Policy on the Processing of Personal Data

This English translation is provided for convenience only. The legally binding version of this document is the Russian original, which prevails in the event of any discrepancy or inconsistency between the two versions.

1.1. The personal data operator is the Limited Liability Company NEXT LEVEL (NEXT LEVEL LLC), INN 9729294203, KPP 772701001, OGRN 1207700059676, address: 15 Krzhizhanovskogo St, bldg 5, Akademichesky Municipal District, Moscow 117218, Russia. This Policy describes the processing of data of visitors to the website https://dialogic-ai.ru/, persons who have submitted a request, and client representatives. Contact for inquiries: info@dialogic-ai.ru.

1.2. This document is publicly available on the website. Reading the Policy does not in itself constitute consent to data processing. This version takes effect on the date of its publication on the website.

1.3. When audio recordings, correspondence, and information from a corporate client’s CRM are processed for the client’s purposes, the operator of such data is usually the client itself, and NEXT LEVEL LLC processes the data on the client’s instruction. Such instruction is contained in the license agreement or in a signed agreement for a trial audit. The client is responsible for the lawfulness of recording and transferring the communications. This Policy also covers the processing that NEXT LEVEL LLC carries out on its own account of the data of its own visitors, counterparties, and platform users.

2.1. Personal data means any information relating to a directly or indirectly identified individual. Processing includes obtaining, recording, storage, use, transfer to specified recipients, depersonalization, blocking, and destruction. The operator determines the purpose and scope of the data; a person acting on the operator’s instruction processes them within the limits of the operator’s directions.

2.2. A visitor is a person who views the website. An applicant is a person who submits a request for a demonstration, an audit, or a commercial proposal. A platform user is an employee or representative of a client who has an account. Demo data means recordings and related information provided by a client for a trial audit before a license is signed.

2.3. Cookies are identifiers that the website and connected services store in the browser. An IP address and cookie identifiers may constitute personal data if they can be used to identify a person directly or indirectly. For details, see the separate Cookie Policy.

3.1. The Operator may process data within the stated purposes and legal bases, entrust processing to third parties subject to the requirements of the law, verify the accuracy of the necessary information, and defend its rights in the event of a dispute. Withdrawal of consent does not cancel processing for which another independent legal basis remains.

3.2. The Operator must restrict access to data, ensure their accuracy and security, respond to requests from data subjects, stop unlawful processing, and destroy data upon the occurrence of the grounds provided for by law; and must provide information to Roskomnadzor and notify it in the cases provided for by law.

3.3. Persons who have obtained access to data on the Operator’s instruction must maintain confidentiality and process the data only within the specified purposes and contractual instructions.

4.1. A data subject has the right to find out whether his or her data are being processed; to obtain available information on the purposes, legal bases, categories, retention periods, and recipients; to demand that inaccurate data be rectified, or that data be blocked or destroyed, where there are legal grounds for doing so; to withdraw consent; and to appeal against the Operator’s actions to Roskomnadzor or a court.

4.2. A request must make it possible to identify the requester and the connection between the request and the data. To avoid disclosing information to an unauthorized person, the Operator may ask for the supporting information provided for by law and does not disclose other people’s data to the requester.

4.3. If a request concerns call recordings and other materials uploaded by a corporate client, the requester should contact that client as the operator. NEXT LEVEL LLC forwards any such request it receives to the client and assists in fulfilling it in accordance with the terms of the instruction.

5.1. Website visitors: IP address, technical information about the device and browser, date and time of page access, cookie identifiers, and on-site events. Optional analytics identifiers are described in the Cookie Policy.

5.2. When a request is submitted, the following are processed: the name; the chosen contact method, namely a phone number or a Telegram, WhatsApp, or Max identifier; information about the organization and job title, if provided; and the comment and subsequent correspondence regarding the request. These data are used to respond, give a demonstration, and prepare a tailored proposal. Please do not include health information, passport details, or other information unrelated to your request in the comment.

5.3. With respect to representatives of existing clients and platform users, the following may be processed: last name, first name, job title, work contact details, and information about the organization and their authority, the account, role, actions in the platform, support requests, and performance of the contract. No plan is paid for on the website when a request is submitted; bank card details are not collected through the request form.

5.4. Recordings and correspondence that a corporate client transfers to Dialogic may contain data of its employees, customers, and other participants in the communications. The client determines the scope of such data and the legal bases for processing them. Dialogic analyzes the content of speech and does not use the voice for biometric identification. Special categories of data may be transferred only where there is an appropriate legal basis and a processing regime agreed upon with the client.

6.1. Data are processed lawfully and to the extent necessary for predetermined purposes. Applicants’ data are not used for advertising mailings unrelated to the request. Incompatible purposes and data sets are not combined without a separate legal basis.

6.2. The Operator takes reasonable measures to keep data up to date and accurate. Access by employees and contractors is limited to the tasks they perform. Storage in a form that allows a person to be identified ceases once the purpose has been achieved, unless the law or a permissible contractual interest requires retention.

6.3. Publication of the personal data of a client, its employees, or call participants to an unlimited number of persons does not follow from the fact that the data were transferred to Dialogic and requires an independent legal basis.

7.1. Processing requests: contacting the applicant, clarifying the task, arranging a demonstration, agreeing on a plan, and preparing a proposal and a contract. The free audit of 100 calls is conducted under a separate signed agreement; the standard request form is not intended for uploading real recordings.

