Privacy Policy

Version 1.7 · As of: October 7, 2026

This is a convenience translation. Only the German version is legally binding.

This privacy policy applies to the website oravoice.de, the account area konto.oravoice.de, the Ora service api.ora-ai.de and the desktop app "Ora" for macOS (together "Ora"). It explains which personal data we process, for what purpose, on what legal basis, to whom it is passed on and how long we retain it.

1. Controller

Gianmarco Colaiacolo
Sole proprietor, trading as "Ora"
Roman-Herzog-Str. 26
81248 München
Germany

Email: support@ora-ai.de (also for all data protection matters)
Contact form: https://konto.oravoice.de/kontakt

We have not appointed a data protection officer because there is no legal obligation to do so. Please direct all questions about data protection to the address above.

2. The most important points in brief

• Ora converts spoken language into text and refines it using artificial intelligence. There are two modes for this:
  • Fast mode: Your audio is transmitted in encrypted form, while you speak, via the Ora service to our speech recognition provider (Soniox, EU region) and converted into text there in the EU. The text is refined by Mistral AI (EU).
  • Local mode: Speech recognition runs on your Mac. Your audio does not leave your Mac. Only the recognized text is sent via the Ora service to Mistral AI (EU) for refinement.
• You can switch off the AI refinement. In Local mode, no dictation content then leaves your Mac.
• The Ora service stores neither your dictation text nor your audio: not in a database, not in files and not in logs. It only passes the content through.
• Settings, dictionary, history, meetings and progress data are stored only on your Mac.
• For your account, we store your email address and a few technical details (Section 5).
• On request, we will write to you once at the launch of Ora or Ora Pro, only with your confirmed consent and revocable at any time (Section 4.5).
• The app checks once a day whether a new version is available and downloads it silently; in doing so, our service providers only learn the technically necessary connection data. You can switch this off (Section 6.6).
• We use no analytics, advertising or tracking services, and the app sends no usage statistics or crash reports.

3. Website oravoice.de

The website oravoice.de (the former address ora-ai.de and www.ora-ai.de redirects there; in German and English) is operated together with the account area and the Ora service by Vercel Inc. (USA) in the data center in Frankfurt am Main (Section 4.1). When you visit it, Vercel processes technically necessary data that your browser transmits: IP address, date and time, the page requested, the amount of data transferred, referrer and information about your browser and operating system. This data is necessary to deliver the pages and to ensure secure operation. We do not combine it with other data and do not evaluate it for analytics purposes. The server logs are retained only as long as necessary for the security of operations and are then deleted.

The legal basis is Art. 6(1)(f) GDPR (DSGVO). Our legitimate interest lies in providing the website securely and without errors.

The website sets no cookies for analytics or advertising purposes. We store your choice between light and dark display only in your browser (Section 4.4). We remember your choice of language (German or English) in the cookie ora_lang (Section 4.2). Content from third parties is loaded only in the "Notify me" form, where Cloudflare Turnstile checks requests (Sections 4.3 and 4.5).

4. Account area konto.oravoice.de

4.1 Hosting

The account area and the Ora service are operated by Vercel Inc. (USA) in the data center in Frankfurt am Main. When you visit them, Vercel processes technically necessary connection data such as your IP address, date and time and the address requested, in order to deliver the pages and to fend off attacks. The legal basis is Art. 6(1)(f) GDPR (secure operation). For the transfer to the USA, see Section 11.

4.2 Cookies

In the account area, we use only cookies that are strictly necessary for the sign-in you requested (Section 25(2) no. 2 TDDDG). In our assessment, this also includes the cookie ora_ref, which we set only if you open a referral link and which serves solely to assign your new account to the referring person (Section 5.8). The cookie ora_lang, which we set on the website and in the account area when you choose a language, are redirected once automatically to the English page, or sign in, is equally strictly necessary; it contains only the language and serves only the language display you requested. No consent is required for this; that is why we do not show a cookie banner.

All cookies apply only to the account area, which is reachable exclusively via encrypted connections (HTTPS). The contents of these cookies are not used for analytics or advertising purposes. The legal basis for the associated processing is Art. 6(1)(b) GDPR.

