Version of 12 October 2026. Effective from the date of publication.
Previous version: 1 October 2026.
This is an English translation of the Ukrainian original. In the event of any discrepancy, the Ukrainian version prevails.
1. General provisions
1.1. This Privacy Policy (the “Policy”) explains what personal data is collected when you use the WordCraft mobile app (iOS and Android), the website https://surdo.org.ua, the web portals for responsible persons of organisations, the WordCraft widget on organisations’ websites, the staff call pages and related web pages on the surdo.org.ua and word-craft.surdo.org.ua domains (together, the “Service”). It also explains for what purposes and on what legal grounds this data is processed, to whom it is disclosed and what rights the user has.
1.2. The controller of personal data and the operator of the Service is WORDCRAFT LLC, EDRPOU code 43677030, registered address: 22 Kvitneva Street, Odesa, Odesa Oblast, 65017, Ukraine (the “Company”, “we”). Contact for personal data matters: email wordcraft@surdo.org.ua, tel. +380505405411. The Company is officially registered as a provider of the social service of sign language interpreting (Register of Providers and Recipients of Social Services, decision No. 2501521 of 30.07.2025); the Service is built to meet the requirements of the State Standard of the Social Service of Sign Language Interpreting for remote interpreting (Order of the Ministry of Social Policy of Ukraine No. 220 of 06.05.2021).
1.3. The Policy applies to all users of the Service:
— registered users (including employees of partner organisations);
— sign language interpreters;
— responsible persons of organisations;
— employees of organisations who receive staff calls;
— visitors who use guest access or the staff call button without registering.
The Policy also applies to website visitors and to representatives of organisations to whom the Company sends emails about its services (clause 3.14).
1.4. Personal data is processed in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI. For users located in the European Economic Area, the principles of Regulation (EU) 2016/679 (GDPR) are also taken into account.
1.5. By using the Service, you confirm that you have read this Policy. Consent to the processing of personal data is given separately: during registration (by ticking the relevant consents) or, for guest access, by starting to use it. Consent to the recording of a Meeting or a Website Call is given separately and each time (section 4). If you do not agree with the Policy, please do not use the Service.
1.6. We may update the Policy. A new version is published on this page with its date; we additionally notify you of material changes in the app or by email. Continuing to use the Service after a new version takes effect means that you have read it.
1.7. A separate category of data is data about persons whom an organisation invites to a Meeting and enters into the Service itself (clause 3.10). With respect to this data, the organisation is the Controller: it determines the purpose and legal ground of processing and is responsible for the lawfulness of entering the data. The Company’s role with respect to this data depends on who the organisation is:
— if the organisation is a legal entity under private law, the Company acts as a Processor: it processes this data on behalf of and in the interests of the organisation under an agreement concluded in writing (Part 4 of Article 4 of the Law of Ukraine “On Personal Data Protection”);
— if the organisation is a state authority, another state body or a local self-government body, the Company does not act as a Processor. Part 3 of Article 4 of that Law provides that, apart from these bodies themselves, only an enterprise in state or municipal ownership may be the processor of personal data whose controller is a state authority or a local self-government body. In such relations, the Company is a Recipient of this data and processes it solely to the extent necessary to send the invitation and hold the Meeting. The division of responsibilities between the parties is set out in the agreement with such an organisation.
2. Definitions
— Personal data — information or a set of information about an individual who is identified or can be specifically identified.
— Processing — any action or set of actions with personal data: collection, registration, accumulation, storage, adaptation, alteration, renewal, use, dissemination, depersonalisation, destruction.
— Controller — a person who determines the purpose of processing personal data and establishes the composition of such data and the procedures for processing it (Article 2 of the Law of Ukraine “On Personal Data Protection”); under the GDPR, the controller, i.e. the person who determines the purposes and means of processing.
— Processor — a person whom the Controller has entrusted with processing personal data on its behalf (the list is given in section 8).
— Recipient — a person to whom personal data is provided, including a third party (Article 2 of the Law of Ukraine “On Personal Data Protection”). The terms “Controller” and “Processor” in this Policy refer solely to the processing of personal data. They are not related to the concepts of the owner and manager of an information and communication system in the legislation on the protection of information in information and communication systems.
— User — an individual who uses the Service: a registered user, an interpreter, a responsible person, an employee who receives staff calls, or a guest.
— Guest — a person who uses the Service without creating an account: calls an interpreter via guest access, takes part in a Meeting via a personal invitation link, or calls an organisation’s employee with the staff call button.
— Organisation — a legal entity that has concluded an agreement with the Company for the provision of sign language interpreting services to its employees and visitors.
— Responsible person — an employee of an Organisation authorised by it to hold Meetings and/or receive Website Calls and to use the Web Portal.
— Meeting — a pre-scheduled video meeting with the participation of an Organisation’s responsible person, a sign language interpreter and an invited person (guest).
— Website Call — a video call to a sign language interpreter that a person makes via the widget on an organisation’s website, its link or QR code. The organisation’s responsible person joins such a call together with the interpreter, in the Calls Web Portal or in the app. A call made via an organisation’s sign intended solely for contacting an interpreter is not a Website Call.
— Web Portal — the Service’s web pages for responsible persons. There are two of them:
— Meetings Web Portal — for scheduling and holding Meetings and accessing Meeting Recordings;
— Calls Web Portal — for receiving Website Calls, keeping the call log and accessing Call Recordings.
— Recording — a video and audio recording of a Meeting (“Meeting Recording”) or of a Website Call (“Call Recording”) made by means of the Service solely with the consent of all participants.
— Staff Call — a feature that allows a visitor who scans a QR code or NFC tag near the entrance to an organisation’s premises to call an employee of that organisation. There is no video connection.
— Live Card — a notification on the device lock screen showing the status of a staff call or a scheduled interpreting session: on iPhone, a Live Activity; on Android, a pinned notification.
— Two-way encryption — encryption of data on all transmission segments: from the device to the server and from the server to the device. TLS (versions 1.2 and 1.3) is used for service data, and DTLS-SRTP is used for the audio and video stream in accordance with the WebRTC standard.
3. What data we collect
3.1. Registration data. When you register an account, we collect:
— your first name and surname;
— your email address (confirmed with a one-time code);
— your phone number;
— a password. It is stored only in a protected (hashed) form; we have no access to your password in plain text.
3.2. Profile data. If you wish, you can add a profile photo (avatar). It is visible to the other participants of your calls and Meetings and to your colleagues in the organisation. You can change or delete the photo in your profile at any time.
