Privacy Policy
By accessing, using and making use of Verbatim (the "Services"), you understand that your data in relation with your use of our Services is processed according to the following privacy policy (the "Privacy Policy"). The Privacy Policy states (i) what data we collect through your access and use of the Services; (ii) the use we make of such data; and (iii) the safeguards put in place to protect your data. The Privacy Policy is to be read and understood as being a complement to our terms and conditions.
1. Legal Framework
The Services are operated by RubidiumData OÜ (the "Company", "We"), domiciled at Järvevana tee 9, 11314 Tallinn, Harju maakond, Estonia. It is therefore governed by the laws and regulations of Estonia.
2. Data that may be collected using Verbatim, and how they may be used
Our overriding policy is to collect as little user information (personal data included) as possible to ensure a private user experience when using the Services.
Data collection is limited to the following:
2.1 Verbatim data processing activities
In order to provide you with the Services, the Company processes the following data:
2.1.1 Survey creator account creation
If you create surveys using our services, your account is linked to an email address you provide at the creation of the account. No additional personal information is required for account creation. The legal basis for this processing activity is the execution of a contract.
2.1.2 Survey participant access
Survey participants do not create accounts. When participants click on magic links to access surveys, we place cookies on their devices to maintain survey session state. No personal account information is collected from survey participants unless explicitly provided within the survey responses themselves. The legal basis for cookie placement is legitimate interest in providing functional survey services.
2.1.3 Survey Activity
Your inputs are processed by the Services in order to provide outputs. Survey participants access surveys through magic links sent to their email addresses. This includes the content of surveys you create, questions, responses, and any other survey-related information provided by participants. Contact information of survey respondents is limited to email addresses used to distribute survey access links. After processing of an input and generation of an output, data is stored to maintain your survey history and results within Verbatim.
2.1.4 Payment information
If you purchase a Verbatim subscription, we rely on third parties to process payments. We do not retain full credit card details, only the last 4 digits of the credit card number. We may use your account data for payment-related matters, including but not limited to sending you emails, invoices, receipts, notices of delinquency, and alerts to update payment information. The legal basis of these processing activities is the necessity to the execution of the contract to provide the Services. In order to respect the principle of data minimisation, we reserve our right to remove payment information from our systems that is no longer valid, without notice.
2.2 Third-party processing activities
2.2.1 Social Media
We are active on different social media platforms. Any information, communication, or material you submit to us via social media platforms is done at your own risk without any guarantee of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
2.3 Fraud and abuse detection
We may use the data mentioned above to detect abusive and fraudulent use of our services, and take appropriate measures. The legal basis of this processing is our legitimate interest to protect our service against non-compliant or fraudulent activities.
3. Data processors
To provide the Services, we rely on different data processors, which process different categories of data. Processors never store data outside of the scope of their specific purpose. Notably, they do not store data in relation with the general day-to-day use of your account and Services, which is exclusively processed by the Company. Processors are as follow:
3.1 Third-party processors
Microsoft Corporation / Microsoft Azure
Purpose: To provide artificial intelligence features through Azure OpenAI services, including voice transcription and survey analysis capabilities
Data processing location: European Union (Azure Sweden Central region)
Guarantees for international transfer: Standard Contractual Clauses, Data Processing Agreement
Amazon Web Services EMEA SARL / Amazon Web Services, Inc. (AWS Frankfurt)
Purpose: To provide cloud infrastructure and compute services required to run the Verbatim platform
Data processing location: European Union (AWS Frankfurt region)
Guarantees for international transfer: Standard Contractual Clauses, Data Processing Addendum
OVH SAS / OVHcloud
Purpose: To provide cloud storage for the Verbatim platform
Data processing location: European Union
Guarantees for international transfer: Standard Contractual Clauses, Data Processing Addendum
4. Data disclosure
We will only disclose the limited user data we possess on a Verbatim account if we are legally obligated to do so by a binding request coming from the competent Estonian authorities.
5. Your privacy using Verbatim
You can request access, editing, deletion, or export of personal data processed by the Company in your use of the Services by contacting our support team.
In case of violation of your rights, you have the right to lodge a complaint to the competent supervisory authority.
6. Modifications to Privacy Policy
Within the limits of applicable law, the Company reserves the right to review and change this Privacy Policy at any time. As long as you are using the Services, you are responsible for regularly reviewing this Privacy Policy. Continued use of the Services after such changes are performed shall constitute your consent to it.
In case of discrepancy between the English version of these Terms and any translated version, the English version shall prevail.