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Legal

Privacy Policy

Last updated: October 6, 2026 · Version 1

This English version is provided for convenience. The German version is legally binding.

1. Controller

The controller responsible for the processing of personal data through the website, the Orena app and the update services operated by Ernst Systems is:

Isabel Ernst
trading as “Capacity Leadership Coaching”
Business name: Ernst Systems
Möhnestraße 5
79238 Ehrenkirchen
Germany

Email for privacy requests: privacy@ernst-systems.com
Phone/WhatsApp Isabel Ernst: +49 (0)176 32357986

Privacy requests should preferably be made by email.

Contacting us via WhatsApp is voluntary. In that case, WhatsApp or its provider processes its own connection, device and communication data. For confidential or data protection matters, we recommend contacting us by email.

We have not appointed a data protection officer because there is no legal obligation to do so.

2. Scope

This privacy policy applies to:

  • the Ernst Systems website;
  • the Orena app for iPhone and iPad;
  • the Orena software for Mac;
  • the connection between the app on iPhone or iPad and the Mac;
  • the Orena manager dashboard on the Mac, on the iPhone and iPad and in the browser, including the encrypted transfer via Ernst Systems' intermediate store;
  • the provision and verification of software updates;
  • enquiries, contract conclusion and customer support by Ernst Systems.

Services and accounts that a purchaser sets up themselves with Apple, Anthropic, Google, Cloudflare or other providers are additionally subject to the privacy terms and contracts of the respective provider.

3. Core principle of the Orena architecture

Orena is fundamentally locally operated software.

Conversations, reminders, tasks, files, contacts, personal settings and Orena's local memory are generally processed and stored on the user's Mac. Ernst Systems does not operate a central cloud in which this content is stored in readable form and has no routine access to it. The only exception is the optional transfer of the manager dashboard: its content is encrypted on the Mac before it leaves the Mac and cannot be read by Ernst Systems (see the section “Cloudflare, software updates and dashboard”).

The app for iPhone and iPad serves as a remote control for the connected Mac. If the Mac is switched off or unreachable, functions that require the Mac cannot be carried out.

The app for iPhone and iPad may cache content that has already been loaded in protected form so that it can be displayed within the app. Such local copies are removed when the connection is removed or when a complete local deletion is performed.

In the case of business use, the respective purchaser or their company generally decides on the purposes and means of processing their content. The purchaser is then usually the controller for their own use under data protection law. Ernst Systems does not receive this content merely because the Orena software is used.

4. Processing when visiting the website

4.1 Technical provision and server logs

The website is hosted by STRATO. When the website is accessed, technically necessary data may be processed, in particular:

  • IP address;
  • date and time of access;
  • page or file requested;
  • amount of data transferred;
  • browser type and operating system;
  • referring website;
  • technical error and security information.

The processing serves the secure and trouble-free provision of the website, error analysis and protection against attacks.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest lies in the secure and reliable operation of our website.

Log data is only stored for as long as necessary for operation, security, misuse detection or statutory record-keeping obligations. The specific technical retention period of the hosting provider is additionally governed by the plan and data processing agreement concluded with STRATO.

4.2 Visitor counting with consent

Ernst Systems counts visits with its own counter on its own web space, but only if the visitor chooses “Yes, sure” in the notice. The visitor's browser then sends the page viewed, the sections reached, clicks on contact and sign-up buttons, submitted forms (without their content) and the domain of the referring page to Ernst Systems' server. The device type (computer, phone, tablet) is derived there from the browser identifier. No cookies are set. IP address and browser identifier are not stored. To group the visits of one day, a short identifier is derived using a random value that is created anew each day and deleted afterwards, so visits on different days cannot be linked. Browsers with “Do Not Track” enabled are not counted. The counting data is evaluated exclusively by Ernst Systems in its own systems, including in the Orena dashboard. It is not passed on to third parties and is deleted after 400 days at the latest. The legal basis is the visitor's consent (Section 25(1) TDDDG and Article 6(1)(a) GDPR). The visitor can withdraw it at any time with effect for the future via “Privacy settings” at the bottom of every page. The choice is stored in the local storage of the visitor's browser (entry “es-zaehlung”) so that the notice does not appear on every visit. This is strictly necessary for that purpose (Section 25(2) No. 2 TDDDG). No advertising trackers or profiling are used. Personal data is not used for behavioural advertising and is not sold to data brokers.