3.3. Organisation data. For employees of organisations, we process:
— membership of an organisation;
— the role in the Service (user, interpreter);
— the attribute of being the organisation’s responsible person, including the “QR Calls” role (receiving Website Calls);
— the attribute of access to the Web Portal;
— for employees who receive staff calls, the locations they are assigned to (clause 3.17).
This data appears after you join an organisation (by scanning the QR code provided by the organisation) and is required to provide services under the agreement with the organisation.
The work contact details of a responsible person (work email, work phone) are entered into the Service at the organisation’s request. With respect to such data, each party is a controller for its own part:
— the organisation, as the employer that determines who its responsible persons are and is responsible for keeping the list up to date and for promptly notifying the Company when an employee’s authority ends;
— the Company, to the extent necessary to provide access to the Web Portal and keep records of Meetings and Website Calls.
3.4. Usage data. We process service information about the use of the Service:
— call metadata: start, answer and end times, participants, call status;
— requests for scheduled interpreting: date, time, comment on the request, participants, statuses;
— Meeting metadata: scheduled time, participants, status, the time each participant joined and left;
— the Website Call log (clause 3.15);
— voluntary call quality ratings: a score of 1–5, the reason for a low score, a comment. A responsible person may rate a Website Call in the same way, but the caller does not receive this rating;
— the notification feed in the app.
3.5. Guest call to an interpreter. During a guest call to an interpreter (without registration), we process:
— the name the guest enters in the app;
— the technical device identifier provided by the operating system (clause 3.6);
— a temporary random guest identifier for the video connection, created for each call;
— the date, time and duration of the call.
The device identifier is needed for three things:
— to track the free daily interpreting quota (25 minutes per day per device);
— for statistics on the use of the organisation’s access points (clause 3.6);
— to automatically cancel a previous unfinished call from the same device.
The guest’s name is shown to the interpreter during the call. In a Website Call, the organisation’s responsible persons also see it (clause 3.15). The name is stored in the service record of the call.
No account is created for the guest, and no email address or phone number is requested. A guest’s participation in a scheduled Meeting is described in clause 3.8.
3.6. Technical data. We receive some data automatically:
— Notification tokens. These are the device’s push tokens (Firebase, Apple, VoIP), used to deliver notifications and incoming calls, and Live Card tokens on iPhone (clause 3.18).
— Device and app information. This is the technical device identifier provided by the operating system (on iOS, the identifier for vendor; on Android, the system identifier), the platform type (iOS or Android), the status of notification channels on the device and the app version. It is needed to deliver notifications, to track the guest quota and to check whether a participant’s app supports the request for consent to recording.
— Server logs. They contain the IP address, the request time, the address of the requested page, information about the browser or app (User-Agent) and technical response codes. The page address may contain tokens of invitation links, QR codes and organisation links. Back-end logs may also record the titles of notifications sent (which may contain the other party’s name) and technical device identifiers. This data is needed for security and diagnostics.
— Connection quality data. The device model, the version of the operating system, app or browser and the network status are received by the video infrastructure (clause 8.1) to ensure call quality. If the app crashes, this data is also received by the crash reporting service (clause 3.20). The device model is not transmitted to the Company’s servers.
When you follow an organisation’s smart link (a link, QR code or NFC tag), a click event is recorded. It is needed for statistics on the use of access points and for quota tracking, and contains:
— the time, the organisation and the event type;
— the platform type (iOS, Android or other);
— an indication of whether the organisation’s agreement is in force;
— the duration of the guest call;
— the technical device identifier, if the app provided it.
These records do not contain your name, phone number or email address.
3.7. Website. On the website https://surdo.org.ua, we process the following data.
Form data. You provide it voluntarily:
— “Contract form”: name, the institution’s official email address, phone, EDRPOU code, the head’s position and full name, IBAN account, the selected plan and promo code;
— “Consultation”: name, email address, phone;
— the “Account deletion” form on the page https://surdo.org.ua/deleteaccount: the account’s email address.
Form data is stored on the website platform (Webflow, clause 8.1). It is passed to the Company to conclude an agreement, provide a consultation or fulfil a deletion request.
Analytics. The website uses Google Analytics 4 (Google). During a visit, the cookies _ga and _ga_<identifier> are set for up to 2 years. Google receives information about the pages viewed, the referral source, the device and browser type and the approximate location determined from the IP address. We use this information only in aggregate form, to understand which pages are useful to visitors. You can block these cookies in your browser settings or with the Google Analytics Opt-out add-on.
Third-party resources. The website loads:
— Google Fonts;
— libraries from content delivery networks (Webflow, Cloudflare cdnjs);
— the YouTube player (Google), only if you click on a video.
These services receive your IP address and browser information, and YouTube may set its own cookies.
Coverage map. The public map on the website shows the addresses and coordinates of places where partner organisations with a valid agreement provide the service, including their registered addresses. An address is shown as stated in the agreement, so it may include an apartment or premises number, for example for individual entrepreneurs. The map does not show the names of organisations.
There are no advertising cookies or advertising trackers on the website.
3.8. Taking part in a Meeting as a guest, without registration. You can take part in a scheduled Meeting without creating an account, using a personal invitation link sent by the organisation. In this case we process:
— the name you enter yourself in the app before joining the Meeting: it is shown to the other Meeting participants and stored on your device so that you do not have to enter it again;
— technical connection data needed to transmit video and audio;
— the fact and time of joining the Meeting and leaving it.
We do not ask a guest to provide a phone number, email address or documents or to create a password. The free daily quota (clause 3.5) does not apply to participation in a scheduled Meeting. The invitation link is personal: anyone who uses it will get into your Meeting. It is valid until the end of the Meeting and for one more hour afterwards, after which it becomes invalid.
3.9. Recording-related data. If consent to recording was requested during a Meeting or a Website Call, we store for each participant:
— their decision (consent or refusal);
— their role;
— the name shown during the conversation (for example, “Guest: Olena”);
— the participant’s technical identifier;
— an indication of late joining;
— the time of the request and the time of the decision.
For Website Calls, we also record that the participant’s app supports the consent request: the app version and the time the app reported this. This information is needed to confirm the lawfulness of the recording at any time and is kept regardless of whether the recording eventually took place. The Recording itself is described in section 4.
For each recording, the Service generates a consent record in PDF format. The consent record contains:
— the organisation’s name;
— the name, work email address and phone number of the responsible person;
— the names, roles and phone numbers of participants who have an account (including the interpreter);
— for a Meeting, the invited person’s phone number, if the organisation entered it;
— the time participants joined and left, and for a Website Call, the start, answer and end times of the call;
— the information listed at the beginning of this clause, the outcome of the recording and its identifier.
After 30 days, the guest’s name in a Website Call consent record is replaced with the word “guest”.
