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Privacy Notice

This Privacy Policy explains how Deepsight B.V., trading as VOYC ("VOYC", "we", "us" or "our"), processes personal data when you visit our website, contact us, use our services, or otherwise interact with us. We process personal data only where we have an applicable legal basis. Where consent is required, we will request it separately. You are not required to consent to all processing merely to browse this website.

1. Introduction

1.1  VOYC provides a software-as-a-service platform that helps organisations analyse call-centre voice data and related interaction data. This Privacy Policy applies to personal data we process as controller in connection with our website, marketing, sales, account administration and business relationships. Where we process personal data contained in customer call recordings, transcripts, metadata or other customer content in providing the platform, we generally act as processor or operator on the relevant customer’s documented instructions. The customer is responsible for providing the applicable notices and obtaining any required permissions or other lawful basis.

1.2  VOYC respects the rights of Users whose personal data is collected and used by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal data.

1.3  The purpose of this Privacy Policy is to provide Users with information about the information processing activities of VOYC and the way their rights are protected.

1.4  This Privacy Policy shall serve as a blanket notification to Users about VOYC’s processing activities which will remain valid for as long as one has an active account with or is using the services of VOYC, including the browsing of this website. Users will not be notified separately on each occasion that VOYC processes the same personal data in the same way over the period.

1.5   VOYC may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.

1.6  This Privacy Policy is intended to address applicable privacy requirements, including the EU General Data Protection Regulation and the UK General Data Protection Regulation where applicable, the Protection of Personal data Act, 2013 of South Africa, and applicable United States privacy laws. It does not limit any mandatory rights available to individuals under applicable law.

1.7  The provisions of this Privacy Policy is, as far as possible, be incorporated into any agreement between VOYC and Users.

2. Definitions and interpretation

2.1  In this Privacy Policy, the following words bear the following meanings:

2.1.1  "consent" means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

2.1.2  "controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

2.1.3  "data subject" means an identified or identifiable natural person to whom personal data relates;

2.1.4  "direct marketing" means the processing of personal data for the purpose of sending communications that promote or offer VOYC's goods or services to a data subject;

2.1.5  "Data Protection Officer" means VOYC’s data protection officer, if one has been appointed, whose name and contact details are set out in 3.2 below;

2.1.6  "processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

2.1.7  "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier;

2.1.8  ‘’POPIA’’ means the Protection of Personal data Act of 2013, including any regulations or codes of conduct promulgated under it;

2.1.9  "applicable privacy law" means the data-protection and privacy laws applicable to the relevant processing, including, where applicable, the GDPR, UK GDPR, POPIA and applicable United States state privacy laws;

2.1.10  "processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, including:

2.1.10.1  collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation or use;

2.1.10.2  disclosure by transmission, dissemination or otherwise making available; or

2.1.10.3  alignment or combination, restriction, erasure or destruction;

2.1.11  “special categories of personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation;

2.1.12  “services” means the services provided to any User by VOYC;

2.1.13  ‘’the website’’ means the website or any part thereof which is accessible from www.voyc.ai.

2.2  Any reference in this Privacy Policy to:

2.2.1  the singular includes the plural and vice versa;

2.2.2  any one gender includes the other genders, as the case may be;

2.2.3  an act, regulation or other law is to the version of that law in force at the effective date of this Policy and includes any amendment or re-enactment made to that law after the effective date of this Policy.

2.3  When calculating any number 1of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.

2.4  The word "include" means "include without limitation". Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.

3. Controller and processor

3.1 For the processing described in this Privacy Policy, Deepsight B.V. is the controller of personal data under the GDPR and UK GDPR and the responsible party under POPIA, where applicable. For customer content processed through the services, the relevant customer is the controller or responsible party and acts act as its processor or operator. 

3.2 VOYC’s contact details are as follows:

Deepsight B.V,

WeWork c/o Deepsight BV,

Strawinskylaan 4117 4th Floor,

Amsterdam 1077 ZX,

Netherlands;

email: infosec@voyc.ai;

website: www.voyc.ai.

You may use this email address to submit questions, complaints and privacy-rights requests. Lethabo Motsoaledi is the DPO. 