4.3 Protection against automated requests (Cloudflare Turnstile)

On the sign-in page (sign-in by email link), in the contact form and in the "Notify me" form (Section 4.5), we use Cloudflare Turnstile from Cloudflare, Inc. (USA). Turnstile checks whether a request comes from a human. For this purpose, your browser loads a script from Cloudflare, and Cloudflare processes your IP address as well as technical information about your browser and device. We have the server confirm the result of the check; we do not store it. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in protecting the sign-in and the forms against automated mass requests and abuse. For the transfer to the USA, see Section 11.

4.4 Light or dark display

The pages of oravoice.de and konto.oravoice.de appear in light mode. If you choose the dark display using the switch in the navigation, we store this choice only in your browser (Local Storage, entry ora-theme with the value "dark" or "light") so that it applies again on your next visit. This is not a cookie; the entry is not transmitted to us or to third parties and is not evaluated. It is strictly necessary for the display you requested (Section 25(2) no. 2 TDDDG). You can delete it at any time via your browser settings.

4.5 Notification at launch

On the start page of konto.oravoice.de, you can sign up with your email address so that we write to you as soon as Ora launches or as soon as Ora Pro becomes available.

• Purpose: a notification at launch or about Ora Pro. We use the list for nothing else, in particular not for advertising or analytics.
• Data: your email address, your preference ("Launch" or "Pro"), the language of the page on which you signed up (so the emails arrive in that language), the time of sign-up and the time of your confirmation. We also store an encrypted check value (hash) for the confirmation and unsubscribe links.
• Double opt-in: After signing up, you receive an email with a confirmation link. You are on the list only once you open it and submit the confirmation.
• Legal basis is your consent (Art. 6(1)(a) GDPR). Providing the data is voluntary.
• Withdrawal: Every email to the list contains an unsubscribe link. With it, you withdraw your consent at any time with effect for the future (Art. 7(3) GDPR), and your entry is deleted immediately. You can also write to support@ora-ai.de.
• Deletion periods: We automatically delete unconfirmed entries after 7 days. We delete confirmed entries as soon as the notification about the launch or Ora Pro has been sent, at the latest when the list is discontinued.
• Recipients: We send the emails via Brevo (Sendinblue SAS, France); the list is held in our database at Supabase in the data center in Frankfurt am Main (Section 11).
• Protection against abuse: We check the form with Cloudflare Turnstile (Section 4.3). We limit sign-ups per IP address and confirmation emails per email address; for this purpose, we store encrypted fingerprints of the IP or email address for no more than 2 hours (Art. 6(1)(f) GDPR; legitimate interest: protection against mass requests and against third parties flooding other people's addresses with emails).

5. Account and sign-in

5.1 What data we store

To use Ora, you need an account. For your account, we store:

• your email address,
• the type of sign-in (email link, Google or Apple) and a sign-in identifier,
• for sign-in with Google or Apple, the information that the respective provider transmits (Sections 5.3 and 5.4), including your name, if it is stored there and you release it,
• the time of registration and of your last sign-in,
• your preferred language (German or English), used only to show the account, the sign-in link and the emails to you in that language; it is stored with the account and with the sign-in service and is included in the data export,
• the time and version of the terms of use and the privacy policy that you confirmed at registration, as well as your acknowledgment of the data processing agreement,
• your device sign-ins (Section 6.4) and the counters for the weekly limit and the meeting limit (Section 6.5),
• if you provide it voluntarily, your information on how you found out about Ora (Section 5.7),
• if you recommend Ora or arrive via a referral link: your referral code and the link between the referring and the referred account (Section 5.8).

We store no password, no dictation text and no audio.

The legal basis is Art. 6(1)(b) GDPR (usage contract). Storing the time and version of your confirmation additionally serves as evidence (Art. 6(1)(c) and (f) GDPR).

The account database and the sign-in are operated by Supabase in the data center in Frankfurt am Main (Section 11).

