Privacy PolicyPrivacy Policy

The data controller for personal data processed through Ember is IORDACHE MIHAI-RAZVAN PFA, a sole-proprietor business (PFA) in Romania.

Privacy inquiries and data subject requests go to [email protected], the controller's contact address for this notice. No data protection officer has been appointed.

Purchases are made from Polar as merchant of record, so your invoice and the checkout page carry Polar's billing details for the payment itself. Polar handles payment, invoicing, tax, and fraud-prevention data as an independent controller under its own terms.

As data controller, Ember determines the purposes and means of processing your personal data in accordance with the EU General Data Protection Regulation (GDPR, Articles 13 and 14) and Romanian data protection law (Law 190/2018). The supervisory authority is ANSPDCP (Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal) at dataprotection.ro.

Ember collects and processes the following categories of personal data depending on how you use the product and website:

Where the data comes from (GDPR Articles 13 and 14). Most data comes from you directly, when you create an account, use the app, or write to support. Sign-in identity data comes from Google or Apple at your request. Billing and order metadata (customer email, plan, subscription and payment status, order and invoice identifiers, tax status, renewal and cancellation information) comes from Polar. Technical data comes from the app on your computer.

Your email address and payment details are needed to create an account and to subscribe; without them Ember cannot provide the contract. Audio, transcripts, and prompts are sent for AI processing only when you start a feature that needs them, and not sending them only means that feature is unavailable. Analytics and affiliate cookies are optional, and refusing them has no effect on the service.

Ember makes no decision about you that has legal or similarly significant effects solely by automated means, and does not profile you for such decisions (GDPR Article 22). Ember does apply automated technical controls, such as rate limits on sign-in and account requests per IP address, plan device limits, and credit limits; Polar applies its own fraud checks to payments. These controls can block a request, a sign-in, a free trial, or a checkout attempt. If one does and you think it is wrong, email support to have a person review it, to give your view, and to contest the outcome.

Under GDPR Article 6, we process your personal data on the following legal bases:

Where we rely on legitimate interest, we have assessed that our interests do not override your fundamental rights and freedoms. You may object to processing based on legitimate interest at any time by contacting us at [email protected].

Emails. We send essential service and account notices (for example, scheduled maintenance, security, billing, a purchase confirmation, or material changes to your plan) on the basis of contract or legitimate interest; these do not require marketing consent. We send product news, feature updates, and offers only to accounts that opt in, with an unsubscribe link in every such message and a product-news preference you can change on your Account page. You can withdraw that consent at any time, and our opt-in is never pre-ticked or required to create an account.

We will not use your data for a new purpose that needs your consent without asking you for that consent first.

Subtitle editing, track layout, file exports, and DaVinci Resolve integration run entirely on your local machine. When you work with local files, those operations are not transmitted to Ember’s servers.

The desktop app keeps working files in its app-data folder on your computer: caches of caption plans and business plans, and the music mixes it caches for exports. They exist to save time and are not sent to Ember.

Ember's servers keep the following, and delete it on the schedule shown:

When Ember fails, it sends a diagnostic report to Ember's servers automatically so the defect can be found and fixed. This processing relies on our legitimate interest in keeping the service reliable and secure (GDPR Article 6(1)(f)); you can object to it at any time by turning off Automatic diagnostic reports in Settings > Account > Privacy. The Report button stays available for a report you choose to send yourself.

A report contains the error, the app version, the operating system, and bounded excerpts of Ember's recent logs from the last two app launches. Before a log line is written or sent, Ember removes file paths and file names, email addresses, access tokens and URL query strings. A report never contains your footage, audio, subtitles, scripts or transcript text, and it is not used for advertising or sold.

Ember sends one report per distinct error per app version: the same failure on the same build is never sent twice, while a new app version reports it again so a regression stays visible. At most three new reports are sent per day in total. Reports are kept for support and defect analysis for 12 months and then deleted automatically; you can ask for earlier deletion through the contact address in this policy.

Ember's AI features process content with remote providers. Ember sends only the audio, transcript, subtitle text, still frames, or prompt content needed to complete the request you start. Cloud transcription and Translation use speech-processing providers; Furnace with Cast or Scripts and Refine use language-model providers. For customer requests sent through Ember's AI routing service, Ember requires Zero Data Retention (ZDR) on each request, restricting routing to endpoints that do not retain the submitted content after processing. Ember's servers check an upload's format, duration, and decodability before transcription and keep no copy of the audio. For transcription providers that temporarily store an upload and transcript, Ember requests deletion immediately after processing and retries a failed deletion. To answer repeated requests safely, Ember's servers keep AI results (the transcript, or a Refine or Cast answer) for 24 hours and then delete them; queued job payloads (prompts and inline images) also expire after 24 hours. Requests from Ember's own developer accounts for building and testing are exempt from the request-level ZDR requirement so provider-side logs remain available for debugging; customer accounts are never routed that way. Models and processing routes may change. Contact [email protected] for details of the providers that process your data.