3.3 VOYC may instruct third party processors from time to time to undertake certain processing activities relating to the User’s personal data.

4. What personal data is collected

4.1   Depending on how you interact with us, we may collect the following categories of personal data:

4.1.1  identity and contact data, such as name, business email address, telephone number, job title, employer and correspondence;

4.1.2  account, authentication and service-administration data, such as account credentials, user identifiers, permissions, support requests and service communications;

4.1.3  Email address;

4.1.4  website and device data, such as IP address, device and browser information, approximate location derived from IP address, cookie identifiers, pages viewed and usage information;

4.1.5  commercial and transaction data, such as billing contact details, subscription information, invoices and payment-related information; and

4.1.6  Where VOYC acts as processor or operator for a customer, customer content includes call recordings, voice data, transcripts, call metadata, speaker or agent identifiers, quality-assurance information and analytics outputs (“Customer Content”). The categories of Customer Content depend on the customer’s configuration and use of the services.

4.2  Providing personal data is generally voluntary. However, if you do not provide information needed to respond to an enquiry, create or administer an account, enter into or perform a contract, process payment, or comply with a legal obligation, we may be unable to provide the relevant service or complete the requested transaction.

4.3  We may collect or verify limited personal data from publicly available sources, service providers or business partners where permitted by applicable privacy law and necessary for security, fraud prevention, legal compliance, account administration or the establishment, exercise or defence of legal claims.

5. Purpose/s for collection and processing of personal data

5.1   VOYC shall only collect and process a User’s personal data for a specific, explicitly defined and lawful purpose relating to a function or activity of VOYC‘s business and where the applicable lawful basis under applicable privacy law applies, as identified below.

5.2  Such purposes may include the following:

5.2.1  to provide, operate, secure, support and improve the website and services, where necessary for the performance of a contract with a User or for VOYC's legitimate interests in operating, securing, supporting and improving the website and services, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms;

5.2.2  to respond to enquiries, arrange demonstrations, manage customer and prospective-customer relationships, and communicate about our services, where necessary for VOYC's legitimate interests in managing those relationships, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms, or on the basis of consent where consent is required;

5.2.3  to create and administer accounts, subscriptions, contracts, invoices and payments, where necessary for the performance of a contract with a User or to take steps at the User's request before entering into a contract;

5.2.4  to analyse customer-provided voice and interaction data and generate transcripts, insights, quality-assurance outputs and other service outputs, solely on the relevant customer’s documented instructions and as necessary to provide the services, where VOYC acts as processor or operator, as applicable;

5.2.5  to maintain, troubleshoot, protect and improve the security, reliability and performance of our services, where necessary for VOYC's legitimate interests in maintaining secure and reliable services, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms;

5.2.6  to comply with applicable legal obligations, where necessary for compliance with a legal obligation to which VOYC is subject, and to establish, exercise or defend legal claims, where necessary for VOYC's legitimate interests in doing so, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms;

5.2.7  to enter into a contract with a User, where processing is necessary to take steps at the User's request before entering into that contract;

5.2.8  to perform any obligations under a contract with a User, where processing is necessary for that purpose;

5.2.9  to comply with a legal obligation, where processing is necessary for that purpose;

5.2.10  to protect a legitimate interest of a User, where processing is necessary for that purpose and the User's interests or fundamental rights and freedoms do not override that legitimate interest (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.11  to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with, where processing is necessary for that purpose and such interests are not overridden by the User's interests or fundamental rights and freedoms (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

5.2.12  to send marketing communications where permitted by applicable law, including based on consent where consent is required, and to honour opt-out requests;

5.2.13  to understand website use and improve website content and user experience, where necessary for VOYC's legitimate interests in improving the website and user experience, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms, and subject to applicable cookie and similar-technology requirements;

5.2.14  to conduct business analytics, reporting and product development using aggregated, de-identified or anonymised information where appropriate and permitted by law, and, where personal data is processed, where necessary for VOYC's legitimate interests in conducting those activities, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms.