5.2 Sign-in with email link

If you sign in by email link, we send a sign-in link to your email address. It is valid for 15 minutes and only once. For sending, we use Brevo (Sendinblue SAS, France). If you request a link for an address with which you never sign in afterwards, we delete this address after 24 hours.

5.3 Sign-in with Google

If you choose "Continue with Google", you are redirected to Google. Google Ireland Limited (Ireland) processes your sign-in there as an independent controller in accordance with Google's privacy policy and learns in the process that you are signing in to Ora. From Google, we receive only the information that belongs to the permissions "openid", "email" and "profile": your email address, your name, an identifier of your Google account and, where applicable, the address of your profile picture. We receive no access to contacts, documents, calendars or other Google services. Signing in with Google is voluntary; you can use the email link instead at any time. The legal basis is Art. 6(1)(b) GDPR.

5.4 Sign-in with Apple

If you choose "Continue with Apple", you are redirected to Apple. Apple Distribution International Ltd. (Ireland) processes your sign-in there as an independent controller in accordance with Apple's privacy policy and learns in the process that you are signing in to Ora. From Apple, we receive an identifier of your Apple Account sign-in for Ora, your email address and, only at the first sign-in and only if you release it, your name. If you choose "Hide My Email" at Apple, we receive a forwarding address generated by Apple (…@privaterelay.appleid.com) instead of your address; Apple forwards our emails to this address on to you. We receive no access to further data of your Apple Account. Signing in with Apple is voluntary; you can use the email link or Google instead at any time. The legal basis is Art. 6(1)(b) GDPR.

5.5 Protection against abuse of the sign-in

To prevent the trial-and-error guessing of sign-ins and the mass sending of sign-in links, we count requests per email address, per IP address and per app installation. What is stored is not the address itself but only a fingerprint encrypted with a secret key (HMAC) and the time of the request. These entries are deleted after 2 hours at the latest. The legal basis is Art. 6(1)(f) GDPR (protection against abuse and security of processing).

5.6 Deletion and export

In the account area, you can download your data as a file at any time ("Download my data") and delete your account yourself. The export also contains the section "empfehlung" (referral) (Section 5.8). Upon deletion, we immediately remove your account, your device sign-ins, your counters, your information on how you found out about Ora (Section 5.7) and your referral code including the links (Section 5.8).

We automatically delete accounts that have not been used for a long time: after 23 months without a sign-in and without a status query from one of your devices, you receive an email stating that your account will be deleted in 30 days. If you sign in during this time, the account remains.

5.7 Information on how you found out about Ora ("How did you hear about Ora?")

During the setup of the app and in the account area, we ask you how you found out about Ora. Providing this information is voluntary. Nothing is preselected, and you can skip the question without any change to your use of Ora.

If you answer, we store on your account your selection (for example "Social media"), where applicable your more specific selection (for example "Instagram"), a short free text of no more than 100 characters (for example the name of a podcast) as well as the time of the entry and of its last change. Please do not enter names or personal details in the free text. We store no IP address and no device data for this and do not link the information to your dictations.

We want to understand through which channels people find Ora. For this purpose, we evaluate the answers only in aggregate (for example, how many accounts chose "Podcast"). We do not evaluate them for individual persons, do not pass them on to third parties and do not use them for advertising, profiling, the weekly limit or your license.

The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by providing the information voluntarily. You can withdraw it at any time with effect for the future by removing the information in the account area with "Delete information" or by writing to us.

The information is held in the account database in the data center in Frankfurt am Main (Section 11) and is stored until you delete it or your account is deleted. You can view, change or delete it at any time in the account area; it is part of "Download my data".

5.8 Referral link ("Recommend Ora")

If you recommend Ora, we generate a random referral code for your account, which is part of your referral link. If someone opens your link and creates an account, or someone redeems your code in the app, we store that this account came about via your code (the two account identifiers and the time) and count the redeemed referrals. We store no names or email addresses for the referral. We never show you who used your link; for each referral, we show only the date and status (signed up, rewarded, completed) and the number of your referral months; the referred person never sees who the link came from.

