Privacy Policy

Last updated: 24 September 2026

1. General Provisions

This Privacy Policy (the "Policy") is issued by ALEKSANDR KOVALKO PR BEOGRAD (Registration No. 68581974, Tax ID (PIB) 115720536, Dunavski kej 48, 11000 Belgrade, Serbia; the "Operator"), in accordance with applicable Serbian data protection legislation.

This Policy governs how the Operator processes personal data of users of the ClearTranscriptBot bot, available on Telegram (https://t.me/ClearTranscriptBot).

2. Key Terms

This Policy uses terms as defined by applicable data protection legislation: "personal data", "data controller", "processing of personal data", "automated processing", and similar.

3. Categories of Personal Data

The Operator processes the following categories of personal data of individuals who use the ClearTranscriptBot bot:

• Telegram identifiers: user_id, username, first/last name, profile photo (where provided by Telegram);
• Media files (audio, video) submitted by the user for transcription;
• Technical data: request time, device type, Telegram client version;
• Payment-system tokens/identifiers (bank card details are never stored);
• Any other data the user chooses to share.

4. Purposes and Legal Basis for Processing

4.1. Performance of the agreement (Terms of Service) with the user.

4.2. Registration and provisioning of access to the bot's functionality.

4.3. Informing the user about new features and updates (where consent has been given).

4.4. Accounting and tax record-keeping, as required by applicable law.

4.5. Improving the service and personalization based on de-identified data (the Operator's legitimate interest).

5. Principles and Conditions of Processing

Personal data is processed lawfully and fairly. The scope and nature of the data processed correspond to the stated purposes. The Operator takes measures to keep data accurate, up to date, and secure.

6. Data Subject Rights

The user has the right to:

1. obtain information about the processing of their personal data;
2. request correction, restriction, or deletion of their data;
3. lodge a complaint about the Operator's actions or omissions with the competent data protection authority or a court;
4. withdraw consent to processing at any time.

7. Data Protection Measures

The Operator applies the following protective measures:

• internal policies governing data handling;
• access restrictions;
• encryption in transit (TLS 1.3 for API calls);
• backups;
• logging;
• access audits.

Audio files and transcription results are kept only for the limited period necessary to deliver the service.

8. Where Data Is Processed

Personal data is processed on infrastructure operated or contracted by the Operator. The specific hosting location(s) for this international offering are being finalized and will be confirmed here before launch.

9. International Data Transfers

Where personal data is transferred across borders, the Operator ensures an adequate level of protection consistent with applicable law and, where required, obtains the user's consent.

10. Retention and Deletion

Personal data is deleted once the purpose of processing has been achieved or consent has been withdrawn.

Retention periods:

• user data — up to 30 days after the user stops using the service;
• accounting records — as required by applicable law.

11. Updates to This Policy

This Policy remains in effect indefinitely and may be amended by the Operator. The current version is published at this link.

12. Operator Contact Details

ALEKSANDR KOVALKO PR BEOGRAD
Registration No. 68581974
Tax ID (PIB): 115720536
Dunavski kej 48, 11000 Belgrade, Serbia

E-mail: alex@gistrec.cloud
Telegram: https://t.me/gistrec