The Meeting consent record is attached to the email with the link to the Meeting Recording sent to the responsible person. The Website Call consent record is generated at the request of the responsible person who handled the call, in the Calls Web Portal, and is not stored in the Service. The consent record serves as confirmation that the recording was lawful.
3.10. Data about invited persons entered by the organisation. When scheduling a Meeting, the organisation’s responsible person may enter into the Service the invited person’s phone number, email address and an internal note, in order to send them an invitation and prepare the Meeting. The organisation is the controller of this data, and the Company’s role is determined by clause 1.7 and depends on who the organisation is. In any case, we process this data only to the extent necessary to send the invitation and hold the Meeting and do not use it for our own purposes. Retention period: clause 9.3. The organisation may at any time ask us to delete the data it entered for a specific Meeting.
The responsible person may also send a Meeting card to an email address they specify. The card contains the participants, the time and links to the Recordings and consent records. We record the recipient’s address in the Web Portal activity log.
3.11. Signing in to the Web Portal and the session. A responsible person signs in to the Web Portal by scanning a QR code on the computer screen with the app. If both Web Portals are available to them, they choose which one to enter.
Only a one-time sign-in session identifier is transmitted via the QR code; the login and password are not transmitted through it. Sign-in is confirmed in the app, where you are already signed in. To protect against spoofing, the sign-in is bound to a random browser identifier that the Web Portal keeps in the browser storage; only its hash is stored in the database.
About the session, we store:
— the type of Web Portal;
— the time of creation and of the last activity;
— the IP address at creation and at the last request;
— information about the browser (User-Agent);
— the reason the session ended.
We record a change of IP address during a session in the security log (the previous and the new address). The session token is not stored in the database; only its hash is stored. This data is needed for security, to detect and investigate unauthorised sign-ins. Each time someone signs in to the Calls Web Portal, a notification is sent to your phone, so that you notice immediately if someone else has signed in.
3.12. Restoring a link after the app is installed. Sometimes you follow an invitation link or an organisation’s link, but the app is not installed yet. In that case we help preserve the context of the click, so that after installation you go straight to where you were heading rather than to an empty start screen:
— on Android devices, the Google Play service passes a technical referral tag to the app. The app requests it after installation until it receives the tag or until you sign in to your account;
— on iOS devices, the landing page writes its own technical tag to the clipboard, and the app checks the text in the clipboard once, on the first launch after installation. If it contains our tag in a known format, the app uses it and clears the clipboard. The app does not store, transmit or use any other content, and in that case it leaves the clipboard unchanged. The app does not access the clipboard again.
The tag contains only the parameters of the link you followed (the organisation identifier and the code of its access point) and contains no information about you.
3.13. Interpreters’ data. For sign language interpreters, we additionally process:
— their work schedule and availability;
— their busy status during calls;
— workload and interpreting quality indicators;
— the information required to formalise their relationship with the Company in accordance with the law.
The interpreter’s name is visible to users and to the organisation’s responsible persons (including in the Website Call log). The interpreter’s phone number is included in the consent record (clause 3.9).
The interpreter, in turn, sees the name, profile photo, organisation and phone number of the registered user they are talking to or whose request they are fulfilling.
3.14. Mailing data. When sending emails about WordCraft services to representatives of organisations, we process:
— their work email address;
— where known, their name, position and the name of the organisation;
— the source from which the address was obtained and the date it was added to the mailing list;
— information about consent to receive emails: when and how it was given.
The mailing service records the delivery of an email, its opening, link clicks, unsubscribes and spam complaints.
3.15. Website Calls and the Calls Web Portal. When a person calls via an organisation’s widget, link or QR code, the organisation’s responsible person joins the call in addition to the interpreter. For this purpose, we process the following data.
About the caller:
— the guest’s name (clause 3.5) or, if a registered user is calling, their name and profile photo;
— an indication that the caller works for this organisation;
— the caller’s technical identifier in the video connection;
— the hashed identifier of the caller’s device.
Call log:
— the time the call arrived;
— which of the responsible persons received and accepted the call, and where (in the Web Portal or in the app);
— which interpreter joined;
— the waiting time and the conversation time;
— the outcome (accepted, missed, cancelled);
— the timeline of events.
About the responsible person in the Calls Web Portal:
— the call reception status: “on duty”, pause, end of duty and its reason;
— regular technical presence signals from the page (about once every 15 seconds). They show whether the browser has been granted permission to use the microphone and to show notifications, whether sound is on, whether the tab is open, the connection status and the identifier of the active call.
These signals are needed so that a call rings where the person can actually answer it. If the page is not online, the call goes to the phone.
Alias in the conversation. In a conversation from a computer, the responsible person takes part under a separate technical profile (an alias). The other parties see their name, profile photo and the name of the organisation. When they finish work, the alias is replaced, and its profile in the video infrastructure is overwritten with the neutral “Responsible person”.
Who sees what:
— The organisation’s responsible persons see all Website Calls of their organisation in the log (it can be filtered to show only their own): the date and time, the caller (“Guest: name” or “User: name”), who answered, the outcome, the waiting and conversation time and the interpreter’s name. The guest’s name is shown in the log for 30 days, after which only “Guest” is shown. The log does not show the caller’s phone number, email address, IP address or device identifier.
— The Company’s administrators see which of the organisations’ responsible persons are on duty and the technical signals described above, for support purposes.
Notifications. With your permission, the browser shows system notifications about incoming calls in the Calls Web Portal. Neither these notifications nor the push notifications sent to the phone about calls and the status of the Web Portal contain the caller’s name.
Browser storage. The Web Portal stores in it only technical settings (including the selected camera, microphone and speaker) and the random browser identifier (clause 3.11).
3.16. Recording of a Website Call. A Website Call that a responsible person handles in the Calls Web Portal may be recorded, only with the consent of all participants and in accordance with the rules of section 4. Consent data: clause 3.9.
3.17. Staff Call. By scanning a QR code or NFC tag near the entrance to an organisation’s premises, a visitor opens the staff call page in the browser and can call an employee. No registration, name, phone number, camera, microphone or geolocation is required for this.
About the visitor, we process:
— the entrance number, the time of the call and its statuses (accepted, cancelled, completed, unanswered);
— the page session identifier (valid for 15 minutes);
— the hashed browser identifier.
The page creates the browser identifier randomly and keeps it in the browser storage. We use its hash to limit the number of calls from one device (no more than 5 per hour). The visitor’s IP address is processed by the server to protect against abuse and is included in the server logs (clause 3.6). The page also keeps in the browser storage the last scanned location (name, address, entrance) and the language and accessibility settings.