With the same consent, Ernst Systems additionally integrates the statistics service Metricool (Metricool Software, S.L., Madrid, Spain). For this, the browser loads a script from tracker.metricool.com and transmits the address of the page viewed, the referring page, the size of the browser window and an identifier of Ernst Systems' Metricool account. For technical reasons, Metricool also receives the IP address and the browser identifier. Metricool does not set cookies in the process. Delivery takes place via the Amazon CloudFront network. Ernst Systems uses the evaluation to view website visits together with the reach of its own social media channels. Metricool processes the data on behalf of Ernst Systems on the basis of a data processing agreement. The legal basis is the visitor's consent (Section 25(1) TDDDG and Article 6(1)(a) GDPR). Without consent, Metricool is not loaded. Consent can be withdrawn at any time via “Privacy settings” at the bottom of every page.

4.3 Fonts

Where the fonts used on the website are provided locally, no connection to Google takes place when the fonts are loaded.

If fonts are instead loaded directly from Google Fonts, the IP address of the device may be transmitted to Google. External embedding only takes place if it has been enabled beforehand by valid consent or if another sound legal basis exists. Consent given can be withdrawn at any time with effect for the future.

4.4 Waitlist for Orena

Anyone who joins the waitlist on the website provides their email address and, optionally, their first and last name. We use this information exclusively to inform them about the launch of Orena and how to get access.

The legal basis is consent pursuant to Article 6(1)(a) GDPR. Consent can be withdrawn at any time with effect for the future, for example via the unsubscribe link in every email or by message to privacy@ernst-systems.com.

To manage the waitlist and send emails, we use ActiveCampaign (ActiveCampaign, LLC, Chicago, USA). On submission, the data entered and technical connection data such as the IP address are transmitted to ActiveCampaign. A data processing agreement is in place with ActiveCampaign. Transfers to the USA are based on the EU-U.S. Data Privacy Framework or standard contractual clauses.

The data is stored until consent is withdrawn or the waitlist is no longer needed.

4.5 Encryption

The website is transmitted exclusively in encrypted form via HTTPS (TLS). An encrypted connection can be recognised by the padlock symbol and “https://” in the browser’s address bar.

4.6 Links to social networks

We link to our Instagram profile on the website. This is a simple link; no Instagram content is embedded. Data is only transferred to Instagram (Meta Platforms Ireland Ltd.) when visitors click the link and open the Instagram page. Meta’s privacy policy applies to this.

5. Contact and pre-contractual communication

When people contact us by email, phone or WhatsApp, we process the data provided, in particular:

  • name and contact details;
  • content of the enquiry;
  • communication history;
  • where applicable, contract, invoice and payment information.

The processing serves to handle the enquiry, prepare and perform contracts, provide customer support and keep records.

Depending on the occasion, the legal bases are Article 6(1)(b), (c) and (f) GDPR. Documents relevant under commercial and tax law are stored in accordance with the statutory retention periods. Other enquiries are deleted as soon as they are no longer needed and there are no legal grounds for further retention.

6. Local processing by Orena

Depending on the activated functions and the user’s instructions, Orena may process the following data locally:

  • chat messages and conversation histories;
  • tasks, reminders and personal settings;
  • selected files, images and documents;
  • contacts or calendar information released by the user;
  • content from programs and services the user connects, for example emails, customer data, receipts or messages;
  • microphone and voice input;
  • optionally a mathematical voice vector for speaker recognition;
  • on instruction, camera images and screen content of the Mac;
  • optionally the most recently transmitted location;
  • connection and pairing data between iPhone or iPad and Mac;
  • local security and error logs.