5.2.15  to enable the User to voluntarily participate in interactive features, where processing is necessary for the performance of a contract with the User or on the basis of the User's consent, where consent is required;

5.2.16  to notify the User about changes to the website or services, where necessary for the performance of a contract with the User, compliance with a legal obligation to which VOYC is subject, or VOYC's legitimate interests in keeping Users informed, provided that such interests are not overridden by the User's interests or fundamental rights and freedoms.

5.3  If VOYC intends to process a User’s personal data for any other purpose not listed in clause 5.2, it shall identify the applicable lawful applicable privacy law under POPIA and, where it relies on legitimate interests, ensure that those interests are not overridden by the User's interests or fundamental rights and freedoms, and, where consent is the appropriate lawful basis, obtain the User’s consent to do so.

5.4   VOYC will not sell a User’s personal data to any third party.

6. Collection directly form user

6.1   VOYC shall, as far as possible, always collect personal data about a User directly from the User, except where VOYC collects, verifies or obtains from appropriate third-party sources personal data and supporting records necessary to perform legal due diligence, identity verification, screening, recordkeeping or related legal compliance obligations, or in the following circumstances:

6.1.1  Where personal data is collected from a public record, or from another source if the information has already been made public by the User;

6.1.2  where the User has given their written consent to VOYC to collect their information from another source;

6.1.3  where the collection of a User’s personal data from another source will not prejudice any of the User’s legitimate interests;

6.1.4  where the collection of personal data from another source is necessary to maintain VOYC’s legitimate interests or those of any third party it intends sharing the information with;

6.1.5  where the collection of personal data directly from the User would prejudice the purpose for the collection;

6.1.6  where the collection of personal data directly from the User is not reasonably practicable in the circumstances.

6.2  If VOYC collects personal data from a source other than the User, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.

6.3  Personal data may be collected from or supplied by the User in any of the following ways:

6.3.1  during the process of scanning a QR Code or sending a SMS, USSD number or Whatsapp message;

6.3.2  when requesting further services or information from VOYC;

6.3.3  when contacting VOYC to report a problem with the website or the services or for any other reason;

6.3.4  when completing any forms on the website.

6.4  When you visit the website, we and our service providers may automatically collect device, browser, IP address, approximate location, log and usage data. Some of this information may constitute personal data. We use it for website operation, security, analytics and improvement, subject to applicable law and your cookie choices. We do not treat information as anonymous merely because it is aggregated unless it has been appropriately de-identified or anonymised.

7. Cookies

7.1  We use cookies and similar technologies to operate the website, remember preferences, understand website use and, where enabled, measure or personalise marketing. Cookies may collect identifiers, device and browser information, pages viewed, timestamps and preference information.

7.2   VOYC may use Cookies on this website to:

7.2.1  distinguish one User from another on the website;

7.2.2  remember the User’s last session when they return to the website;

7.2.3  estimate the website's audience size and usage patterns;

7.2.4  store information about the User’s preferences, which allows VOYC to customize the website and content according to the Users individual preferences; and

7.2.5  speed up searches on the website.

7.3  Third parties may set cookies or similar technologies through our website where we use their services. We remain responsible for providing the disclosures and choices required by applicable law for technologies deployed through our website. We make available a cookie notice that identifies the cookies and similar technologies actually deployed through the website, including the relevant categories, purposes, providers and retention periods, and explains how to change preferences.

7.4  Where required by law, we will obtain your consent before placing non-essential cookies or similar technologies. You may withdraw or change your choices at any time through our cookie-preference tool. You can also manage cookies through browser settings, although disabling certain cookies may affect website functionality.

8. General conditions for processing personal data

8.1   VOYC shall comply with applicable privacy law when it processes a User’s personal data.

8.2   VOYC shall not act unreasonably when processing a User’s personal data. This means that it will collect and process a User’s personal data in a way that the User can reasonably expect and in a way that is fair.

8.3   VOYC shall always respect the User’s right to privacy. If there is another way in which it can achieve the same goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.

8.4  Similarly, if VOYC needs to process personal data but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.

8.5   VOYC shall ensure that the personal data that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

8.6  If there are any alternative ways to achieve the identified purpose/s without processing personal data, VOYC shall not process that personal data.

8.7   VOYC shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.

8.8   VOYC shall ensure that, regardless of the stated purpose/s for processing personal data, the rights and interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.