The terms of the campaign are set out in the participation terms "Recommend Ora" (konto.oravoice.de/empfehlung/bedingungen). In short: The referred person immediately receives one month of Pro; the referring account receives one month of Pro as soon as the referred person has dictated 500 words, up to 12 times at most. You can redeem a code only once and only within 7 days after creating your account. For this, we use the words of the referred person that are counted anyway for the weekly limit (only the number, never the content).

The purpose is to grant the referral month and to protect against abuse (self-referral, mass accounts). To this end, when a code is redeemed, we check whether both accounts are signed in on the same computer, and we limit the use and redemption of codes per internet address, per device and per account. We store the internet address for this purpose only as an encrypted fingerprint, for no more than 2 hours (Section 5.5).

Legal basis: Art. 6(1)(b) GDPR (carrying out the campaign you chose; participation is voluntary) and Art. 6(1)(f) GDPR (our legitimate interest in protecting the campaign against abuse).

Cookie: Via a referral link, we set the cookie ora_ref (Section 4.2) with the referral code, for no more than 30 minutes until the account is created. We then delete it.

Retention period: The referral code and the link remain stored until your account is deleted. Links for which no referral month was granted are automatically deleted after 90 days at the latest. Processing takes place in the account database in Frankfurt am Main (Section 11), without additional service providers.

Your rights: You can find access and export in your account under "Download my data" (section "empfehlung"). When you delete your account, your code and your links disappear immediately. Participation is voluntary: if you create your account without a referral link, no link is created. Where we process data on the basis of Art. 6(1)(f) GDPR, you can also object (Section 17).

6. Dictating with the app

6.1 How your data flows through Ora

You choose the mode in the setup assistant and can change it at any time in the settings. If, in Fast mode, speech recognition at the provider cannot be reached, the Ora service first has the same audio recognized by Mistral AI (EU); if your Mac is offline, Ora recognizes the dictation on your Mac instead, provided the speech model is loaded (Section 9). For this purpose, the recording stays in working memory only until the result is available.

You can switch off the AI refinement in the settings (set "Refinement level" to "None"). Ora then inserts the recognized text unedited; in Local mode, no dictation content then leaves your Mac.

The legal basis for processing your dictations is Art. 6(1)(b) GDPR (providing the service you use). If you use Ora professionally or for business, we process the dictation content on your behalf (Section 13).

6.2 The Ora service

The app contains no access key for Mistral. All requests to Mistral and to the speech recognition provider run via the Ora service (api.ora-ai.de, Vercel, data center in Frankfurt am Main). The Ora service checks your device sign-in and your weekly limit, forwards the request with our key to Mistral AI or to the speech recognition provider and returns the response to the app. In doing so, it stores neither text nor audio.

For operation, the Ora service writes one log line per request with the time, type of request, result code, duration, text length in characters or audio duration in seconds and a non-reversible short identifier of the device. These logs never contain text, audio, email addresses, access tokens or IP addresses and are deleted after 14 days at the latest. The legal basis is Art. 6(1)(f) GDPR (operation, troubleshooting and security).

6.3 Mistral AI

Text refinement is carried out by Mistral AI SAS (France) as our processor. In Fast mode, Mistral AI also recognizes speech as a fallback if the speech recognition provider (Section 6.3b) cannot be reached, is not set up or has aborted. The Ora service uses only the EU endpoint of Mistral (api.eu.mistral.ai). The following go to Mistral:

• only in the fallback case, the audio of your dictation and the audio of a meeting transcript (microphone and sound of the Mac), without terms,
• the recognized text,
• the instruction of the selected template and profile,
• only those of your own terms from the dictionary that occur in the dictation or sound similar, never the whole list.

The following do not go to Mistral: your email address, your account, device or installation identifier and your IP address. The names and technical terms that Ora reads from the screen (Section 7) never go to Mistral.

