Ember Română

Privacy Policy

Ember · effective [publication date]

This says, briefly and plainly, what data Ember uses, why, who we share it with and what rights you have. If anything is unclear, write to us at privacy@ember-si.com. If the Romanian and English versions differ, the Romanian version prevails.

1. Who we are

The data controller is Paradigm Systems S.R.L., registered office Cluj-Napoca (municipality), Cluj County, Strada Poet Andrei Mureșanu no. 9, apt. 3, tax ID (CUI) 55676388, Trade Register no. J2026057051002 (EUID ROONRC.J2026057051002). Contact for personal data: privacy@ember-si.com.

2. What data we use

DataWhyLegal basis
Your account: the Apple or Google identifier, name, email and profile picture link (if the provider shares them)To sign you in and keep your conversations on any deviceContract (Art. 6(1)(b) GDPR)
Conversations with Ember and the experts, photos you sendTo reply to you and let you come back to themContract
What Ember knows about you (“memory”) and Ember’s “soul”So Ember knows you and talks the way you likeConsent: you can turn it off and delete it at any time
Tasks, goals, notes, remindersYour plan and its notificationsContract
Your voice, in voice modeTo understand what you say. Your voice is recognised first by the phone’s dictation (Apple or Google); when that fails, the audio is transcribed by a provider (below). We don’t keep recordingsContract
Subscription and purchases (no card details)To know your plan and the credits you’re owedContract
AI usage (cost in credits) and invitationsUsage limits, invitation rewards, preventing abuseContract and legitimate interest
Technical data: device type, app version, errors (not what you wrote)To fix problems and keep the service secureLegitimate interest
Usage statistics (Firebase Analytics): which screens and features you use, app version, device type; never the content of conversations. Collected only after your consentTo improve EmberConsent, given on the “Before we start” screen (the “You help me get better” row); withdraw it at any time under You → “Withdraw consent”. We keep the data for at most 14 months (Firebase’s maximum)
Reports: when you report an AI answer (long-press it → Report), the reported message and your previous message, the reason and your noteSafety and moderationLegitimate interest. We keep reports for 12 months
Notification tokenTo send the notifications you turned onConsent

Health and other sensitive data. If you choose to tell Ember or an expert about your health or other sensitive information, we use it only to reply to you, based on your explicit consent (Art. 9(2)(a) GDPR), which you give on the “Before we start” screen in the app by tapping “I agree”. You can withdraw it at any time in the app, under You → “Withdraw consent”; without it, Ember does not answer you. You can delete the data at any time, together with the conversation.

3. Artificial intelligence

Ember’s and the experts’ replies are generated by artificial intelligence models. To reply, your message and the needed context (the recent conversation, what Ember knows about you, your plan) are sent, through OpenRouter, to the AI model that writes the reply (see below). We use the providers’ paid services, where our data is not used to train models. We make no automated decisions with legal effects on you.

4. Who we share data with

We don’t sell your data. These providers use it only on our behalf, under data processing agreements, in this order:

ProviderWhat it receives / for what
Google Firebase / Google CloudYour account, database, files and server (EU/US, with standard contractual clauses)
OpenRouterRoutes your messages to the AI models (US)
Google Gemini and Anthropic ClaudeThe AI models that write the replies, reached through OpenRouter
OpenAIThe voice in Ember Plus and speech transcription
ElevenLabsThe voice in Ember Plus, coming soon
Google Cloud Text-to-SpeechThe voice on the free plan
RevenueCatSubscriptions and purchases
StripeCard payments on the website
NetlifyHosting of the website and the web app
Apple and GoogleApp stores, sign-in and notifications

The providers use the data only to provide the service, not to train their models.

Some providers process data outside the European Economic Area, mainly in the US. Transfers use the safeguards GDPR requires: the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses.

Authorised personnel of Paradigm Systems S.R.L. may access a user’s conversations and memory only to answer a report the user filed or a support request. Each access is recorded in an access log (who, when, why), and the log is kept for 12 months.

5. How long we keep data

As long as you have an account. You can delete a conversation, what Ember knows about you, or your whole account at any time in the app (You → Account). When the account is deleted we delete conversations, memory, plan and usage data. How to delete your account: /delete-account. Temporary accounts (without Apple or Google) unused for 12 months are deleted automatically. Server logs are kept for at most 30 days, and reports of answers and the staff access log for 12 months. Anonymised technical statistics and records the law requires (accounting, for example) may remain as long as the law requires.

6. Your rights

You have the right to access your data, correct it, delete it, restrict its processing, take it with you, object to processing based on legitimate interest, and withdraw consent at any time. Write to us at privacy@ember-si.com; we reply within one month. You also have the right to complain to the Romanian data protection authority, ANSPDCP (dataprotection.ro), or to the authority in your EU country.

7. Age

Ember is for people aged 16 and over. We don’t knowingly collect data from younger children.

8. Security

Data is encrypted in transit and on the servers, and access to it is limited. No system is perfect; if an incident affects you, we’ll tell you as the law requires.

9. Changes

If we change something important, we’ll tell you in the app before it takes effect.