This data generally remains on the user’s devices. The user decides which content Orena receives and which functions are activated.

An optional voice vector is not an audio recording but a mathematical representation of voice characteristics. It is stored locally on the Mac and can be deleted there.

Location data is only processed if the user grants the corresponding permission and uses a location-based function. Orena does not keep a permanent movement profile; only the location most recently provided for the respective function is intended to be processed.

Microphone recordings are not stored permanently without a specific purpose. Files provided for analysis or temporary working files are deleted once processing is complete, unless they are expressly to be saved as part of a task or conversation.

Speech recognition (converting speech to text), wake word detection and speaker recognition run with local models on the Mac. Orena downloads the model files from the Hugging Face service during setup and with updates. Hugging Face receives the Mac's IP address but no content.

7. Confirmation of legal texts and record of proof

7.1 What this is about

Before using Orena for the first time, the user confirms in the app and during setup in the dashboard that they have received and read the terms, this privacy policy and the AI notices. The user also confirms that they check important results. Ernst Systems records this confirmation in order to be able to prove later that, and which, texts were shown to the user.

7.2 What data is processed

  • time of the confirmation (UTC and local time);
  • place of the confirmation (app or dashboard);
  • device model, app or Orena version and a random installation ID;
  • name and email address of the account that confirmed;
  • version and checksum (SHA-256) of each confirmed text and the wording of both confirmations.

No Orena content is transferred, i.e. no emails, appointments, documents, conversations or customer data.

7.3 Where the data is stored

  1. On the user's device: The confirmation is stored in an append-only log. Each entry contains a checksum of the previous one, so later changes become apparent. The user cannot delete or reset this log in Orena, not even via “Delete everything”, because it serves as proof for Ernst Systems (see legal basis). It is part of the encrypted backup.
  2. At Ernst Systems: With every confirmation, Orena sends a copy of the details listed above from the user's own mailbox connected in Orena to privacy@ernst-systems.com. The user also receives a confirmation email. If no mailbox is connected yet, Orena keeps the copy on the device and sends it as soon as a mailbox is connected.

7.4 Legal basis

Article 6(1)(f) GDPR. Ernst Systems' legitimate interest is being able to prove that the contractual terms and notices were validly included, and to establish, exercise or defend legal claims. Insofar as the documentation serves the performance of the contract, additionally Article 6(1)(b) GDPR.

7.5 Recipients

  • Ernst Systems as controller;
  • Ernst Systems' email provider STRATO GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany, as processor, with servers in Germany;
  • the provider of the user's mailbox through which the copy is sent.

Ernst Systems does not transfer this data to third countries.

7.6 Retention period

Ernst Systems stores the records for the duration of the contract and thereafter until the statutory limitation periods expire. As a rule, this is three years from the end of the year in which the contract ends (Sections 195, 199 German Civil Code). If legal proceedings are pending, they are stored until the proceedings are concluded and deleted afterwards.

7.7 Rights of the user

The user has the rights of access, rectification, restriction and to lodge a complaint with a supervisory authority, as described in the section “Rights in Germany and the European Union”. Under Article 21 GDPR the user can object to the processing. However, Ernst Systems may continue to store the records insofar as they are needed to establish, exercise or defend legal claims (Article 21(1) sentence 2, Article 17(3)(e) GDPR). Requests should be sent to privacy@ernst-systems.com.

7.8 Renewed confirmation

If Ernst Systems materially changes any of these texts, the user will be asked to confirm the new version again. Earlier confirmations are kept as proof.

8. Connection between iPhone or iPad and Mac

The app for iPhone and iPad connects to the Mac paired by the user. The connection serves to transmit tasks, retrieve results and control Orena on the Mac.

The connection is bound to the respective pairing and is encrypted. Ernst Systems does not store a copy of the conversation content transmitted between iPhone or iPad and Mac.

To establish the connection, technical data such as device identifiers, pairing information, connection status and security logs may be processed. This data is used exclusively for authentication, system security and troubleshooting.