6.3b Speech recognition in Fast mode

In Fast mode, the Ora service recognizes your speech using the real-time speech recognition service of Soniox Inc., 1045 Helm Lane, Foster City, CA 94404, USA, as our processor. The Ora service uses only the EU region (endpoints api.eu.soniox.com and stt-rt.eu.soniox.com). The audio goes there while you speak, encrypted (TLS 1.2 or higher) via the Ora service; the recognized text comes back. This also applies to the meeting transcript in Fast mode (Section 8), including the voices of other conversation participants.

The following go to the provider: the audio (for meetings continuously and separately for your microphone and the sound of your Mac, Section 8), the selected language and up to 100 terms as context: the terms from your own dictionary, the triggers of your text snippets and, if "Pass names from the screen to the refinement" is switched on, names from the active window. The terms apply only to that one dictation; for the meeting transcript, no terms are sent. Please do not enter passwords or account data in the dictionary. The following do not go to the provider: your email address, your account, device or installation identifier, your IP address, the text of text snippets, the window text, the basic terms of your profession, notes and titles.

According to the provider, audio and transcripts in the EU region are processed and stored exclusively in the EU; the provider's system, account, usage and billing data (without content) may be processed outside the EU. Via the real-time interface, which the Ora service alone uses, the provider stores neither audio nor recognized text. Audio and transcripts are never used to train models. The Ora service likewise stores neither audio nor text. The provider is certified under SOC 2 Type 2 and ISO 27001.

If the provider cannot be reached, is not set up or aborts, the Ora service recognizes the same audio at Mistral AI instead (Section 6.3), without the terms; if your Mac is offline, Ora recognizes on your Mac. A session always runs with only one of the two services.

Distinguishing speakers in meetings: For the meeting transcript in Fast mode, the provider distinguishes the voices of the conversation participants on the "Others" track (sound of your Mac) and labels them in the transcript as "Speaker 1", "Speaker 2" and so on. To do this, it analyzes the voices within the running connection. We transmit no voice samples and create and store no voice profiles; the numbers are not stored by us, and the provider stores nothing on the real-time route. The numbers apply only within the running connection and the individual meeting; persons are not recognized again across meetings. Only you yourself assign names to the speakers; they remain on your Mac (Section 8). In Local mode, no audio goes to a service provider.

6.4 Sign-in of the app and status query

To connect the app to your account, Ora opens the account area in your browser. After your confirmation, the app receives a device token, which it stores in the macOS keychain (Keychain) only on this Mac. For this process, we briefly store a sign-in request that contains only encrypted fingerprints and expires after 10 minutes at most; requests that are not redeemed are deleted 2 hours later at the latest.

For each signed-in device, we store an encrypted fingerprint of the randomly generated installation identifier, a check value (hash) of the device token, the sign-in date and the day of the last check. We store no device or computer names and no serial numbers. A maximum of two devices per account is possible. The entry is deleted immediately if you sign the device out, replace it with another one, delete your account or the device has not reported in for 60 days.

At startup and then at most every 24 hours, the app queries the Ora service as to whether your device is signed in and how much of your weekly limit has been used. The device token and the app version are transmitted in the process.

The legal basis is Art. 6(1)(b) GDPR.

6.5 Weekly limit and meeting limit

Ora is currently free of charge and has a weekly limit for dictated words as well as a limit for meeting transcripts (terms of use). For this, we store:

• per account and calendar week, the number of processed words: only numbers, never text. The current week and the four preceding weeks are retained;
• per dictation, a receipt consisting of a random identifier and the word count already counted, so that a dictation counts only once. Receipts are deleted after 2 hours;
• per meeting for which a summary was created, a random meeting identifier with the calendar week. Never content, title, duration or notes. These entries are deleted after 8 weeks.

To protect against overload and cost abuse, the Ora service also limits the number of requests per device and account per minute; these counters are deleted after 2 hours at the latest.

The legal basis is Art. 6(1)(b) GDPR, and for the abuse limitation Art. 6(1)(f) GDPR.

6.6 Automatic app updates

Ora checks in the background about once a day whether there is a new version of the app. For this, the app retrieves a small description file ("appcast.xml") from our website oravoice.de. If a newer version is available, the app downloads the update from our file storage at Supabase (data center in Frankfurt am Main), checks its digital signature and installs it only the next time you quit Ora. An update therefore never interrupts a running dictation or meeting transcript. Update files without a valid signature are not installed.