About the employees who receive calls, we process:
— their name and profile photo;
— the locations the employee is assigned to, and who assigned them;
— the acceptance of a call, a refusal with its reason (“busy”, “not at the location”, “other”) and the completion;
— the location event log with the names of those who performed the actions.
Colleagues at a location see each other’s names, photos and availability, as well as who accepted a call. An employee sees the email address of the owner of the organisation’s account. If a call remains unanswered for a long time or all employees are unavailable, the owner of the organisation’s account is notified: by a push notification or, if they do not have the app on their phone, by email.
About locations, we process the addresses, the coordinates of the location and its entrances, opening hours, the logo, entrance codes (QR/NFC) and information about who created them.
The staff call page shows the visitor the name of the organisation and the location, the address, the entrance, the logo and the opening hours. Employees’ names are not shown to the visitor.
3.18. Notifications and Live Cards on the lock screen. The app’s push notifications may contain service information. For example:
— the name of the other party;
— the request number and the interpreting time;
— the location address and the entrance number;
— the name of the colleague who accepted a staff call.
During a staff call and before a scheduled interpreting session, the app shows a Live Card on the lock screen:
— for a staff call, the address, the entrance and the name of the employee who accepted the call;
— for a scheduled interpreting session, the name of the other party (the client or the interpreter), the comment on the request and the time.
This information is visible on the lock screen without unlocking the device. The “Accept” and “Decline” buttons on a staff call card work without opening the app. Showing notifications on the lock screen and Live Cards can be turned off in the device settings.
For Live Cards on iPhone, we store the tokens issued by Apple and send card updates directly via the Apple Push Notification service. On Android, the cards are delivered via Firebase Cloud Messaging.
3.19. Geolocation. The app requests access to your precise location only in the staff call section, when an employee setting up a location or an entrance taps “My position” on the map. The coordinates obtained are needed only to show your position on the map. Only the point that you yourself have confirmed as the location or entrance is sent to the server. The app does not track your location continuously or in the background. Maps are loaded from mapping services (clause 8.1), which see the IP address and the map area being viewed.
3.20. Crash reports. If the app crashes or a call cannot be established, the app sends a report to the Firebase Crashlytics service (Google). The report contains:
— the device model and the versions of the operating system and the app;
— a technical description of the error;
— for call failures, up to the last 150 lines of the app’s technical log.
These lines may contain internal user identifiers, the addresses of requests to the server (including the text of an address search) and links to profile photos, and on iPhone, the name of the other party. The reports are used only to fix errors.
3.21. Data on your device. So that you do not have to sign in every time, the app stores on the device:
— access tokens;
— a cache of the profile, the organisation and the history;
— a technical log of recent events (up to 250 lines).
On Android, this data may be included in the device backup in your Google account if backup is turned on.
On iPhone, WordCraft calls appear in the “Recents” list of the system “Phone” app with the name of the other party; this is the standard iOS behaviour for calls. This list is managed by iOS and may be synchronised with iCloud according to your settings.
What we do NOT collect:
— your date of birth;
— contacts from your phone book;
— payment card data. Settlements with organisations are made under an agreement outside the app. Organisations’ details (name, EDRPOU code, IBAN account, full name and position of the head) are processed to conclude and perform the agreement;
— background geolocation.
The app contains no advertising, no advertising identifier and no third-party advertising or marketing analytics trackers. Crash reports are described in clause 3.20, and connection quality data in clause 3.6.
4. Recording of the content of calls, Meetings and Website Calls
4.1. Ordinary calls with an interpreter are not recorded. The video and audio content of calls with an interpreter is NOT recorded and NOT stored by the Company. This applies to instant, scheduled and guest calls, including calls made via “interpreter only” signs. Only a scheduled Meeting or a Website Call accepted by a responsible person in the Calls Web Portal can be recorded by means of the Service, and only with the consent of all participants (clause 4.2).
Media streams are transmitted in real time in encrypted form (two-way encryption within the meaning of section 2) via a specialised video infrastructure. If no recording is being made, they are not stored after the call ends. For the Service, a geographic restriction is set at the level of this infrastructure: the media streams of calls, Meetings and Website Calls are routed exclusively through nodes located within the European Union.
4.2. Meetings and Website Calls may be recorded, only with the consent of all participants.
4.2.1. Recording is never switched on automatically and is not a condition for using the Service. A Meeting or call without recording takes place as usual and in full.
4.2.2. Only the organisation’s responsible person who is holding the Meeting or handling the Website Call in the Calls Web Portal can start a recording. The interpreter, a guest or another caller cannot switch recording on. A Website Call that the responsible person has accepted in the app on their phone cannot be recorded.
4.2.3. After recording is requested, each participant present in the conversation receives a request for consent. In a Website Call, the request arrives in the WordCraft app, and the responsible person who initiates the recording does not receive a separate request.
Recording starts only when everyone present has given consent:
— if at least one participant refuses, recording does not start, and if it was already in progress, it stops; the initiator and the other participants see exactly who refused;
— if the app of any participant in a Website Call does not support the consent request (an outdated version), recording is not possible, and the request is not sent to anyone;
— if there are no other participants yet at the time of the request, there is no one to ask for consent, and recording starts immediately; the Service asks each person who joins later for consent separately (clause 4.2.4).
So that recording can start without delay, the technical recording tool may join the conversation as early as the moment consent is requested. Until all participants have given consent, it records nothing.
4.2.4. A participant who joins after recording has started immediately receives a separate request for consent with a notice that the conversation is being recorded. Until they respond, recording continues; up to 40 seconds are allowed for a response. Recording stops automatically if such a participant:
— refuses;
— does not respond within this time;
— uses an app that does not support the consent request.
The composition of participants in active recordings is continuously checked by the server side of the Service. The fragment recorded before such a stop is kept in the recording file on general terms (clause 4.2.8). Recording of a Website Call also stops if the responsible person leaves the conversation.
4.2.5. Recording is visible. While recording is in progress, participants see a recording indicator on the screen; participants are likewise notified when recording stops. A participant who joins during recording immediately receives a request for consent with a notice that the conversation is being recorded. Covert recording by means of the Service is technically impossible: the Service has no way to start a recording other than through the consent procedure.
4.2.6. Refusing consent does not deprive anyone of the right to take part in a Meeting or a Website Call and does not affect the quality or scope of the service.
4.2.7. What is recorded. The video and audio stream of the conversation is recorded: the image and voice of all participants, including the sign language and the interpreter’s speech. Under each participant’s image, the recording shows their name and role as in the conversation.
4.2.8. Where and for how long recordings are stored. Recordings are stored in encrypted form in Amazon S3 cloud object storage in the European Union (Frankfurt) region. To reduce the file size, a recording is additionally processed by the AWS Elemental MediaConvert service in the same region, and the compressed copy is stored next to the original.
