Legal notice and privacy
Legal notice (Impressum)
Provider (§ 5 DDG)
Andrea Otto, sole proprietorship, trading as Embervy c/o Block Services Stuttgarter Str. 106 70736 Fellbach Germany
Contact
Email: info@embervy.ai
VAT
Small business under § 19 UStG (Kleinunternehmerregelung): no VAT is charged.
Responsible for content (§ 18 (2) MStV)
Andrea Otto, address as above.
Consumer dispute resolution
We are neither willing nor obliged to take part in dispute resolution proceedings before a consumer arbitration board.
Privacy policy
1. Who is responsible
Andrea Otto, sole proprietorship, trading as Embervy c/o Block Services, Stuttgarter Str. 106, 70736 Fellbach, Germany info@embervy.ai We have not appointed a data protection officer; please write to the address above.
2. Visiting this website
This website is delivered by Cloudflare, Inc. (San Francisco, USA). To deliver the pages and protect them against attacks, Cloudflare processes technically necessary connection data: your IP address, the time of the request, the page requested and your browser's technical details. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is a working and secure website. We set no cookies, use no analytics or tracking, and load no fonts, videos or scripts from other providers.
3. Writing to us
Emails to info@embervy.ai are received by Cloudflare, Inc. and delivered to two places: our mailbox at Outlook.com, operated by Microsoft Ireland Operations Limited (Dublin, Ireland), and a copy on our own server at netcup GmbH (Karlsruhe, Germany), where we read and answer them. We use your address and your message to answer you. Legal basis: Art. 6(1)(b) GDPR if your message concerns a purchase or a contract, otherwise Art. 6(1)(f) GDPR (answering enquiries). We delete enquiries that do not lead to a purchase when the conversation is finished, at the latest after one year.
4. Buying Embervy Quickstart
For a purchase we process your name and email address, your postal address if you give it to us, the purchase record (date, price, invoice number, your consent to an early start and your acknowledgement of the loss of the right of withdrawal), payment data as far as it arises, and the support code we assign to you. We keep these records on our server at netcup GmbH (Karlsruhe, Germany). Your email address, support code, date of purchase and the end of your update year are also stored in the database of the download portal at Cloudflare, Inc. (see 5). Legal basis: Art. 6(1)(b) GDPR (contract), Art. 6(1)(c) GDPR together with § 14b UStG and § 147 AO (invoices and business records).
Renewal reminder. About four weeks before your update year ends, we send you one email with an offer to buy a further update year. Legal basis: Art. 6(1)(f) GDPR together with § 7(3) UWG; our legitimate interest is offering our own product to the people who bought it. You can object at any time, without giving reasons and at no cost other than the transmission costs at the basic rates (Art. 21(2) GDPR): reply to any of our emails or write to info@embervy.ai. We record your objection and send no further reminders. Update notices are not affected, because they are part of the contract.
5. Download portal
Your files are in a password-protected download portal at Cloudflare, Inc., at your own address under embervy.ai. The portal stores your support code, email address, date of purchase, end of your update year and your password only as a salted hash. When you sign in and download, your IP address and the time of access arise technically. Legal basis: Art. 6(1)(b) GDPR.
6. Support
To help you move in and to fix problems with our code, we keep what support needs:
Your emails are kept in the mailbox and nowhere else. Our records and the mailbox copy are stored on our server at netcup GmbH (Karlsruhe, Germany) and in the Outlook.com mailbox (see 3).
- your customer record: name, email address, support code, product, price, invoice number, payment date, contract date, end of the withdrawal period, download link, date of installation, the way your house runs (harness and model), the updates you received, and the date of your first support email;
- your support emails and our replies, in our mailbox.
Support requests are read and answered with the help of AI agents. To answer, an agent reads your email in full; for this, the text is sent to its model provider: Anthropic Ireland, Limited (Dublin, Ireland) or OpenAI Ireland Limited (Dublin, Ireland). Both use their services for us under their own terms as independent controllers, process data also in the USA under standard contractual clauses, and do not use our conversations for training. A person reads every reply before it is sent. We make no automated decisions about you.
The agents do not keep your emails. Their records hold only a reference to the email and your support code, never your name, address or the text. What they learn from a case is written down without any person in it (symptom, cause, solution). The agents run on our support server at Hetzner Online GmbH (Gunzenhausen, Germany; server in Nuremberg), their memory is stored with Cloudflare, Inc., and a small helper model at OpenRouter, Inc. (USA) works on their notes, which contain support codes only; OpenRouter does not store them.
If you do not want an AI agent to read your email, write "ohne KI" or "no AI" in the subject. Then only a person reads it.
Please do not send us passwords, API keys or the content of conversations with your AI agent. Legal basis: Art. 6(1)(b) GDPR; for the AI-assisted reading, Art. 6(1)(f) GDPR (our legitimate interest is answering quickly and well), and you can choose a person only, as described above.
7. Transfers outside the EU
Cloudflare, Microsoft, Google and OpenRouter also process data in the USA, and Anthropic and OpenAI do so from their Irish companies (see 6). Cloudflare, Microsoft and Google are certified under the EU-US Data Privacy Framework (adequacy decision of 10 July 2023, Art. 45 GDPR). OpenRouter transfers data on the basis of standard contractual clauses (Art. 46(2)(c) GDPR).
8. How long we keep data
Tax retention periods do not end while the records matter for a tax not yet assessed (§ 147(3) AO).
- Invoices and accounting records: eight years from the end of the calendar year in which they were issued (§ 14b UStG, § 147 AO).
- Emails concerning the contract (offer, acceptance with your consent, confirmation): six years from the end of the calendar year (§ 147 AO).
- Your email address for update notices and the renewal reminder: as long as we owe you updates, then within the periods above. If you object to the reminder, we keep a note of your objection so that we respect it.
- Support emails and our notes without tax relevance: until claims from the contract are time-barred, at the latest three years after the end of the year in which your move-in help ended. Deleting them means deleting them in the mailbox and your customer record; the agents' records hold only a reference and your support code.
Backups. We back up our server every day and every week, and the support agents' server every week. Each backup is encrypted on the server before it leaves it, with a key only we hold, and is then stored in Google Drive (Google Ireland Ltd., Dublin); Google cannot read it. Daily backups are kept for seven days, weekly backups for seven weeks; older ones are deleted, not moved to a bin. Data you have asked us to delete can therefore remain in a backup for up to eight weeks after we deleted it. We do not restore deleted data from a backup. If we ever have to restore a backup after an outage, we delete such data again straight away.
9. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18) and data portability (Art. 20). You may object to processing based on Art. 6(1)(f) GDPR on grounds relating to your particular situation (Art. 21(1)), and to the renewal reminder at any time without giving reasons (Art. 21(2), see 4). Write to info@embervy.ai. You may complain to a data protection supervisory authority (Art. 77 GDPR). Ours is: Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Ludwig-Erhard-Str. 22, 20459 Hamburg, mailbox@datenschutz.hamburg.de.
Status: October 2026