9. Cloud AI from Google Gemini and Anthropic

Orena currently uses models from the Claude Sonnet family by Anthropic, mainly for reasoning and writing, and Gemini Flash Live by Google, mainly for live conversation. The model version used may change with updates.

Orena can use external AI services. They are only used if the user:

  1. provides their own access or API key for the respective provider;
  2. activates the cloud AI function; and
  3. expressly consents to the data transfer intended for this purpose.

Depending on the task, the following may be transmitted from the Mac directly to the selected provider:

  • the current input;
  • parts of conversations, reminders and content from connected programs selected for the task;
  • expressly selected images or documents;
  • for live voice functions, microphone audio or transcripts (Google);
  • on instruction, camera images: single shots to Anthropic, in live camera mode about one image every two to three seconds to Google;
  • on instruction, screenshots of the Mac (Anthropic) when Orena is to check something on the screen or operate the Mac;
  • for song recognition, a few seconds of ambient audio (Google) if recognition via Shazam on the iPhone fails or the request is made on the Mac;
  • for web searches, the search term (Google).

Orena does not store camera images, screenshots or audio snippets permanently. Only the result is kept, for example the answer as text.

Ernst Systems does not receive this content. The purchaser maintains the account with the respective AI provider themselves, decides which provider is used and is responsible for its contract, privacy and billing settings.

The terms, privacy information and, where applicable, data processing agreements of the selected provider also apply. In particular, the user should check whether content is used for training purposes, which region is set, how long data is stored and whether a Data Processing Addendum is offered.

Consent to cloud AI can be withdrawn in Orena at any time via “Withdraw cloud AI”. The withdrawal takes effect for the future. Cloud-based AI and live voice functions will then no longer be available; local data and other local functions remain unaffected.

Where a company uses Orena for employees, customers or other persons, the company itself must ensure that there is a valid legal basis for the transfer to the selected AI provider and that the required information obligations are fulfilled.

10. Apple services and App Store

Apple processes data under its own responsibility when the Orena app is obtained or updated via the App Store or used on an Apple device. This may include Apple ID, device, payment, diagnostic and App Store data. Ernst Systems has only limited influence on this processing.

Orena uses the Apple Push Notification service and, where applicable, VoIP push to notify the user on the iPhone or iPad and to inform a connected device about a pending connection or task. The Mac sends the notifications directly to Apple. In particular, the following is processed:

  • a push token provided by Apple;
  • technical delivery information;
  • the text of the respective notification.

Regular notifications contain the text of the message, for example a reminder or a short message from Orena. They may therefore contain personal or business content. Notifications for incoming calls (VoIP push) contain no content, only a random identifier. Messages that cannot be delivered immediately may be stored temporarily in accordance with Apple's technical conditions. The user decides in the iPhone or iPad settings how notifications appear on the lock screen.

Apple’s privacy terms also apply.

11. Cloudflare, software updates and dashboard

Ernst Systems uses services provided by Cloudflare to deliver signed software updates and to secure their retrieval. Ernst Systems also operates an intermediate store for the manager dashboard there: the Mac stores the current dashboard status there in encrypted form, and the iPhone, iPad or a browser retrieves it. Tasks the user triggers in the dashboard travel back to the Mac the same way, encrypted.

The following may be processed:

  • IP addresses of the Mac, iPhone, iPad or browser;
  • time of retrieval;
  • requested update version or file;
  • technical HTTP and security information;
  • information about successful or failed retrievals;
  • for the dashboard, additionally a random identifier of the dashboard and the size and time of the encrypted data packets.

The dashboard content is encrypted on the Mac with AES-256 before it leaves the Mac and is only decrypted again on the iPhone, iPad or in the browser. The key is derived from the user's dashboard password. It is stored in the Mac's keychain and reaches the iPhone or iPad when pairing via QR code. Ernst Systems and Cloudflare therefore cannot read the content. No readable Orena conversations, reminders, files, contacts or API keys are transferred to Ernst Systems via updates or the dashboard.

