Privacy Policy

Introduction

Welcome to the Audio Recorder & Transcribe ("Software", "Application", "App", "Voice Recorder") Privacy Notice ("Notice", "Privacy", "Privacy Policy").

Software respects your privacy and is committed to protecting your personal data. This Notice will inform you as to how we look after your personal data when you use our Software and tell you about your privacy rights and how the law protects you.

Important Information and Who We are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Software collects and processes your personal data through your use of this Software, including any data you may provide through this Software when you sign up to our Software.

This Software is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

You will be required to read and accept this Privacy Policy when signing up for your Audio Recorder & Transcribe account or filling out the form on our Software.

If you do not accept and agree with this Privacy Policy, you must stop using our Software immediately.

Controller

UmkaSoftware OU ("Company," "We", "Our", "Us") is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions concerning this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Сontact Details

Full name of legal entity: UmkaSoftware OU

Email address: legal@DeepTown.com

Postal address: Tornimae 3-7, Tallinn, 10145, ESTONIA

Changes to the Privacy Notice and Your Duty to Inform Us of Change

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We reserve the right to and may change this Privacy Notice from time to time. If we make any material changes, we will notify you through the Software, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional personal data from you.

Your continued use of the Software after the effective date of an updated version of this Notice will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Notice explicitly.

Personal Data You Provide to Us and the Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may automatically collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Device Data includes [hardware model information about the operating system and its version, unique device identifiers (e.g., IDFA), and device storage information]

• Location data includes [internet protocol (IP) address, language, time zone setting, and location].

• Usage Data includes [information about how you use our Software and Services, the Software from which you visited us].

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Software feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

• We may process your data if you have given us specific consent to use your personal information for a specific purpose.

If you share with us personal data of a third party, you confirm that such a third party gave you consent to the collection and processing of his/her data by us. We in our turn will take the same measures and procedures to ensure the safety of such information as we do in the relation to your personal data.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Device Data (b) Location Data (c) Usage Data	Performance of a contract with you
To manage our relationship with you	(a) Device Data (b) Location Data (c) Usage Data	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our blog/services)
To administer and protect our business and this Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	(a) Device Data (b) Location Data (c) Usage Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Consent
To deliver relevant Software content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Device Data (b) Location Data (c) Usage Data	(a) Necessary for our legitimate interests (to study how customers use our blog/services, to develop them, to grow our business, and to inform our marketing strategy) (b) Consent
To use data analytics to improve our Software	(a) Device Data (b) Location Data (c) Usage Data	(a) Necessary for our legitimate interests (to define types of customers for our services, to keep our Software updated and relevant, to develop our business, and to inform our marketing strategy) (b) Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can control your choices through the following personal data control mechanisms:

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

• External Third Parties: Google, Inc., Facebook, Inc., Apple, Inc., Appfigures, Inc., Amplitude Inc., and others. These parties analyze your data and show relevant information about the Software to people who might be potentially interested in it or remind you about revisiting the Software, if you stopped using it a while ago; or help us to store all Personal Data when you use the Software, to understand how you use the App, engage with particular features and what you like or dislike the most to generate statistical reports.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Opt-out options. You can withdraw your consent or opt-out, whatever applies in your case, from sharing of your Personal Data in accordance with this subsection anytime by using one of the following options:

• By contacting us at legal@DeepTown.com;

• By adjusting your device settings in iOS or Android in order to stop sharing your IDFA or Android Advertising ID

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (for six years after they cease being customers) for tax purposes.

Not collected Identity Data may be deleted by you at any time.

In some circumstances you can ask us to delete your data: see Request the Erasure for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request Access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request Correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request the Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to Processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes or other purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request Restriction of Processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • (a) if you want us to establish the data's accuracy;
  • (b) where our use of the data is unlawful but you do not want us to erase it;
  • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  • (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our voice typing, speech to text, or other Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No Fee is Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We may Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

In this Policy the following terms shall have the following meanings:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Complying with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

California Privacy Rights

This section provides additional details about how we process the personal data of California consumers and the rights available to them under the California Consumer Privacy Act ("CCPA") and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected, including the categories of sources, please see paragraph 2 above. We collect this information for purposes described in paragraph 3 of this Privacy Policy. We may also share your information with certain categories of third parties as indicated above.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any "sales" that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at legal@DeepTown.com. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.