During these retrievals, the website's hosting provider (Sections 3 and 4.1) and Supabase process technically necessary connection data: your IP address, date and time, the file requested and the identifier of the app with its version number, as every file retrieval sends it. In doing so, we transmit no account, device or installation identifier, no device token and no information about your Mac (no system profile), and we do not combine these retrievals with other data or evaluate them. The providers' logs are retained only as long as necessary for secure operation.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in fixing errors and security vulnerabilities of the app promptly. You can switch off automatic updates at any time under "Settings" → "System" → "Update automatically"; the app then neither retrieves the description file nor downloads updates. In this case, you receive new versions via the download page of our website.

7. What stays only on your Mac

The app processes the following data exclusively on your Mac. It is not transmitted to us; we have no access to it.

• Settings, including dictation key, mode, profile, microphone and, if you enter them, your name and your firm or company for the greeting in the app.
• Own dictionary: terms and names that you enter yourself. It remains until you remove terms or uninstall Ora.
• Collected words for suggestions in the dictionary: individual words from your dictations (never whole sentences), 200 at most, which are deleted after 30 days without a new occurrence. The function can be switched off; the collected words are then deleted immediately.
• Dictation history (switched on by default for new installations, can be switched off at any time): inserted and recognized text of past dictations with time and template. Entries are automatically deleted after 30 days, can be deleted individually and are deleted immediately when you switch off the history.
• Meetings (Section 8): transcript, summary, title and your notes, 30 days at most.
• Progress data: only numbers, dates and identifiers about your dictation behavior (for example number of dictations and words per day, time saved, streak, achievements). Never text, never names. Programs in which you dictate are stored only as a non-reversible identifier. The daily values are deleted after 13 months; the function can be switched off and reset.
• Screen terms: At the start of a dictation, Ora reads the text around the cursor in the active text field in order to derive names and technical terms for the correct spelling. The text read is discarded immediately; the terms apply only to that one dictation and are neither stored nor transmitted. The function can be switched off.
• Style per app type: Ora recognizes from the active program whether you are currently writing a message, a work chat, an email or something else, and writes in the style set for it (formal, balanced or casual). The program name stays on your Mac; only the type of app (for example "Email") and the style instruction go to Mistral.

The files are located in the "Ora" folder under ~/Library/Application Support/, are readable only by your macOS user and are excluded from Time Machine backups. The device token is stored in your Keychain, only for this Mac and without synchronization. Ora never stores audio on the hard drive.

8. Meeting transcript

When you start the meeting transcript, Ora records the microphone ("Me") and the sound of your Mac ("Others") and recognizes the speech as specified by the mode set at the start. This mode applies for the entire meeting.

• Local mode: Speech recognition runs exclusively on your Mac. The audio is neither stored nor transmitted.
• Fast mode: The audio goes continuously and encrypted via the Ora service to our speech recognition provider (Soniox, EU region) for as long as the transcript is running and is converted into text there in the EU. For your microphone ("Me") and for the sound of your Mac ("Others"), there is a separate connection each. This means that pauses and background noise are also transmitted, not just spoken segments. The audio also contains the voices of the other conversation participants. On the "Others" track, the provider distinguishes the voices and labels them in the transcript as "Speaker 1", "Speaker 2" and so on (Section 6.3b); there are no voice samples or voice profiles, and the numbers apply only within the meeting. Only you yourself assign names to the speakers; they are stored only on your Mac and never transmitted. Your weekly limit counts the recognized words as for a dictation. Terms from your dictionary are not sent along for meetings. Neither the Ora service nor the provider stores the audio or the text. If a connection drops, Ora temporarily sends the audio from that point on, in short segments (each 20 seconds at most), via the Ora service for recognition (at Soniox, otherwise at Mistral AI in the EU); in these segments, the speakers are not distinguished, and Ora automatically re-establishes the running connection. If your Mac is offline, the Ora service cannot be reached or your weekly limit has been reached, Ora recognizes the segment on your Mac instead, provided the speech model is available; otherwise it is missing from the transcript. The recognized text appears provisionally in the app already during the meeting and is held in working memory only until it is incorporated into the transcript.