If a company uses Ernst Systems' intermediate store, Ernst Systems processes the connection data mentioned on its behalf (Article 28 GDPR). Alternatively, the intermediate store can be set up on the user's own Cloudflare account during setup. The transfer then does not run through Ernst Systems.

The processing is carried out to perform the contract and to securely provide necessary updates on the basis of Article 6(1)(b) and (f) GDPR. The data protection agreements required for the service, including provisions for international data transfers, are in place with Cloudflare.

Cloudflare accounts or tunnels that the purchaser sets up for their own installation are controlled by the purchaser. The purchaser is responsible for their configuration and data processing.

12. Connected third-party programs and services

12.1 Principle

Orena can work with more than 100 programs and services, such as email and calendar, CRM systems, accounting and invoicing software, payment services, project tools, newsletter, marketing and automation services, website and analytics tools, social networks and messengers, and the Apple apps on the Mac. The full list is on our home page.

The user decides which programs are connected. Orena connects directly from the user's Mac to the respective provider, using the user's own accounts. Credentials and sign-in keys are stored in the Mac's keychain. The retrieved content is processed on the Mac. Ernst Systems does not receive it; there is no intermediary server operated by Ernst Systems.

Processing by the respective provider is subject to its terms and privacy notices. If a company uses Orena, it is itself responsible for the connected accounts. It names these services in its own privacy notices and, where required, concludes data processing agreements with the providers.

12.2 Sign-in by click via the “Orena” application

For the following services, the user signs in with one click. The provider's sign-in page opens in the browser. The user signs in there, sees which permissions Orena receives and agrees. The user is then returned automatically to their Mac. The sign-in runs via an application called “Orena” that Ernst Systems has registered with the respective provider. The provider therefore shows Ernst Systems as the publisher. Orena only requests the permissions it needs for the respective tile, in most cases read-only access.

  • Google (Google Calendar, Google Drive, Google Analytics, Google Search Console)
  • Notion
  • Slack
  • Calendly
  • Typeform
  • Asana
  • ClickUp
  • monday.com
  • HubSpot
  • Airtable
  • Vimeo
  • Square
  • SumUp
  • Instagram (Meta)
  • Meta Business Suite (Meta)
  • Xero
  • QuickBooks (Intuit)
  • Sage Accounting
  • FreshBooks
  • DocuSign
  • Zoho CRM

The access keys are stored only on the user's Mac and are not transmitted to Ernst Systems. However, in the developer areas of these providers Ernst Systems can see technical information about the application, for example how many accounts are connected, and logs of sign-in events with account or workspace identifiers. Ernst Systems does not see any content from the accounts there. Ernst Systems uses this information only to provide technical support for the sign-in and to fix errors. The legal basis is our legitimate interest in a working sign-in (Article 6(1)(f) GDPR). How long this information is stored depends on the respective provider's settings. Several of these providers are based in the USA or process data there (see “International data transfers”).

The user can revoke access at any time in Orena or directly in their account with the provider.

12.3 Programs with the user's own access key

The user connects all other programs with an access key they create themselves in their account with the provider, or Orena opens the service in the user's browser. This applies, for example, to Lexware Office, sevDesk, DATEV, Stripe, PayPal, Klarna, Mailchimp, ActiveCampaign, WordPress, Wix and email mailboxes. Ernst Systems is not involved in these connections and receives no data from them.

Orena connects payment services read-only, for example to display sales, payouts or refunds. Orena does not trigger payments, transfers or refunds. In accounting software, Orena can upload receipts and create drafts.

12.4 Public information sources

For news, weather and exchange rates, Orena retrieves public sources directly from the Mac, for example BBC, Tagesschau, The Guardian, GDELT, the European Central Bank as well as wttr.in and Open-Meteo for weather and place search. The respective provider receives the Mac's IP address and, where applicable, a search term, a place name or coordinates rounded to two decimal places. Orena checks search terms for passwords and personal identifiers beforehand.