8.9  VOYC shall retain the personal data of Users only for as long as necessary to achieve the purpose for which the User’s personal data was collected, unless applicable privacy law requires VOYC to retain the information for a longer period of time, or retention is necessary for contractual administration or the establishment, exercise or defence of legal claims.

8.10  If VOYC no longer needs to process personal data to achieve the purpose originally specified, it will stop using that information.

9. Disclosure and sharing of personal data

9.1   VOYC may, while providing any content or services on this website, or for the purposes of concluding or performing any other services or transaction with a User, share certain personal data with third party processors who perform certain processing activities on behalf of VOYC.

9.2  We may disclose personal data to the following categories of recipients where necessary for the purposes described in this Privacy Policy: hosting, cloud-infrastructure, communications, customer-support, security, analytics, payment, professional-adviser and other service providers; affiliates; business partners; competent authorities; and parties involved in a corporate transaction. We require service providers to process personal data only as permitted by applicable law and our instructions or contractual arrangements.

9.2.1  For customer content processed through the services, we may disclose data to the relevant customer, its authorised users and service providers, and to our subprocessors, only as necessary to provide, secure and support the services or as required by law. Subprocessors can be found at trust.voyc.ai.

9.3   VOYC may also share aggregated information about Users of this website and their usage patterns. VOYC may also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be de-identified and the User’s personal data will not be disclosed.

9.4  We do not sell personal data for money. We do not share personal data for cross-context behavioural advertising except to the extent expressly disclosed in a separate notice and permitted by applicable law. Where applicable United States privacy law gives you a right to opt out of a sale, sharing, targeted advertising or certain profiling, you may exercise that right by contacting us using the details in the section 3.2.

10. User's rights in relation to the processing of their personal data

10.1  Subject to applicable law and any relevant exemptions, individuals may have rights to request access to, correction of, deletion of, restriction of, or objection to processing of their personal data; data portability; withdrawal of consent; and information about certain automated decision-making. Individuals may also have rights under applicable United States privacy laws to know, access, correct, delete, opt out of certain processing, and not be discriminated against for exercising privacy rights. Where a request relates to Customer Content processed by VOYC on behalf of a customer, VOYC will handle the request in accordance with its applicable processor or operator obligations and that customer's documented instructions, and the customer will be responsible for responding to the request as controller or responsible party, where applicable.

10.1.1  where applicable privacy law provides, to access and correct any personal information held by VOYC about them;

10.1.2  where applicable privacy law provides, to object to the processing of their information; and

10.1.3  where applicable privacy law provides, to lodge a complaint with the Information Regulator.

10.2  To exercise privacy rights, contact us using the details in the Contact section and provide enough information for us to verify your identity and understand your request. You may use an authorised agent where permitted by law, subject to verification of the agent’s authority. Where a request relates to Customer Content processed by VOYC on behalf of a customer, VOYC will handle the request in accordance with its applicable processor or operator obligations and that customer's documented instructions, and the customer will be responsible for responding to the request as controller or responsible party, where applicable. Otherwise, we will respond within the period required by applicable law. Where required by applicable United States privacy law, if we deny your privacy-rights request, you may appeal our decision by contacting us using the details in the Contact section. If you are in the EEA, you may lodge a complaint with your local supervisory authority; if you are in the UK, with the Information Commissioner’s Office; and if you are in South Africa, with the Information Regulator.

11. Further processing

11.1  Subject to applicable privacy law, VOYC shall not process a User’s personal data for any purpose not previously specified except in the following circumstances:

11.1.1  where the User has consented to such further processing;

11.1.2  where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between VOYC and the User;

11.1.3  where the further processing activities are linked to or compatible with the original purpose;

11.1.4  where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;

11.1.5  where the further processing is necessary to enforce any law;

11.1.6  where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;

11.1.7  where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the User or another individual;

11.1.8  where the further processing is necessary for historical, statistical or research purposes.

11.2  Where required by applicable privacy law, VOYC shall ensure that if it intends processing personal data for other purposes not previously specified, it shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

12. Accuracy, correctness and completeness of personal data

12.1  Where required by applicable privacy law, VOYC shall take reasonably practicable steps to ensure that the personal data kept by it about Users is complete, accurate, not misleading and is updated when necessary.

