Data Processing Addendum

1. Roles

If a user uploads a file containing personal data of other people, the user determines the lawful basis and purpose for providing that data, and Formatello.com processes it within the technical instruction: accept the file, convert it, provide the result and delete files under the retention policy.

For the user's own data, Formatello.com acts as a personal data operator under the Privacy Policy and Personal Data Processing Consent.

2. Data categories

• any personal data the user chooses to include in the source file;
• images, voice, documents, metadata, file names and other information contained in the material;
• technical job data: format, size, duration, status, event timestamps and a link to the payment record.

3. Processing operations

Formatello.com may collect, record, store, retrieve, transform, transfer within its infrastructure, provide the result, restrict access, delete and destroy data to the extent needed to complete the job.

Formatello.com does not use user content to train machine-learning models of the Provider or third parties without separate consent.

4. Sub-processors and Lava.top

Formatello.com may use infrastructure, storage, conversion, monitoring, transactional email, analytics and payment providers to perform jobs.

For the international payment contour, USD and EUR payments are processed through Lava.top. Lava.top's own documents apply on Lava.top, including its Terms of Service, Privacy Policy and Data Processing Agreement between the platform user and LAVALANE LTD.

Formatello.com shares with the payment provider only the data required to create an invoice, verify payment, process refunds, keep records and prevent abuse.

5. Security and retention

Access to data is limited to staff, contractors and services that need it for job completion, support, security, accounting or legal compliance.

Source uploads are deleted after 24 hours; results are normally available for 7 days; minimal job and payment records may be kept longer for accounting, refunds, security and disputes.

6. User obligations

• have a lawful basis for uploading and processing third-party personal data;
• not upload prohibited, malicious, unlawful or third-party content without rights;
• not include excessive personal data in a file when it is not needed for conversion;
• respond to data subject requests when the user is the controller or operator for that data.

7. Data subject requests

If Formatello.com receives a data subject request connected with a user's file, the service may ask the user to confirm the lawful basis for processing or take steps to delete, restrict processing or provide information.

Requests for data that Formatello.com processes as operator should be sent to info@conspecto.ru.