The retention period is 30 days from the moment the recording is ready. After that, the original and the compressed copy are deleted automatically, with no need for a request; deletion is performed by a storage rule, usually within a day after the period expires. The participants’ names shown on the recording are passed to the video infrastructure together with the recording settings.
4.2.9. Who has access. A Meeting Recording is available to the organisation’s responsible person who held the Meeting, via the Meetings Web Portal. A Call Recording is available only to the responsible person who handled the call, via the Calls Web Portal; colleagues in the organisation do not see it.
A link for viewing or downloading is created personally for a specific access and is valid for 60 minutes; the file has no permanent address. 3 days before a recording is deleted, the responsible person receives a reminder on their phone. Passing the link on to third parties is prohibited by the Terms and Conditions of Use.
4.2.10. Your rights regarding the recording are set out in clause 10.5.
4.3. Metadata. Regardless of whether there is a recording, we store the metadata of a call, Meeting or Website Call (clauses 3.4, 3.15): who communicated, when and for how long, and the voluntary quality rating. If no recording was made, the content of the conversation remains exclusively between its participants.
4.4. Captions. The captions feature is available in the app for iOS and Android. Captions (speech-to-text) are switched off by default and are switched on only by you during a call or Meeting; once they are switched off, sound processing stops completely. Only the speech of the other parties that you hear is recognised; your own voice is not processed for captions.
The sound exists only in the device’s RAM in short fragments, is not written to a file, is not transmitted to the Company and is not processed on the Company’s servers. The caption text is not stored anywhere.
— On iPhone, recognition is performed by the built-in iOS feature. Depending on the device model, the iOS version and the availability of an offline language model, recognition is performed either entirely on the device or with the involvement of the Apple speech recognition service. In the latter case, such processing is carried out by Apple on its own terms and outside the Company’s control.
— On Android, recognition is performed entirely on the device using the open Vosk language model. When captions are switched on for the first time, the app downloads this model once (about 133 MB) from its developer’s server (alphacephei.com); no sound is transmitted anywhere in the process.
If you do not want any sound processing for captions, do not switch this feature on. There are no captions in the Web Portal.
4.5. QR codes and NFC tags are read locally on the device.
Some QR codes are built on short links of the Pageloot dynamic QR code service (pglt.me). The app opens such a code in a built-in hidden browser to obtain the final call address. In doing so, Pageloot receives the IP address and the technical details of the request, just as when the code is scanned with a phone camera.
Only the call request, if you initiate it, or the one-time Web Portal sign-in session identifier (clause 3.11) is transmitted to the Company.
5. Sensitive data
5.1. We are aware that the very fact of using a sign language interpreting service may indirectly indicate that the user has a hearing impairment, i.e. information about health, which is a special category of personal data (Article 7 of the Law of Ukraine “On Personal Data Protection”).
5.2. The legal ground for such processing is your separate consent given when registering or when starting to use guest access, as well as the need to provide the social service of sign language interpreting in accordance with the legislation on social services.
5.3. We do not use this information for marketing or profiling and apply enhanced protection measures to it. We do not transfer it to third parties, except:
— to the organisation, to the extent of clauses 3.9, 3.15, 3.17 and 8.3;
— to the technical processors listed in section 8, solely to the extent necessary for the operation of the Service.
5.4. A Recording contains the image and voice of the participants, including sign language, and is therefore also highly sensitive information. The legal ground for making it is the separate, specific and informed consent of each participant present, given immediately before the recording starts or immediately after joining a conversation that is being recorded (clause 4.2). Recordings are not used for marketing, profiling or training automated recognition systems. They are not transferred to anyone except the organisation that held the Meeting or Website Call and the technical processors listed in section 8.
6. Purposes and legal grounds for processing
Below, for each purpose, we state what data we process and on what legal ground.
— Provision of services. Purpose: providing the services of the Service: calls to an interpreter, scheduling, guest access, holding Meetings, Website Calls, staff calls. Legal ground: performance of the agreement with the organisation and provision of the service requested by the user.
— Account. Purpose: creating and maintaining the account, email confirmation, password recovery. Legal ground: the user’s consent and provision of the service.
— Notifications and Live Cards. Purpose: delivering notifications and Live Cards about calls, requests, Meetings, Website Calls, staff calls and service events. Legal ground: provision of the service. Notifications and Live Cards can be turned off in the device settings.
— Website Calls. Purpose: routing a call to a responsible person, keeping the call log and showing it to the organisation’s responsible persons. Legal ground: performance of the agreement with the organisation. Technical presence signals from the Calls Web Portal page are processed on the basis of the legitimate interest of the Company and the organisation: so that calls are not lost.
— Staff Call. Purpose: passing a visitor’s call to the organisation’s employees and passing it to the owner of the organisation’s account if no one has answered. Legal ground: performance of the agreement with the organisation. Limiting the frequency of calls by the hash of the browser identifier is based on the legitimate interest of preventing abuse.
— Security and quotas. Purpose: tracking the free guest quota (25 min/day), preventing abuse, protection against fraud, security and diagnostics, keeping records of Web Portal sessions. Legal ground: the Company’s legitimate interest in the stable and secure operation of the Service.
— Recordings. Purpose: making and storing a Recording and providing it to the organisation that held the Meeting or Website Call. Legal ground: the separate consent of each participant (for users in the EEA, Article 6(1)(a) and Article 9(2)(a) GDPR). Keeping track of the consents given: legitimate interest and the need to confirm the lawfulness of the processing.
— Scheduling Meetings. Purpose: processing data about invited persons entered by the organisation (clause 3.10). Legal ground: performance of the agreement with the organisation (item 3 of Part 1 of Article 11 of the Law). The legal ground for entering such data into the Service is determined by the organisation itself as its controller; for state authorities and local self-government bodies, it is the permission to process data granted by law for the exercise of their powers (item 2 of Part 1 of Article 11 of the Law). The Company’s role with respect to this data is determined by clause 1.7.
— Web Portal. Purpose: QR code sign-in of the responsible person, maintaining the session and notifying about sign-ins. Legal ground: provision of the service and security.
— Interpreters. Purpose: processing the data of sign language interpreters. Legal ground: performance of the contract with the interpreter and fulfilment of an obligation imposed on the Company by law as a provider of a social service (items 3 and 5 of Part 1 of Article 11 of the Law). The Company is the controller of this data.
— Quality and stability. Purpose: monitoring the quality of interpreting (ratings after a call), usage statistics under agreements with organisations, crash reports and connection quality data. Legal ground: legitimate interest and performance of the agreement.