12.2  However, if a User is aware of any personal data in VOYC’s custody that is incorrect, inaccurate or which needs to be updated, the User may make a written request to VOYC’s Data Protection Officer at the details provided in 3.2 to update or correct the relevant information, where applicable privacy law provides.

12.3  Where required by applicable privacy law, if a User has contested the accuracy of any personal data being used by VOYC, it shall immediately stop using that information until its accuracy has been verified.

12.4  Subject to applicable privacy law, VOYC reserves its right to only adhere to a request from a User in terms of clause 12.2 if the correction or updating of that information will result in the personal data being correct and accurate.

12.5  Where required by applicable privacy law, personal data that has been shared by VOYC with a third party is subsequently updated or corrected, VOYC shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

13. Security safeguards

13.1   VOYC is committed to protecting the personal data in its custody against any loss of, damage to or unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.

13.2   VOYC takes steps to continually identify and document any risks to the personal data it has in its possession or under its control and that appropriate security safeguards are in place against those risks.

13.3  Where required by applicable privacy law, VOYC shall ensure that any contracts entered with third party processors who process personal data on VOYC’ behalf include the following obligations:

13.3.1  the operator shall not process any personal data without VOYC’s knowledge and authority;

13.3.2  the operator shall treat all personal data given to it as confidential and shall not disclose it to any unauthorised third parties;

13.3.3  the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal data as that employed by VOYC;

13.3.4  the operator shall notify VOYC immediately where there are reasonable grounds to believe that any personal data has been leaked to or accessed by any unauthorised person;

13.3.5  if the operator is situated in another country, it must comply with the applicable privacy law in that country and be able to provide verification that it is so compliant;

13.3.6  if an operator is legally obliged to disclose any personal data processed by them on VOYC’ behalf to other parties, it must notify VOYC beforehand to enable VOYC and/or individual Users to protect their rights if necessary.

13.4  VOYC shall ensure that all personal data on its systems is properly backed up and that back-up copies are stored separately from the live files.

14. Notification of breach of security

14.1  If we become aware of a personal-data breach, we will investigate, take appropriate remedial measures and notify affected individuals, customers and competent supervisory authorities where required by applicable law. Where VOYC acts as a processor or operator for customer content, we will notify the relevant customer without undue delay in accordance with our contractual obligations so that the customer can meet its own notification obligations.

14.2  Where required by applicable privacy law, VOYC shall provide sufficient information to the User to allow him or her to take the necessary protective measures against the potential consequences of the compromise or shall advise Users of the steps to be taken by them and the possible consequences that may ensue from the breach for them.

15. Decisions based on personal information processed

15.1  The services may use automated and AI-enabled techniques to analyse customer-provided voice and interaction data and generate outputs such as transcripts, classifications, summaries, quality-assurance indicators and insights. VOYC does not intend to make decisions producing legal or similarly significant effects about individuals solely through automated processing in connection with website interactions. Customers remain responsible for determining whether and how to use service outputs in employment, customer-service or other decisions and for meeting their own legal obligations.

15.2   If VOYC engages in automated decision-making that is subject to specific notice, explanation, human-intervention or objection requirements under applicable law, we will provide the required information and mechanisms. This does not replace the customer’s obligations where the customer determines the purposes and means of processing customer content.

15.3  Where required by applicable privacy law, VOYC shall ensure that the underlying logic behind any decision made pursuant to the automated processing of personal data is sound and that this underlying logic can be communicated to the User to enable them to make representations.

15.4  Where required by applicable privacy law, if VOYC has made a decisions based on incorrect personal data, it shall immediately revisit that decision as soon as it receive Policy or becomes aware of the error or inaccuracy of that information.

16. Linked third party websites

16.1  This website may contain links or references to other websites, including those of advertisers (“third party websites“) which are not under VOYC’s control.

16.2  The provisions of this Privacy Policy are not applicable to third party websites and VOYC shall not responsible for the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

17. Children's personal data

Our website and services are not directed to children. We do not knowingly collect personal data directly from children. If you believe that a child has provided personal data to us without appropriate authorisation, please contact us so that we can take appropriate action. Customers are responsible for ensuring that their use of the services involving children’s data complies with applicable law.