Payments, checkout, invoicing, tax collection, and subscription management are handled by Polar as Ember’s merchant of record. When you purchase Ember, Polar may collect billing contact details, payment method details, billing address, VAT or tax information, IP address, fraud-prevention signals, order details, and invoice data.

Ember does not receive or store full payment card numbers. Ember receives limited billing metadata from Polar, such as your customer email, product or plan, subscription status, payment status, invoice or order identifiers, tax status, and renewal or cancellation information needed to provide the service. After each purchase Ember emails you a confirmation of your plan, price, renewal terms, and immediate-performance acknowledgement.

Ember uses license and session data to activate the app, restore access on launch, authorize downloads, and check for updates.

Your account credentials and refresh token are stored locally on your device. Access tokens are kept in memory for the active session.

The Ember website uses cookies and similar technologies. When optional analytics is configured, a consent banner asks for your choice. Visitors in Europe who arrive through an affiliate partner link are asked before any affiliate referral cookie is placed, and accepting and rejecting are equally easy. Elsewhere, affiliate referral cookies are placed when you arrive through a partner link, and you can switch them off at any time. We decide which group you are in from the country our content delivery network (Cloudflare) infers from your IP address, which we use only for that one decision and do not store; if no country is available we use your browser’s time zone, and when that is unknown or European you are asked first.

Strictly necessary cookies are used for core website functionality and do not require consent. All analytics cookies, and marketing cookies for visitors in Europe, require your prior opt-in consent before being placed on your device, in accordance with the EU ePrivacy Directive (2002/58/EC) as transposed by Romanian Law 506/2004.

Analytics data may include IP addresses, browser information, device data, pages visited, and interaction events. When Google Analytics is configured, it operates under Google’s data processing terms.

Two different periods apply to analytics. The cookie lifetime in the list above is how long the identifier stays on your device (up to 24 months). The event data collected with it is kept in Google Analytics for no more than 14 months and then deleted automatically. Withdrawing consent deletes the cookies right away; data already collected is deleted when its 14 months end.

When optional tracking is active, you can change or withdraw your choice at any time through Manage cookie choices on this page, which reopens the same banner. Withdrawing a category deletes the cookies it had already placed and reloads the page so any tracker that had started stops running. Your browser settings can block or delete cookies independently of that control.

If Ember adds additional non-essential cookies, this section and the consent banner will identify the provider, purpose, category, and duration before those cookies are placed.

Ember shares personal data with the categories of recipients below only as needed for the service, or when the feature or choice involved applies. For the current list of recipients, the data involved and their locations, email [email protected]. See also Subprocessors.

Business customers can request a data processing agreement by emailing [email protected].

Your personal data is transferred to and processed in countries outside the EU/EEA in the following circumstances:

Every transfer to a recipient outside the EU/EEA that has no adequacy decision relies on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), or the EU-US Data Privacy Framework where the recipient is certified under it. You can ask for a copy of the safeguards at [email protected].

We retain your personal data only as long as necessary for the purposes described in this policy. The windows for what Ember's servers store are listed in What Ember Stores on Its Servers; the rest follows these rules:

When retention periods expire, data is securely deleted or anonymized. Legal obligations (such as tax records) may require longer retention of certain data categories.

Under the General Data Protection Regulation, you have the following rights regarding your personal data:

Right to object to direct marketing (Art. 21(2)): you have the right to object at any time, free of charge, to our processing of your personal data for direct marketing purposes. This right is separate from any other objection you may raise, and raising it stops direct-marketing processing immediately. Object by emailing us or by using an unsubscribe link in any marketing message you receive.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days as required by GDPR. We may need to verify your identity before processing your request.

Complaints. If you are unhappy with how we handle your data, email [email protected]. We answer in writing within 30 days. You may also complain to ANSPDCP or to the supervisory authority of your EU member state at any time; you do not have to contact us first.

Breaches. If a personal data breach occurs, we notify ANSPDCP within 72 hours of becoming aware of it where the law requires notification, and we notify the affected users without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

Ember is not directed at children. You must be at least 18 years old (or the age of legal majority in your jurisdiction) to use Ember.

In Romania, the GDPR consent threshold for children is 16 years of age (Article 8 GDPR, as implemented by Romanian Law 190/2018). Under the U.S. Children’s Online Privacy Protection Act (COPPA), the threshold is 13 years.

If we become aware that we have collected personal data from a child without appropriate parental consent, we will take steps to delete that data promptly. If you believe a child has provided us with personal data, contact us at [email protected].

Ember implements appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

No method of electronic transmission or storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

Ember may update this privacy policy as the product, legal requirements, or data practices change. We notify account holders by email at least 30 days before a material change takes effect; other changes are published on this page with a new date.

If we want to use your data for a new purpose that is based on your consent, we ask for your consent again; continued use of Ember is never treated as consent. The current version is always available at www.embersubs.com/privacy.