PONORA

Guidance on Lawful Audio Recording

Information for Users of Ponora Recording Devices and Services

As of: 31 August 2026

Ponora International GmbH · Hammfelddamm 4 A · 41460 Neuss · Germany

This Guidance is intended to help users create, process, share and delete audio recordings with Ponora responsibly and lawfully. It supplements Ponora’s General Terms and Conditions and Privacy Policy.

Which rules apply depend in particular on the country, the place of recording, the relationship between the parties involved, the context of the conversation and the subsequent purpose of use.

In Germany, section 201 StGB protects the confidentiality of the non-publicly spoken word. The unauthorised recording of the non-publicly spoken word may be a criminal offence. The provision also covers, in particular, the unauthorised use or disclosure of a recording made in this way.

Before starting a recording, you should check in particular:

• Are all people informed that an audio recording is being made?
• Is the recording lawful under the applicable law and—where necessary—is valid consent in place?
• Was the purpose of the recording clearly explained, for example logging, transcription or summary?
• Do the participants know if the recording is uploaded to the Ponora cloud and processed with transcription or AI functions?
• Is the conversation likely to contain particularly sensitive information, such as health data, political opinions, religious beliefs or other special categories of personal data?
• Is a recording really necessary, or would a less intrusive alternative, such as written notes, be sufficient?

During the recording, make sure that everyone involved can recognise at all times that recording is taking place. If a person withdraws their consent or no longer wishes the recording to continue, stop or pause it to the extent required by law.

Do not make secret recordings in situations in which the participants may reasonably expect confidentiality, particularly confidential meetings, consultations, personnel discussions or private conversations.

The admissibility of the recording does not automatically mean that any subsequent use is permissible. Before sharing, exporting, publishing or otherwise making available, check again whether there is a sufficient legal basis for this.

• Share recordings, transcripts, and summaries only with people who need them for the intended purpose.
• Check whether transcripts or AI summaries contain confidential or personal information.
• Do not publish the content of conversations without first considering possible personal rights, data protection rights, duties of confidentiality and copyright.
• Delete recordings and derivative content if they are no longer necessary for the intended purpose or if deletion is required for other reasons.
• Please note that confirmation of the recording notice in the app covers only recordings started via the phone or app. Recordings started directly via the device button offline are not covered by it; responsibility for informing the participants lies entirely with you.

Audio recordings and transcripts, summaries or notes generated from them may contain personal data. Depending on the content, special categories of personal data may also be affected.

Anyone using Ponora for business or professional purposes must, in particular, determine their role under data protection law, the legal basis for the processing, the applicable information duties and how data-subject rights will be fulfilled.

Further information about processing by Ponora can be found in the Ponora Privacy Policy. This information does not replace the user’s own data protection assessment or any data processing agreement that may be required.

In many everyday situations, a brief, clear notice before recording begins can be useful. Whether additional express consent is required depends on the applicable law and the specific context.

If a person objects to the recording or does not give the required consent, you should not begin the recording, or should stop it. Instead, consider whether an alternative form of documentation is possible, such as handwritten notes or minutes agreed afterwards.

Ponora provides technical tools for recording, transcription, summarisation, translation, export and sharing. Ponora cannot assess whether a specific recording is permissible in your individual situation. Users therefore remain responsible for reviewing and complying with the statutory, contractual and professional requirements applicable to their use. Please also note: content shared via a sharing link can be accessed without a Ponora account and expires only if you set an expiry date or an access limit; Ponora recommends additionally protecting shares with a password.

Regardless of this, Ponora fulfills its own data protection obligations in accordance with the applicable laws and the Ponora Privacy Policy.

Questions about Ponora or the processing of personal data can be directed to:

Ponora International GmbH · Hammfelddamm 4 A · 41460 Neuss · Germany

Email: support@ponora.ai

As of: 31 August 2026