— Accounting and settlements. Purpose: transferring information about users, organisations, calls and requests to the Company’s internal accounting system (clause 8.1). Legal ground: performance of agreements with organisations and the legitimate interest in keeping accounts and making settlements.
— Website. Purpose: processing requests submitted through the forms. Legal ground: taking steps at your request before concluding an agreement and fulfilling the request. Visit analytics are carried out on the basis of the legitimate interest in improving the website. The coverage map (clause 3.7) shows where the service is available, on the basis of the legitimate interest of the Company and its partner organisations in letting people know where they can go.
— Mailings. Purpose: sending representatives of organisations information about WordCraft services, including commercial offers, and keeping track of unsubscribes. Legal ground: the person’s consent (item 1 of Part 1 of Article 11 of the Law), which can be withdrawn at any time (clause 10.7).
— Legislation. Purpose: complying with the requirements of the legislation of Ukraine (in particular on social services and accounting). Legal ground: a legal obligation.
7. App permissions
7.1. The app requests only the system permissions that are necessary for specific features:
— Camera: a video call with an interpreter, taking part in a Meeting or a Website Call, scanning QR codes, taking a picture for a profile photo or a location logo. Video interpreting is impossible without the camera.
— Microphone: transmitting your voice to the other party during a call or Meeting.
— NFC: reading an organisation’s NFC tag (only while the scanning screen is open).
— Notifications: incoming calls, reminders about scheduled interpreting sessions and Meetings, staff calls, service messages.
— Bluetooth (Android): connecting wireless headsets during a call.
— Photos/gallery: choosing an image for a profile photo or a location logo. On modern versions of Android, the system photo picker is used, without access to the whole gallery.
— Speech recognition (iOS): solely for captions (clause 4.4). Without this permission, the rest of the Service works in full.
— Location: only the “My position” button on the map when setting up a location or an entrance for staff calls (clause 3.19).
— Live Cards (iOS): showing Live Cards on the lock screen (clause 3.18).
— Full-screen notifications and running a call in the background (Android): showing an incoming call full screen and continuing a call when the app is minimised.
When exactly the app requests permissions:
— notifications: when the app is launched;
— camera, microphone and Bluetooth: right after the first sign-in, so that the system permission dialog does not interrupt an incoming call in the middle of a conversation;
— speech recognition and location: only when you first switch on captions or tap “My position”;
— the rest: when the relevant feature is used for the first time.
7.2. Each permission can be withdrawn in the operating system settings; this will limit only the relevant feature, not the Service as a whole.
7.3. Version 2.1.0 added two system permissions: access to location (clause 3.19) and Live Cards on iPhone (clause 3.18). Version 2.1.1 did not add any new permissions.
The app does not read the clipboard during normal operation. The only exception is the one-time check for its own technical tag on the first launch after installation (clause 3.12). The app writes text to the clipboard only when you do so, for example when you copy the text of an invitation.
7.4. What the app does not do.
— The app does not capture images of your device’s screen and has no such feature. The system permission that would technically make screen capture possible on Android has been deliberately excluded from the app’s permissions.
— The camera is used only during a video call, Meeting or Website Call, for scanning QR codes and for taking a picture when you choose to. There is no automatic or background photography.
— Access to the gallery is used solely for the profile photo and the location logo, when you choose to.
— The app has no features for recording audio or video to a file. Recording of Meetings and Website Calls (section 4) is done on the server, not on the device.
8. Who we share data with (exhaustive list)
8.1. We engage a limited number of technical contractors (processors) that process data on our behalf and in accordance with our instructions:
— Amazon Web Services EMEA SARL: cloud hosting of the server side and the database (Frankfurt region, European Union); S3 object storage for Meeting Recordings and Call Recordings (Frankfurt region); the AWS Elemental MediaConvert service for compressing Recordings (the same region).
— Akenes SA (Exoscale), Switzerland: object file storage in the Sofia zone (Bulgaria, European Union) for profile photos and location logos. Listing of the files in the storage is disabled; each file is accessible via a direct link with an unpredictable identifier.
— Stream.io, Inc. (GetStream), USA: a specialised infrastructure for real-time video calls and the channel for delivering incoming calls. It processes:
— participants’ user identifiers, names, profile photos and organisation names, including the alias profile of a responsible person in the Calls Web Portal (clause 3.15);
— push tokens for incoming calls;
— connection quality data (clause 3.6);
— real-time media streams.
Media is not stored, except in the case of recording: if the participants have given consent, Stream.io generates the recording file and transfers it directly to our S3 storage in the European Union, and receives the participants’ names for display on the recording together with the recording settings. Media stream routing is limited to nodes within the European Union (clause 4.1). The provider is an active participant in the EU-U.S. Data Privacy Framework. Data is transferred to the USA on the basis of participation in this framework and the contractual safeguards provided for by the Data Processing Addendum.
— Google LLC (Firebase Cloud Messaging) and Apple Inc. (Apple Push Notification service): delivery of push notifications and Live Cards to Android and iOS devices. They process the device push token and the text of the notification, which may contain the information described in clause 3.18.
— Google LLC (Firebase Crashlytics): app crash reports (clause 3.20).
— Google LLC (Google Play) and Apple Inc. (App Store): distribution of the app. On Android, Google Play additionally passes a technical referral tag to the app (clause 3.12).
— SendPulse LLC (the SendPulse service), Ukraine: sending all of the Company’s emails. It processes the recipient’s email address, the content of the email and the data described in clause 3.14. These are:
— service emails of the Service: confirmation codes, password recovery, Meeting invitations, Meeting cards, links to Recordings and consent records, emails about access to the Web Portals, materials for installing the widget, notifications about unanswered staff calls, the account deletion email;
— mailings about WordCraft services (clause 3.14), with tracking of deliveries, opens, link clicks and unsubscribes.
— Google (the Google Workspace service): the corporate mailbox wordcraft@surdo.org.ua through which we correspond with you, including about exercising your rights.
— Webflow, Inc., USA: hosting of the website surdo.org.ua and storage of requests submitted through the website forms (clause 3.7).
— Google LLC (Google Analytics 4, Google Fonts, YouTube): website visit statistics, fonts for the website, the Web Portal and emails, the video player (clause 3.7).
— Railway Corporation, USA: hosting of the Company’s internal accounting system (records of agreements, invoices and payments). The Service automatically transfers information to it about:
— users: name, email address, phone, profile photo, role, membership of an organisation, the number and term of the agreement;
— organisations: details, including the EDRPOU code, IBAN, the full name and position of the head, the access point code;
— calls and requests: time, participants, duration, status, comments (including a guest’s name), quality ratings.