18. Cross-border transfers of personal data

18.1   VOYC is established in the Netherlands, and personal data may be processed in the European Economic Area, the United Kingdom, South Africa, the United States and other countries where VOYC, its customers or service providers operate. Where applicable law requires safeguards for an international transfer, we will use an adequacy decision, standard contractual clauses, the UK international data-transfer addendum or another valid transfer mechanism, together with supplementary measures where appropriate.

18.1.1  where required by applicable privacy law, the recipient is subject to a law, binding corporate rules or a binding agreement that provides an adequate level of protection for personal data; or

18.1.2  where required by applicable privacy law, the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of the User; or

18.1.3  where required by applicable privacy law, the User has consented to the transfer of their information.

19. Retention of information

19.1   We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including to provide the services, meet legal, accounting and reporting requirements, resolve disputes and enforce agreements. Retention periods vary according to the nature of the data, the relevant service, customer instructions, legal requirements and limitation periods. Customer Content is retained in accordance with the applicable customer agreement, data processing agreement and the relevant customer's documented instructions.

19.1.1  It is required by applicable privacy law to keep a record of such information for a longer period of time; or

19.1.2  It needs to keep a record of such information for contractual administration or the establishment, exercise or defence of legal claims; or

19.1.3  It has a contractual obligation to keep a record of such information; or

19.2  Where permitted by applicable privacy law, VOYC may, if it has de-identified personal data, keep such information for historical, statistical or research purposes. VOYC shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

20. Returning, destroying or deleting personal data

20.1  Where VOYC is no longer authorised to retain a record of any personal data under applicable privacy law, and subject to the applicable customer agreement, data processing agreement, the relevant customer's documented instructions, and applicable legal, regulatory, contractual, and legal-claim retention requirements, it shall, at the User's written request, either:

20.1.1  ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or

20.1.2  return the information to the User or transfer it to a third party, if requested by the User in writing to do so.

21. Consent

21.1  Where we rely on consent, we will request it in a clear, specific, informed and freely given manner, and consent will be unambiguous and obtained before processing. You may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal. We do not rely on consent where another lawful basis is more appropriate, such as performance of a contract, compliance with a legal obligation, legitimate interests or, where applicable, a customer’s documented instructions.

21.2  Where consent is required by applicable privacy law and the User gives consent, the User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy Policy regarding the following:

21.2.1  the types of personal data to be processed, including specifically special personal data;

21.2.2  the specific processing activities to be undertaken;

21.2.3  the specific purpose/s for such processing; and

21.2.4  the possible consequences for the User that may arise from such processing.

21.3  Where applicable privacy law provides a right to withdraw consent, should a User wish to withdraw any consent previously given by the User, they may notify VOYC’s Data Protection Officer in writing.

22. Lodging an objection

22.1  Where applicable privacy law provides a right to object, a User may, on reasonable grounds, object to the processing of their personal data at any time after that processing has started.

22.2  Where applicable privacy law provides a right to object, if a User wishes to object to the processing of their personal data, they must send written Policy of their objection to VOYC’s Data Protection Officer, together with their reasons for doing so.

23. Choice of law

This Privacy Policy does not alter the governing-law or dispute-resolution provisions in any agreement between VOYC and a customer. Nothing in this Privacy Policy restricts rights or remedies that cannot be excluded under applicable privacy law.

24. Amendment of this privacy policy

24.1   VOYC reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.

24.2  It is the User's obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.

24.3  We may update this Privacy Policy from time to time. We will post the updated version and revise the "Last updated" date. Where required by applicable law, we will provide additional notice or obtain consent before a material change takes effect.

Contact

For questions, privacy-rights requests or complaints about this Privacy Policy or our processing of personal data, contact our privacy team at infosec@voyc.ai, or write to Deepsight B.V. DPO, Lethabo Motsoaledi at:

WeWork c/o Deepsight BV

Strawinskylaan 4117, 4th Floor

Amsterdam  1077 ZX

The Netherlands

Last updated: 15 September 2026