This is a convenience translation; the binding version is the Hebrew original. זהו תרגום נוחות; הנוסח המחייב הוא המקור העברי.
Drafted in accordance with the Protection of Privacy Law, 5741-1981 (as amended by Amendment 13) and the Protection of Privacy (Data Security) Regulations, 5777-2017.
1. Who we are and what this policy covers
This policy describes how AttestVoice ("we") collects and processes personal data of account holders ("customers") and of persons whose voice or details appear in recordings and transcripts. With respect to content uploaded by the customer — the customer is the controller of the database, and we are the holder processing it on the customer's behalf under the data processing agreement.
2. What data is collected
a. Account data: name, email, phone, organisation details and billing details (the payment instrument is stored with the payment processor only).
b. Customer content: audio/video files, transcripts, documents and metadata. This content may include data of special sensitivity (for example medical or financial data, or data subject to a statutory duty of confidentiality). The system labels speakers for transcription purposes only and does not perform biometric identification or verification of identity.
c. Usage data: activity logs and product events without content, and technical data required for security.
3. Purposes of processing
Providing the Service and producing transcripts; security and fraud prevention; billing; compliance with legal duties (including retention of recordings on the Comply track); improving the Service on the basis of aggregated, non-identifying data. We do not sell personal data, do not use it for advertising and do not train models on it.
4. Notice and consent
When data is collected, the details required under section 11 of the Law are provided: identity and contact details, purposes, the existence or absence of a legal duty to provide the data, to whom the data will be transferred, and the rights of access and rectification. With respect to recorded persons who are not the customer — the duty of notice rests with the recording customer; the system provides consent tools and notice wording, but the responsibility for notice rests with the customer.
5. Where data is stored and processed
Permanent storage per the organisation's choice: Israel (AWS il-central-1) or the European Union (Germany). Evidentiary content is kept in immutable storage (WORM). Transcription processing takes place in infrastructure in the European Union only (pinned region), with no retention of content beyond processing time. Transfers outside Israel are made in accordance with the Protection of Privacy (Transfer of Data to Databases Abroad) Regulations, 5761-2001 — to countries meeting regulation 2(8), together with the recipient's written undertaking as required by regulation 3. The full data path is documented in the "Data Path" document available to customers.
6. Who receives access (sub-processors)
Infrastructure and storage providers (Hetzner — Germany; AWS — Israel/Germany), GPU processing (RunPod — pinned EU regions), AI providers for text polishing (Anthropic, Google — segment text only, never audio; an organisation flagged "local only" has no content sent to any external AI provider at all), payment processing (Cardcom in Israel; Paddle abroad) and operational mailing services. The full and current list is in the sub-processor annex of the data processing agreement. Disclosure to authorities — only under a lawful order, and with notice to the customer to the extent the law permits.
7. Data security
The database is managed at the high security level under the Data Security Regulations: encryption in transit and at rest, a dedicated encryption key for every recording, access controls and two-factor authentication (mandatory for administrators), SHA-256 signatures, an immutable audit log, environment separation, backups and restore drills. A serious security incident will be reported to the Privacy Protection Authority in accordance with regulation 11 of the Regulations, and to the affected customers in accordance with the data processing agreement.
Recording announcement on the Comply track: by default every call on the Comply track opens with a recording announcement in the organisation's language and in English, and the announcement, the time it was played and the caller's response are recorded in the audit log as part of the Service's protective measures (Privacy by Default). In countries where the announcement is required by law it cannot be disabled; any deviation from the default is an instruction of the customer, documented in the audit log and under the customer's responsibility.
8. Retention periods and deletion
Account data — as long as the account is active and up to 7 years for legal purposes; customer content — until deleted by the customer or 30 days after the end of the subscription; Comply content — for the period chosen by the customer, followed by documented deletion with a certificate; security logs — 24 months. Deletion mechanism: evidentiary content is locked against changes for chain-of-custody reasons; deletion is performed by destroying the dedicated encryption key, which renders the content permanently unreadable, with a signed destruction certificate. Deletion becomes final after 7 days, and is deferred only where a statutory retention duty or a court order applies — in which case it is performed when they expire.
9. Data subject rights
Every person has the right to access personal data about them (section 13 of the Law) and the right to request rectification or deletion of data that is inaccurate, incomplete, unclear or out of date (section 14). In addition, we contractually undertake to delete content at the customer's request through the mechanism in section 8; customers and data subjects within the scope of the GDPR also have the rights under European law. Requests: privacy@attestvoice.com; response within 30 days. A request concerning content uploaded by a customer will be forwarded to that customer (the controller) and we will assist with the response.
10. Cookies
Essential cookies only (sign-in and security); no advertising cookies; aggregated analytics only.
11. Minors
The Service is not intended for minors and we do not knowingly collect data about them.
12. Updates and contact
A material update will be published 14 days in advance. Privacy protection officer: Moshe Ben-Moshe, privacy@attestvoice.com.