— Pageloot: a dynamic QR code service. It redirects the short pglt.me links on which some QR codes are built and keeps scan statistics: IP address, device type, time (clause 4.5).
— Mapping services: displaying the map when setting up locations. They receive the IP address and the map area being viewed:
— in the app, VersaTiles (base map) and Overture Maps on Amazon S3 infrastructure (building outlines);
— in the administrator panel, OpenFreeMap, OpenStreetMap and Esri.
— Geocoding services: the OpenStreetMap Foundation (Nominatim), as well as the Visicom and “Nova Poshta” services (Ukraine). They determine coordinates and refine the addresses of organisations’ locations; they receive only the location address.
8.2. The list above covers all processors that the Company engages to process the personal data of the persons to whom this Policy applies (clause 1.3). If we engage a new processor, we will update the Policy before any data is transferred to it.
Some emails of the Service contain images and fonts. The recipient’s email program downloads them from the Company’s file storage and from the Google Fonts service and, in doing so, passes the IP address to them. Sound processing by the Apple speech recognition service (clause 4.4) takes place outside the Service, on Apple’s own terms, and is not a transfer of data by the Company.
8.3. A Recording is provided to the organisation that held the Meeting or Website Call, via the Web Portal of its responsible person. The organisation’s responsible persons also have access to:
— the Website Call log (clause 3.15);
— consent records (clause 3.9);
— information about staff calls (clause 3.17).
The Company is the controller of the copy of a Recording stored in the Service. The legal ground is the separate consent of each participant, given directly to the Company during the conversation. From the moment it receives its copy, the organisation is an independent controller of that copy. Compliance with the requirements of the established protection regime is ensured by the Company until the copy is transferred via the personal link, and by the organisation from the moment it is received (Parts 3 and 4 of Article 14 of the Law of Ukraine “On Personal Data Protection”). This is not the provision of data to a third party within the meaning of clause 8.4.
8.4. Data is provided to state authorities only on a lawful basis, upon a duly executed request or a court decision, within the limits established by the legislation of Ukraine.
8.5. We do NOT sell personal data and do not transfer it to advertising networks, data brokers or “marketing campaign partners”. Recordings are not transferred to anyone beyond clauses 8.1 and 8.3. The mailing service (clause 8.1) processes addresses only to send the Company’s emails and in accordance with the Company’s instructions.
8.6. Cross-border transfers (Article 29 of Law No. 2297-VI) take place only to the processors listed in clause 8.1:
— to the USA: Stream.io, Google, Apple, Webflow and Railway;
— to Switzerland: Akenes SA (Exoscale); in this case, the data is stored in the European Union (Bulgaria).
Other data, including Recordings and the database, is stored in the EU. Mapping services, the Pageloot service and geocoding services receive only the IP address, the map area or the location address, wherever they are located.
The legal grounds for such transfers are:
— your unambiguous consent;
— the performance of a contract for your benefit;
— adequate protection safeguards: the providers’ participation in the EU-U.S. Data Privacy Framework and contractual obligations, including standard contractual clauses (items 1, 2 and 5 of Part 4 of Article 29 of that Law).
Under normal operating conditions of the Service, the media stream of communication sessions is not transferred to the United States of America: its routing is limited to the territory of the European Union (clause 4.1).
9. Retention periods
9.1. The account and profile: until the user deletes the account (section 10) or at the user’s request.
9.2. Metadata of calls, Meetings and requests: for the term of the agreement with the relevant organisation and for up to 3 years after it ends (reporting and dispute resolution). This also includes a guest’s name in the service record of a call, ratings and comments, comments on requests, the notification feed in the app and the information in the Company’s accounting system (clause 8.1).
9.3. Data about invited persons entered by the organisation (clause 3.10) is stored as part of the Meeting record for the period specified in clause 9.2. The Web Portal activity log, which may contain the email address of an invited person or of the recipient of a Meeting card, is deleted after 24 months.
9.4. Guest quota records and smart link click events (clause 3.6): up to 1 year. Depersonalised statistics may be kept longer.
9.5. Server logs: no longer than 90 days. In addition, the size of the logs is limited, so the actual retention period may be shorter.
9.6. One-time confirmation codes are valid for 1 hour; once used or expired, a code is invalid.
9.7. Recordings: 30 days from the moment the recording is ready; after that, they are deleted automatically.
9.8. Data on consent to recording (the decision, role, name shown in the conversation, time): 3 years, for both Meetings and Website Calls; for a Website Call, together with the call log.
9.9. A personal link for viewing or downloading a Recording: 60 minutes from the moment it is created.
9.10. A guest’s invitation link to a Meeting: until the end of the Meeting and 1 hour after it.
9.11. The QR code for signing in to the Web Portal: 2 minutes from the moment it is displayed. Choosing a Web Portal after the sign-in is confirmed: up to 5 minutes.
9.12. A Web Portal session: until the user signs out, the Calls Web Portal page is closed or the session ends automatically after 8 hours of inactivity. The session cookie is valid for no longer than 30 days from the last activity.
9.13. The technical referral tag in the clipboard (iOS): until the first launch of the app, after which the clipboard is cleared.
9.14. Data that must be kept by law: for the periods established by the legislation of Ukraine.
9.15. Mailing data (clause 3.14): until you unsubscribe (withdraw consent) or for 3 years from your last interaction with the Company’s emails (opening, following a link, replying), whichever comes first. After you unsubscribe, the address is kept only in the unsubscribe list, so that no more emails are sent to it.
9.16. Website Calls. The Website Call log (clause 3.15), together with the information about consent to recording, is kept for 3 years. Information about duty periods, Web Portal sessions with IP addresses and the security log: 24 months. Responsible persons see a guest’s name in the log for 30 days.
9.17. Staff Call. The location event log (with employees’ names) and records of calls and refusals (time, entrance, hash of the browser identifier) are kept for 12 months. Information about locations, entrances and codes is kept for the term of the agreement with the organisation.
9.18. Notification and Live Card tokens. The token of an individual Live Card is kept until the card ends, but no longer than 1 day. Push tokens and tokens for starting Live Cards: until you sign out of the account on the device, delete the account or the token is replaced.
9.19. Requests submitted through the website forms (clause 3.7): until an agreement is concluded or for up to 1 year from receipt if no agreement is concluded. Data relating to concluded agreements is kept in accordance with clause 9.14.
9.20. Crash reports (clause 3.20): 90 days. Website analytics data: according to the Google Analytics settings, but no longer than 14 months.
10. Your rights and how to exercise them
10.1. In accordance with Article 8 of the Law of Ukraine “On Personal Data Protection”, you have the right:
— to know about the processing of your data;
— to access it;
— to demand the correction of inaccurate data;
— to demand the deletion or destruction of data;
— to object to processing;
— to withdraw consent at any time (without affecting the lawfulness of processing before the withdrawal);
— to protection against an automated decision that has legal consequences for you.