13. Remote connection and backup

For the connection between iPhone or iPad and Mac while away, Orena uses the Tailscale service. Tailscale establishes an encrypted connection between the devices and processes device and connection data such as IP addresses and device identifiers for this purpose. Tailscale has no access to the transmitted content. On the home network, the devices connect directly.

Orena regularly backs up its data in encrypted form on the Mac. On request, Orena additionally copies this encrypted backup to a location chosen by the user, such as an external drive or a cloud folder like iCloud Drive or Google Drive. The backup also contains the stored credentials. The backup password stays in the Mac's keychain. Ernst Systems does not receive any backups.

14. Phone agent

Orena does not call other people on its own. A call to third parties is only started on the user's specific instruction via the phone number set up on the user's paired iPhone. For urgent matters, Orena can call the user on their own iPhone.

At the beginning of the call, Orena introduces herself as an AI assistant, for example:

“Hello, I’m Orena, the AI assistant of [name].”

The user is responsible for ensuring that the call is permissible. This applies in particular to advertising calls, automated or artificially generated voices, Robinson or do-not-call lists and any required prior consent.

Promotional calls may only be made if the user can prove the consent required under the law of the country, state or province being called.

Recording or transcription of a phone call may only be activated if all participants have been properly informed beforehand and, where required, have expressly consented. Without these conditions, no recording may take place.

Ernst Systems does not receive a copy of the call merely because the phone agent is used.

15. Messages to other people

Orena sends messages to other people on the user's instruction or as part of functions the user sets up. These include the automatic confirmation of appointment requests by email if the user switches this function on, and a message to customers if the user is running late for an appointment. Orena only sends the delay message if the user has stored a contact in the calendar entry.

Orena reads messages from WhatsApp and Telegram and only writes to the user's own chat. Orena only reads Instagram direct messages. Orena only publishes Instagram posts once the user has approved the draft. For this, the image is temporarily provided via a public link in Google Drive. Orena only sends promotional messages by SMS or iMessage to recipients whose consent is on record.

16. Automated decisions

Orena supports users with tasks and can prepare or carry out actions on their instructions. Ernst Systems does not make solely automated decisions about individuals based on Orena data that produce legal or similarly significant effects.

The user must review results and remains responsible for decisions and actions triggered.

17. Recipients of personal data

Depending on the respective processing, data may be passed to the following categories of recipients:

  • STRATO as the website's hosting provider and Ernst Systems' email provider;
  • ActiveCampaign for the waitlist and email delivery;
  • Metricool for website statistics, only after consent;
  • Apple for the App Store, operating system and push services;
  • Cloudflare for secure update delivery and encrypted dashboard transfer;
  • AI providers selected by the user, such as Google or Anthropic;
  • providers of the programs and services the user connects, directly from the user's Mac;
  • Tailscale for the encrypted connection between iPhone or iPad and Mac;
  • Hugging Face when downloading the local speech models;
  • providers of public news, weather and exchange rate data;
  • tax advisers, payment providers or authorities where required for contracts or legal obligations;
  • communication providers when contact is made by email, phone or WhatsApp.

Orena content is not sold by Ernst Systems to advertising networks or data brokers.

18. International data transfers

Some providers, in particular Apple, Google, Anthropic, Cloudflare, Tailscale, Hugging Face, many of the connected programs and communication services, may process data outside Germany, the European Union, Canada or the respective country of residence.

Where Ernst Systems itself is responsible for such a transfer, the safeguards provided by law are used, for example adequacy decisions, recognised data protection frameworks or standard contractual clauses.

For customer-owned accounts and API access, the purchaser decides on provider, region and contract configuration. The purchaser must conclude the agreements required for their use themselves.

19. Retention and deletion

Ernst Systems only stores personal data for as long as it is required for the respective purpose or due to legal obligations.

