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CONSENT TO THE CROSS-BORDER TRANSFER OF PERSONAL DATA

Revision of 5 September 2026 · Version 1.0

I give my free, specific, informed, and conscious consent to Kristina Alekseevna Yadova, a citizen of the Russian Federation, to the cross-border transfer of personal data (the “Consent”) in the manner provided for by Article 12 of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006, before using the functions of the Service that require such transfer (transcription and diarization of files, processing of the result by a language model). This consent constitutes a separate document and does not form part of the Public Offer, the Personal Data Processing Policy, or any other documents.

1. Operator

Kristina Alekseevna Yadova, a payer of tax on professional income (self-employed, Federal Law No. 422-FZ), TIN 667471164215, website https://whistlerai.ru, e-mail: info@whistlerai.ru (the “Operator”).

2. Personal Data Subject

A User of the Service, identified by registration actions on the website https://whistlerai.ru, or by the numeric account identifier (MAX ID) in the MAX messenger (in the Service's “Whistler Ai” bot, https://max.ru/se13319000_bot), or by the Telegram ID in the Telegram messenger (in the Service's “Whistler Ai” bot, https://t.me/YouTube_SummarySummary_Bot), which is automatically recorded when Consent is expressed. The date and time Consent is expressed are recorded automatically.

3. Recipients and States of Transfer

The User consents to the transfer of their personal data to the following persons:

Recipient State Purpose of transfer
DeepSeek PRC Processing of the transcript / text by a language model
Alibaba Cloud Computing Ltd. (Qwen) USA Processing of the transcript / text by a language model
x.Ai LLC USA Transcription and diarization of audio
Veelma USA Transcription and diarization of audio

4. Risk Disclosure

The User has been informed of, and understands, that the USA is not included in the list of foreign states that ensure adequate protection of the rights of personal data subjects under Roskomnadzor Order No. 128 dated 5 August 2022, “On Approval of the List of Foreign States Ensuring Adequate Protection of the Rights of Personal Data Subjects.” This means that the level of legal protection of PD in the USA may differ from that provided for by the legislation of the Russian Federation.

5. List of Data Transferred

The content of the Content submitted by the User (including voice in audio and video files and transcript text), as well as de-identified (pseudonymized) technical identifiers necessary for processing, in the form of an identifier (UUID).

6. Purpose of the Cross-Border Transfer

Obtaining the result of processing the Content (transcription of speech, separation by speaker, generation of a structured summary/synopsis) using external transcription services and language models.

7. Terms and Duration

7.1. The cross-border transfer is carried out after the Operator files a notification with Roskomnadzor in the manner provided for by Article 12 of Federal Law No. 152-FZ, and upon expiry of the established period for its review (or such other period as established by the authorized body), and subject to obtaining the relevant permit (where necessary).

7.2. Consent is valid from the moment it is expressed by the Personal Data Subject until the purposes of the transfer are achieved, or until it is withdrawn.

7.3. Consent may be withdrawn by sending a request to the Operator's e-mail, info@whistlerai.ru. After withdrawal, the cross-border transfer ceases; it will become impossible to provide the Service's functions that require such transfer (transcription and diarization of files). Functions that do not require the cross-border transfer of the User's PD (for example, summarization of publicly available videos via a link) may remain available.

8. User's Confirmation

The User confirms that they are aware of the nature and consequences of the cross-border transfer, has read the Personal Data Processing Policy, and expresses Consent by performing a conclusive action (clicking the “Confirm” button), recognized as a simple electronic signature.

Date and User identifier are recorded automatically at the moment Consent is expressed.