In both modes, the audio is never stored. What is stored is the recognized transcript, the summary, a title and your own notes: only on your Mac, 30 days at most; you can delete meetings individually or all at any time.

For the summary, the transcript goes, as described in Section 6.3, via the Ora service to Mistral AI (EU); Mistral forms the title from the transcript in the same request. Your notes and a title you assigned yourself never go to Mistral. For the meeting limit, the Ora service learns only a random meeting identifier and the duration, never the content. In Fast mode, during speech recognition it additionally learns the number of recognized words (for the weekly limit).

Important: For conversations with other people, you are responsible for informing the participants beforehand and, where required, obtaining their consent. The unauthorized recording of the non-publicly spoken word is a criminal offense under Section 201 of the German Criminal Code (StGB). For this purpose, the app offers a notice text for participants that you can copy.

9. Download of the speech model (Hugging Face)

For speech recognition on your Mac (Local mode and fallback when there is no connection), Ora downloads a speech model once from the servers of Hugging Face, Inc. (USA). In the process, Hugging Face receives your IP address and technical request data (time, file requested, app identifier). Hugging Face receives no dictation, audio or account data. Hugging Face processes this data as an independent controller. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in providing you with local speech recognition. For the transfer to the USA, see Section 11.

10. Contact form, email and feedback

If you write to us via the contact form, by email to support@ora-ai.de or via the app's feedback function, we process your email address, your name (if provided) and your message in order to handle your request. The app's feedback function only prepares an email in your own mail program; Ora itself sends nothing in the process.

We deliver messages from the contact form as an email to our mailbox via Brevo (Sendinblue SAS, France); the form itself stores nothing. To protect against abuse, we check requests with Cloudflare Turnstile (Section 4.3) and limit the number of messages per IP address; for this purpose, we store an encrypted fingerprint of the IP address for no more than 2 hours.

The legal basis is Art. 6(1)(f) GDPR (answering your inquiry), and for inquiries about your account Art. 6(1)(b) GDPR. We delete inquiries as soon as they are resolved, after 12 months at the latest, unless statutory retention obligations stand in the way.

Please do not send us client, patient or health data. If we receive such data by mistake, we delete it.

11. Recipients and transfers to third countries

We use the following service providers. We have concluded data processing agreements under Art. 28 GDPR with all of those who act on our behalf.

Independent controllers for their respective processing are Google Ireland Limited (Ireland) for the optional sign-in with Google (Section 5.3), Apple Distribution International Ltd. (Ireland) for the optional sign-in with Apple (Section 5.4) and Hugging Face, Inc. (USA) for the download of the speech model (Section 9).

Transfers to third countries: Dictation content (audio and text) is processed exclusively in data centers in the EU: at the Ora service in Frankfurt am Main, at Mistral AI via its EU endpoint and at Soniox in the EU region. However, some service providers are based outside the EU. Where data is transferred to them or access from there is possible, the following applies:

• USA (Vercel, Cloudflare): The transfer is based on the Standard Contractual Clauses of the European Commission (Art. 46(2)(c) GDPR) and, where the respective provider is certified under the EU-US Data Privacy Framework, on the adequacy decision of the European Commission (Art. 45 GDPR).
• USA (Soniox): Soniox Inc. is based in the USA. Audio and transcripts are processed in the EU region; where the provider, its group companies or subcontractors can access them from outside the EU, and for the provider's account, usage and billing data (without content), which may be processed outside the EU, the transfer is based on the Standard Contractual Clauses of the European Commission (Implementing Decision (EU) 2021/914, Module 2), which form part of our data processing agreement with Soniox (Art. 46(2)(c) GDPR). As subcontractors, Soniox uses data center providers (Amazon Web Services, Google Cloud, Oracle Cloud, each in the EU region) and Cloudflare (network and protection against attacks).
• Singapore (Supabase): The data is located in the data center in Frankfurt am Main. Where Supabase or its subcontractors, including in the USA, can access it, this is based on the Standard Contractual Clauses of the European Commission (Art. 46(2)(c) GDPR).
• USA (Hugging Face): You trigger the download yourself in order to use local speech recognition. Where Hugging Face is certified under the EU-US Data Privacy Framework, the adequacy decision applies (Art. 45 GDPR); otherwise, the transfer is necessary for the performance of the usage contract (Art. 49(1)(b) GDPR).

