Privacy Policy

1. Key Terms

In this Policy, the terms "personal data", "operator", "personal data processing", "automated processing", "blocking", "destruction", "anonymisation", "data subject" and others are used as defined in Article 3 of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (Russian Federation).

2. General Provisions

This Policy is developed in accordance with Federal Law No. 152-FZ "On Personal Data" and governs the processing and protection of personal data by Zaritovsky Mikhail Sergeevich (the "Operator"), a self-employed taxpayer, TIN 472600002263, in the course of providing speech analytics services (including LantumApp) and operating the website and related interfaces.

This Policy is publicly available. By continuing to use the website and the Operator's services, the user confirms having read this Policy. If you disagree with its terms, you must stop using the website and services.

3. Operator Details

• Full name: Zaritovsky Mikhail Sergeevich
• Status: Self-employed taxpayer (НПД)
• TIN: 472600002263
• Location: Sosnovy Bor, Leningrad Region, Russia
• Email: mikhail.zaritovsky@yandex.ru

Other details (including banking) are provided upon request when entering into a contract.

4. Legal Basis for Processing

Processing is based on the Constitution of the Russian Federation, Federal Law No. 152-FZ "On Personal Data", and other applicable regulations.

The legal basis for processing contact data submitted via forms on the website is the consent of the data subject, expressed by ticking the consent box before submitting the form. Processing in the context of providing services to clients is based on the contract concluded with the client.

5. Purposes of Processing

The Operator processes personal data for the purposes of:

• processing demo and consultation requests and communicating with users regarding submitted enquiries;
• entering into and performing contracts with clients and supporting the LantumApp service;
• analysing website traffic and improving its functionality;
• record-keeping and compliance with legal requirements.

Processing is not carried out for purposes incompatible with those stated.

6. Categories of Personal Data

Data processed may include, in particular:

• name and contact details (phone number, email address, messenger username);
• company name and job title provided by the user;
• technical and anonymised website visit data: cookies, IP address, device and browser type, on-page behaviour.

The Operator does not request and does not deliberately collect special categories of personal data.

7. Principles of Processing

Processing is conducted in accordance with the principles of lawfulness, purpose limitation, data minimisation, accuracy, and storage limitation. Upon achieving the processing purposes, data is subject to destruction or anonymisation, unless otherwise required by law.

8. Processing Operations and Methods

Operations performed include collection, recording, organisation, accumulation, storage, clarification, use, transfer (including entrusting processing to vetted processors where necessary), anonymisation, blocking, deletion and destruction of personal data. Processing is carried out by automated, non-automated and mixed means.

9. Analytics and Cookies

To analyse website traffic and improve its operation, the Operator uses the web-analytics service Yandex.Metrika (operated by Yandex LLC). The service collects anonymised visit data: cookies, IP address, device and browser information, and user behaviour on the website, including session recording (WebVisor). The data is used solely for analytics purposes and does not allow identification of the user as an individual. The Operator does not perform cross-border transfer of personal data.

By continuing to use the website, the user agrees to the use of cookies and Yandex.Metrika. Cookies can be disabled in browser settings; this may affect certain website functions.

10. Retention Periods

Personal data is retained no longer than required for the processing purposes. Contact data obtained through website forms is retained until the processing purposes are achieved or until consent is withdrawn, but no longer than the period established by Russian law. Upon expiry of the retention period or achievement of the processing purposes, data is destroyed or anonymised.

11. Processing within the LantumApp Service

When providing services, LantumApp processes telephone call recordings and other materials transferred by the client to the Operator pursuant to the client's instructions and in the client's interests. In respect of such data, the client acts as the data controller and the Operator acts as the data processor. The composition of data, purposes, periods and conditions of processing, as well as confidentiality and security requirements, are determined by the contract concluded with the specific client. The Operator does not use such data for its own purposes and does not transfer it to third parties, except as provided for in the contract with the client or by law.

12. Security Measures

The Operator applies organisational and technical security measures: access controls, media accounting, secure communication channels, and maintenance of up-to-date information security tools within available resources.

13. Rights of Data Subjects

Data subjects have the right to:

• obtain information about the processing of their personal data;
• request correction, blocking or destruction of data on grounds provided by law;
• withdraw consent to the processing of personal data;
• appeal the Operator's actions to the supervisory authority for the protection of data subjects' rights (Roskomnadzor) or through the courts.

14. Withdrawal of Consent and Enquiries

Withdrawal of consent to personal data processing and any data subject requests should be sent to mikhail.zaritovsky@yandex.ru. Upon receipt of a withdrawal, the Operator will cease processing the data subject's personal data within the period established by Russian law, except where processing must continue by virtue of law.

Opting out of informational and marketing communications is done by sending an email to the same address with the subject line "Unsubscribe" and does not constitute withdrawal of consent to personal data processing.

15. Final Provisions

This Policy is approved by the Operator, published in the public domain and may be amended upon changes in legislation or data processing practices. The current version takes effect from the moment of its publication on the website.