7.2. Performance of the contract: creating a workspace and accounts, setting up integrations, support, technical notifications, settlements, handling of claims, and fulfillment of accounting and tax obligations.

7.3. Operation of the website: ensuring the availability of forms and pages, protection against abuse, fixing errors, and traffic analysis using Yandex Metrica. The set of its identifiers and their lifetimes are described in the Cookie Policy.

7.4. Submitting a request does not mean subscribing to advertising mailings. The Operator sends advertising messages only with separate prior consent where such consent is required by law; you can opt out of such messages by following the instructions contained in them or by contacting the Operator.

8.1. The legal basis is determined for each purpose: the data subject’s consent, where it is requested separately; the need to conclude or perform a contract with the data subject himself or herself in the cases established by law; compliance with a legal obligation; or the exercise of the legitimate interests of the Operator and its counterparties, provided that the individual’s rights are respected. For employees and representatives of legal entities, the basis is assessed with regard to their role; a contract between two organizations does not in itself make an employee a party to that contract.

8.2. To respond to a request initiated by a corporate representative, the work contact details that he or she has provided are used to the extent reasonably necessary for negotiations. Where a particular form relies on consent, consent is obtained separately from the text of the Policy, through a distinct action and with proof of its receipt.

8.3. Data of call participants are received on the client’s instruction; the client ensures the lawfulness of obtaining, recording, and transferring them. An applicant’s separate consent given on the website does not replace the legal basis for processing the data of these participants.

9.1. Both automated systems and non-automated actions of employees are used. The sources are the data subject, his or her organization, website forms, correspondence, systems connected by the client, and technical logs. NEXT LEVEL LLC does not obtain data from sources unrelated to the specified purposes without a legal basis.

9.2. The Operator does not make decisions that produce legal effects for a data subject or otherwise significantly affect his or her rights solely on the basis of automated processing, unless the special requirements of the law for doing so have been met. Dialogic’s analytical recommendations are intended to be reviewed and decided upon by the client.

9.3. Access is granted to authorized persons on a role basis; employees and contractors are informed of confidentiality requirements. Electronic data are transmitted over protected communication channels.

10.1. When collecting personal data of citizens of Russia, the Operator ensures that their recording, systematization, accumulation, storage, updating, and retrieval are carried out using databases located in the Russian Federation, in the cases provided for by law.

10.2. For the operation of the website, the processing of requests, and the performance of contracts, providers of hosting, CRM, email, and communication services, technical contractors, and Yandex Metrica may obtain access to data to the extent necessary. Such transfers are made in accordance with the law and the contractual obligations of the recipients. Data are provided to government authorities upon a lawful demand. Information on website visits processed by Yandex Metrica is also described in the Cookie Policy.

10.3. Request data are stored for the duration of negotiations and for no more than 12 months after the last substantive contact if no contract is concluded and there is no other legal basis for storage. Account data are processed for the duration of access and thereafter within the periods necessary for settlements and the protection of rights. Accounting and tax records are retained for the mandatory periods.

10.4. Upon achievement of the purpose, withdrawal of consent in the absence of another basis, or discovery of unlawful processing, data are blocked, rectified, or destroyed in the manner and within the time limits established by law. Information processed on the client’s instruction is returned or destroyed in accordance with the signed contract and the client’s instructions.

11.1. Depending on the purpose, the following actions are performed: collection, receipt from the client, recording, systematization, accumulation, storage, updating, retrieval, use, transfer in the form of providing access to specified recipients, depersonalization, blocking, deletion, and destruction.

11.2. Public dissemination of data subjects’ data is not part of the standard processes of the website and analytics. Publication of a name, image, voice, quote, or case study containing an individual’s data is considered separately and is permitted where an appropriate legal basis and the relevant permissions exist.

12.1. Transfer of personal data to a foreign recipient is not an independent purpose of their processing. If a particular technology or the performance of a contract requires a cross-border transfer, the Operator, before commencing it, complies with the requirements of Russian law, including those on notifying Roskomnadzor and assessing the conditions of such transfer.

12.2. Database localization and the requirements for cross-border transfer apply concurrently. When such a transfer takes place, a data subject may request information on its recipients and countries using the contact details in Section 14.

13.1. NEXT LEVEL LLC limits the range of persons who have access to data and uses account controls, role separation, secure transmission channels, backups, logging, and incident detection procedures. This description does not disclose configuration details that could weaken security.

13.2. Persons with access to data do not disclose them to third parties without a legal basis. Upon detecting an incident, the Operator takes measures to contain it and notifies Roskomnadzor, data subjects, and clients in the cases and within the time limits established by law and contracts.

13.3. NEXT LEVEL LLC does not use client recordings to train models for the benefit of other clients without a separate legal basis agreed upon by the parties.

14.1. Requests concerning data, their rectification, and withdrawal of consent should be sent to info@dialogic-ai.ru or by post to the Operator’s address given in Section 1. Please include information that makes it possible to identify the requester and the subject of the request. The Operator will respond and take the required actions within the time limits established by law.

14.2. The Operator updates the Policy when the purposes, technologies, recipients, or legal requirements change. The website indicates the date of the current version; previous versions are kept to the extent necessary to confirm the terms that were in effect.

14.3. The current version of the Policy is published at https://dialogic-ai.ru/legal/privacy/. The Policy does not set the price or the terms of the license. See also the Consent to the Processing of Personal Data and the Cookie Policy.