You can request a copy of the Standard Contractual Clauses at support@ora-ai.de.

12. Notes for professionals bound by professional secrecy

Ora is also used by tax advisors and other professionals bound by professional secrecy (Section 62a StBerG (German Tax Advisor Act), Section 203 StGB). The following applies:

• In the data processing agreement, we commit to confidentiality, also bind the persons working with us and our service providers to it and point out that a breach is a criminal offense.
• Dictation content is only passed through and is not stored at the Ora service. Only the content necessary for the individual dictation goes to Mistral (Section 6.3).
• In Fast mode, Soniox, as our speech recognition provider, receives your audio, that is, voice data, and for meetings also the voices of other conversation participants (Section 6.3b). Soniox distinguishes these voices within the running connection ("Speaker 1, 2 …") without our transmitting voice samples; we create and store no voice profiles; the numbers apply only within the connection. In the data processing agreement, Soniox has committed to bind employees and subcontractors with access to this data to confidentiality within the meaning of Section 203 StGB.
• In Local mode, the audio does not leave your Mac. If the AI refinement is also switched off, no dictation content leaves your Mac.

Please assess on your own responsibility whether and in which mode the use of Ora is compatible with your professional obligations and whether you must inform your clients or obtain their consent. These notes are not legal advice.

13. Professional and business use

If you use Ora for professional or business purposes, you are the controller for the personal data in your dictations and meeting transcripts, and we process it on your behalf. Our data processing agreement under Art. 28 GDPR, including a confidentiality undertaking, applies to this. It is available on the page "DPA & Professional Secrecy" (oravoice.de/avv) and can be downloaded as a PDF.

For your account (Section 5) and the enforcement of the weekly limit and the meeting limit, we remain the controller ourselves.

14. AI notice (Art. 50 AI Act)

Ora recognizes, words and structures your text with the help of artificial intelligence (language models from Mistral AI, a speech recognition service from Soniox in Fast mode and, in Local mode, a speech recognition model on your Mac). Meeting summaries are created by AI and are labeled as such in the app. AI results may contain errors. Please check the inserted text and every summary before you reuse or send it.

15. No analytics, no automated decision-making

We use no analytics, advertising or tracking services, neither on the website nor in the account area nor in the app. The app sends no usage statistics, no crash reports and no telemetry.

No decision based solely on automated processing, including profiling, takes place that produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR). The weekly limit and the meeting limit are technical usage limits that are the same for all users.

16. Obligation to provide data

Providing your email address and the device sign-in are necessary for using Ora; without them, we cannot provide you with the service. Beyond that, you are not obliged to provide us with any data.

17. Your rights

You have the following rights against us:

• access to the data stored about you (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• withdrawal of consent given, with effect for the future (Art. 7(3) GDPR), for example for the notification at launch (Section 4.5) or the information on how you found out about Ora (Section 5.7).

Right to object (Art. 21 GDPR): Where we process data on the basis of Art. 6(1)(f) GDPR, you can object at any time on grounds relating to your particular situation. We will then no longer process the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defense of legal claims.

You can download and delete your account data yourself in the account area. Please direct all other requests to support@ora-ai.de. We respond within one month. Data that is stored only on your Mac (Sections 7 and 8) is managed and deleted by you yourself in the app.

If you use Ora professionally or for business and a person named in a dictation contacts us, we forward the request to you as the controller.

18. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR). The authority responsible for us is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA).

19. Changes

We adapt this privacy policy when Ora or the legal situation changes. You can find the current version at oravoice.de/datenschutz and in the app. We will inform you of material changes in the app or by email.