communication by email;
- security and prevention of unauthorised access.
6. Data protection measures
The Operator takes legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying or distribution, including:
- encryption of personal data (e.g. passwords);
- restricting access to data to authorised persons only;
- use of secure servers and data transmission protocols.
7. Use of third-party services
The Service uses external APIs for speech recognition and generation of text answers. Such APIs include artificial intelligence platforms provided by third parties. The list of services used is set out in the Terms of Use.
Voice fragments and text obtained from speech recognition are sent to third-party services. These data may contain personal data of the user or third parties (e.g. interlocutors) if such information was voiced in the audio stream. The user is responsible for the content of voice fragments and must comply with the requirements set out in the "Data we process" section, including obtaining consent from third parties.
Data transferred to third-party services are processed in accordance with their privacy policies and terms.
The Service does not store the transferred data.
8. Disclosure to third parties
Personal data are not disclosed to third parties except:
- where required by applicable law;
- transfer to third-party services for the Service's functions, as set out in the "Use of third-party services" section.
Transfer to third-party services is carried out in accordance with their privacy policies and with observance of data protection measures.
9. Payment processing
Payment is made through third-party payment systems. The Service does not process or store bank card data.
10. User rights and obligations
10.1. The user has the right to:
- receive information about what personal data are processed by the Service, in the manner prescribed by law;
- request clarification, blocking or deletion of their personal data if they are incomplete, outdated, inaccurate or not required for the processing purposes;
- withdraw consent to processing by sending a request to mail@hintsage.com.
10.2. The user must:
- provide accurate personal data;
- inform the Operator of any changes to their personal data.
11. Deletion and withdrawal of consent
The user may request deletion of their account or withdrawal of consent to processing by sending a request to mail@hintsage.com with the subject "Account deletion" or "Withdrawal of consent to processing of personal data". Processing ceases within the time limits established by law, unless otherwise provided.
To update personal data (e.g. email), the user may do so in the account settings or send a request to mail@hintsage.com with the subject "Update of personal data".
12. Retention period
Personal data are retained for as long as necessary to achieve the purposes set out in this Policy, or until deletion at the user's request, unless otherwise required by law.
13. Confidentiality
The Operator and other persons who have access to personal data must not disclose them to third parties or distribute them without the user's consent, unless otherwise provided by law.
14. Minors
The Service is not intended for persons under 18.
15. Updates
This Policy may be changed without prior notice. The current version is always available at https://hintsage.com/privacy.
16. Contact
For any questions regarding the processing of personal data, the user may contact the Operator at mail@hintsage.com.