For Orena, the following applies in particular:

  • chats, reminders and other content: locally until deleted by the user or until an intended local retention period expires;
  • temporary analysis and working files: generally until the task is completed;
  • local caches on iPhone and iPad: until deletion, unpairing or complete local data deletion;
  • local security logs: usually no longer than 365 days, unless longer retention is required to investigate a specific security incident;
  • local backups: according to the backup schedule set by the user, until deleted by the user;
  • server and update logs: only as long as necessary for operation, security and legal evidence;
  • contract and invoice documents: in accordance with statutory retention periods.

20. Export and deletion

Orena offers functions for exporting and locally deleting the data stored by the user.

An export may include, in particular, chat histories, tasks, settings and other local usage data. For security reasons, secret credentials, API keys, authentication tokens, keychain contents, backups and internal security files are not included in a normal data export.

A complete local deletion removes the affected Orena data on the connected Mac and in the app on iPhone and iPad. Data previously transmitted to a customer-owned AI, cloud or communication provider may also need to be deleted with the respective provider.

Since Ernst Systems does not hold the local Orena content, Ernst Systems cannot view, export or delete it remotely.

21. Security

Orena uses technical and organisational security measures, in particular local storage, credentials in the Mac's keychain, encrypted device connections, pairing protection, encrypted backups, end-to-end encrypted dashboard transfer and signed updates.

No technical system can guarantee absolute security. Users must adequately protect their devices, operating systems, passwords, API keys and cloud accounts and install available security updates.

22. Rights in Germany and the European Union

Data subjects have, provided the legal requirements are met, in particular the right to:

  • access;
  • rectification;
  • erasure;
  • restriction of processing;
  • data portability;
  • object to processing based on legitimate interests;
  • withdraw consent with effect for the future;
  • lodge a complaint with a data protection supervisory authority.

Requests can be sent to privacy@ernst-systems.com. To prevent unauthorised disclosure, reasonable proof of identity may be requested.

The competent authority is generally:

The State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg
https://www.baden-wuerttemberg.datenschutz.de/

23. Rights in Canada

Where Canadian privacy law applies, the principles of PIPEDA and, where applicable, the privacy laws of Alberta, British Columbia or Quebec apply in particular.

Data subjects may in particular:

  • request access to personal data held by Ernst Systems;
  • request information about its purpose, use and disclosure;
  • have inaccurate or incomplete data corrected;
  • withdraw consent with effect for the future, unless legal or contractual reasons prevent this;
  • file a privacy complaint.

Requests are processed within the statutory time limits. Complaints may also be directed to the Office of the Privacy Commissioner of Canada or the competent privacy authority of the respective province.

For cross-border matters, both PIPEDA and a provincial law may apply.

24. Rights in the USA

Where a US state privacy law applies to Ernst Systems, residents of that state may in particular have the right:

  • to know which personal data is collected, used or disclosed;
  • to request access or a copy;
  • to have inaccurate data corrected;
  • to have data deleted;
  • to object to certain processing;
  • to opt out of the sale, sharing for behavioural advertising or certain profiling;
  • to appeal a refusal;
  • not to be discriminated against for exercising their privacy rights.

Ernst Systems does not sell personal data and does not share it for cross-context behavioural advertising.

Requests can be sent to privacy@ernst-systems.com. Where provided for by law, an authorised agent may be used. Reasonable verification of identity or authority may take place before a request is processed.

25. Minors

Orena is not specifically directed at children. Minors may only use Orena if this is permitted under applicable law and, where required, with the consent or supervision of a parent or guardian.

Ernst Systems does not knowingly sell or share personal data of minors for advertising.

26. Obligation to provide data

Certain technical data is required to provide the website, app connection, updates or a contract. Other information and permissions are voluntary.

Anyone who does not enable cloud AI, microphone, location, contacts or phone functions can continue to use Orena within the remaining scope of functions. The respective additional function will then not be available or only to a limited extent.

27. Changes to this policy

This privacy policy may be updated if Orena, the service providers used or legal requirements change.

Material changes will be indicated in the app or on the website. Where new consent is required, it will be obtained separately. The currently valid version can be identified by its date and version number.