10.2. Account deletion. You can delete your account in three ways:
— in the app: Profile → “Delete account”, confirmed with your password;
— via the form on the page https://surdo.org.ua/deleteaccount;
— by email to wordcraft@surdo.org.ua.
Deletion in the app takes effect immediately. We erase your name, email address, phone number, profile photo, password and sign-in tokens. Your devices are removed from notification delivery, your membership of organisations and your Web Portal sessions are terminated, and a confirmation email is sent to your email address. We fulfil a request made via the form or by email within 30 days.
After deletion, depersonalised records of calls, requests and Meetings are kept in the Service, without your name and contact details. They are needed for reporting to organisations and for settlements. Information that relates to you but forms part of the records of other persons or organisations is also kept:
— the name shown in the conversation, in the information about consent to recording (clause 9.8);
— Recordings, until their retention period expires (clause 9.7);
— comments on shared requests;
— the staff call event log (clause 9.17);
— Web Portal sessions (clause 9.16);
— data that must be kept by law (clause 9.14).
This information is deleted when the specified periods expire. Accounts of organisation owners and administrators are deleted by the Service administrator on request.
10.3. To exercise any of your rights, write to us at wordcraft@surdo.org.ua from the address specified in your account (to confirm your identity). We respond within 30 calendar days.
10.4. If you believe that your rights have been violated, you have the right to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court.
10.5. Rights regarding a Recording. You have the right not to consent to recording; in that case the conversation takes place as usual, without recording.
A recording is initiated by the organisation’s responsible person, and the organisation independently manages the copy it has received. Therefore, for access to the copy downloaded by the organisation, obtaining a copy of it or deleting it, you should contact the organisation.
The Company processes the copy of the recording stored in the Service as its controller, on the basis of the separate consent given by each participant directly to the Company during the conversation (clause 4.2). This copy is deleted automatically after 30 days, and you can contact us about it at wordcraft@surdo.org.ua. If the organisation does not respond or cannot be contacted, write to us, and we will notify the organisation and help to have your request considered.
10.6. Rights regarding data entered by the organisation. Requests concerning the legal ground for processing, the correction or the deletion of data that an organisation has entered about you (clause 3.10) should be addressed primarily to that organisation as its controller. Upon receiving such a request, we will promptly notify the organisation and assist in fulfilling it. As regards the processing carried out directly by the Company (storing the data in the Service, sending the invitation), we will consider the request ourselves under the procedure of Article 8 of the Law of Ukraine “On Personal Data Protection”, within 30 calendar days (clause 10.3).
10.7. Opting out of mailings. You can opt out of emails about WordCraft services at any time: via the “Unsubscribe” link in each email or by writing to wordcraft@surdo.org.ua. Opting out is free of charge, requires no explanation and takes effect no later than 2 working days later. Opting out of mailings also means withdrawing consent to the processing of your data for mailings (Article 8 of the Law of Ukraine “On Personal Data Protection”).
10.8. Guests’ rights. A guest does not have an account, so their data is not linked to a person in the Service. To exercise your rights regarding the name you gave during a call, a Recording or the information about consent, write to us at wordcraft@surdo.org.ua. Please state the organisation, the date and the approximate time of the call so that we can find the relevant records.
11. Data security
11.1. We apply technical and organisational protection measures:
— encryption of connections between users’ devices and the Service using TLS versions 1.2 and 1.3 (outdated protocol versions are disabled) and encryption of media streams using the DTLS-SRTP standard, which is two-way encryption within the meaning of section 2;
— encryption of data at rest using the AES-256 algorithm for the database and the Recordings storage;
— storage of data in secure data centres in the EU;
— role-based access control for staff on the principle of least privilege;
— hashing of passwords and session tokens;
— round-the-clock infrastructure monitoring.
11.2. Recordings are stored in private object storage in encrypted form. There is no permanent public link to a file: access is granted only via a personal link with a limited validity period (clause 4.2.9), which is issued to the organisation’s authorised person after their rights have been verified.
11.3. In the event of a security incident that poses a risk to your rights, we will notify you and the competent authorities in accordance with the law. If the incident concerns data processed in connection with serving an organisation, we also notify that organisation without delay from the moment the incident is detected, so that it can fulfil its own obligations as the controller of the data concerned.
11.4. By order, the Company has appointed an authorised person who organises the work related to the protection of personal data during its processing (Part 2 of Article 24 of Law No. 2297-VI). Information about this person has been submitted to the Ukrainian Parliament Commissioner for Human Rights. The Company has itself classified the processing of the personal data of the Service’s users as posing a particular risk to the rights and freedoms of data subjects and has submitted the corresponding notification to the Commissioner under the procedure of Article 9 of that Law.
12. Children
12.1. Persons who have reached the age of 16 may use the Service on their own. Younger persons may use the Service with the consent and under the supervision of their parents or legal representatives. The Service is not intended for the targeted collection of children’s data; if we become aware that a child has created an account without the consent of their representatives, we will delete it.
12.2. If a person under the age of 16 is invited to a Meeting, consent to the recording of the Meeting on their behalf is given by their father, mother or legal representative present at the Meeting. The organisation that schedules such a Meeting is responsible for ensuring such presence. If a Website Call has evidently been made by a person under the age of 16, the organisation’s responsible person should not initiate recording without the participation of that person’s legal representative.
13. Users in the European Economic Area
13.1. If you are in the EEA, the processing of your data is based on:
— the performance of a contract (Article 6(1)(b) GDPR);
— your consent (Article 6(1)(a) GDPR; for data that may indicate a health condition, and for Recordings, Article 9(2)(a));
— legitimate interests (Article 6(1)(f) GDPR): security, prevention of abuse, stability of the Service.
You have the rights provided for in Chapter III of the GDPR, including the right to data portability; they are exercised in accordance with section 10.
13.2. With respect to data about invited persons entered by the organisation (clause 3.10), the organisation is the controller. Where, under clause 1.7, the Company acts as a Processor, it acts as a processor within the meaning of Article 4(8) and Article 28 GDPR; in other cases, as a recipient of data within the meaning of Article 4(9) GDPR.
14. Final provisions
14.1. This Policy is an integral part of the Terms and Conditions of Use of the Service. In the event of any discrepancy regarding the processing of personal data, the Policy prevails.
14.2. Questions about the Policy: wordcraft@surdo.org.ua, tel. +380505405411. Postal address: 22 Kvitneva Street, Odesa, Odesa Oblast, 65017, Ukraine.