PRIVACY POLICY

Avalw Vision

Effective Date: March 15, 2026 | Last Updated: March 15, 2026

This Privacy Policy describes how Avalw Vision ("we," "us," "our," or the "App") collects, uses, and protects information when you use our mobile application. Avalw Vision is operated by Avalw ("Company"), and this policy applies to all users of the App worldwide.

By downloading, installing, or using Avalw Vision, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, please do not use the App.

1. INFORMATION WE COLLECT

1.1 Information You Provide

When you use Avalw Vision, you may provide the following types of content for analysis:

• URLs: Web addresses of privacy policies or terms of service pages you wish to scan.
• Text: Pasted text content from documents you wish to analyze.
• Photos: Images of printed documents selected from your device's photo library for OCR (Optical Character Recognition) processing.
• PDF Documents: PDF files imported from your device for text extraction and analysis.

All content you provide is processed locally on your device. It is never uploaded to our servers or any third-party service for analysis.

1.2 Information We Do NOT Collect

Avalw Vision does not collect any of the following:

• Device identifiers or advertising IDs
• IP addresses or geolocation data
• Usage analytics or behavioral data
• Crash reports or diagnostics (beyond what Apple collects through the App Store, subject to your device settings)
• Cookies, pixels, or tracking technologies
• Biometric data
• Contact lists, calendars, or other personal data
• Browsing history or app usage patterns

1.3 Purchase Information

If you subscribe to Avalw Vision Premium, your purchase is processed entirely by Apple through the App Store. We do not receive, process, or store your payment information, credit card details, or Apple ID credentials. We only receive a confirmation of your subscription status through Apple's StoreKit framework to unlock premium features.

2. HOW WE USE INFORMATION

3. ON-DEVICE PROCESSING

Avalw Vision's core functionality operates entirely on your device using Apple's native frameworks:

• Vision Framework: Used for OCR to extract text from photos of documents. No data is sent to external OCR services.
• PDFKit: Used for extracting text content from PDF files locally on your device.
• Natural Language Framework: Used for automatic language detection of scanned documents.
• StoreKit 2: Used for managing in-app purchases and subscriptions through Apple's secure payment infrastructure.

The only network requests the App makes are:

1. Fetching web pages: When you provide a URL to scan, the App downloads the HTML content of that specific page to your device for local analysis. This is a direct request from your device to the website you specified — no intermediary server is involved.
2. App Store transactions: Subscription purchases and verification are handled by Apple's StoreKit framework.

No data is sent to any Avalw server, third-party API, or external AI/ML service. The App contains no server-side component for document analysis.

4. DATA STORAGE AND SECURITY

4.1 Local Storage

All data is stored locally on your device in the following locations:

• Vault (Documents Directory): Your scan history and analysis results are stored as JSON files in the App's sandboxed Documents directory, protected by iOS data protection.
• Preferences (UserDefaults): Your language selection and onboarding status.
• Keychain: Your free scan usage counter is stored in the iOS Keychain, which provides hardware-level encryption. This data persists across app reinstallations to prevent abuse of the free tier. It contains only a numeric value.
• App Group Container: Temporary data shared between the main App and the Share Extension through a secure App Group container. This data is ephemeral and automatically cleaned up within minutes.

4.2 No Remote Storage

We do not operate servers that store your data. There is no cloud database, no remote backup, and no server-side processing of your scanned documents. Your data exists solely on your device.

4.3 Security Measures

• All local data is protected by iOS App Sandbox isolation.
• The Keychain uses hardware-backed encryption (Secure Enclave where available).
• The App does not implement custom networking beyond standard HTTPS requests to user-specified URLs.
• No user accounts or authentication credentials are collected or stored.
• The App does not use any custom encryption — it relies on iOS platform security.

5. THIRD-PARTY SERVICES

Avalw Vision uses NO third-party SDKs, analytics services, or advertising frameworks. Specifically, the App does not integrate:

• Google Analytics, Firebase, or any Google services
• Facebook/Meta SDK or tracking pixels
• Amplitude, Mixpanel, Segment, or any analytics platforms
• Crashlytics, Sentry, or any crash reporting tools
• Any advertising networks or ad mediation platforms
• Any third-party AI or machine learning APIs
• Any social media SDKs
• Any fingerprinting or device identification libraries

The only third-party service interaction is with Apple's App Store for processing in-app purchases, which is governed by Apple's Privacy Policy.

6. DATA SHARING AND DISCLOSURE

We do not sell, rent, trade, license, or otherwise share your personal data with any third party for any purpose.

Since we do not collect your data on our servers, there is no data to share.

We may disclose information only if required by law, regulation, legal process, or governmental request, though this is exceptionally unlikely given that we do not possess your data.

We do not participate in any data broker networks or data exchanges.

7. YOUR RIGHTS AND CHOICES

7.1 Data Control

You have complete control over your data at all times:

• Delete Individual Scans: Remove any scan result from your Vault at any time.
• Delete All Data: Use the "Delete All Scans" option in Settings to permanently remove all stored analysis data.
• Uninstall: Deleting the App removes all locally stored data (Vault, preferences, alerts). Note that the Keychain entry for scan count persists per Apple's design; this contains only a numeric counter, not personal data.
• Language: Change your display language at any time in Settings.

7.2 Permissions

The App may request the following device permissions:

• Photo Library (Read-Only): Required only if you choose to scan a photo of a document. You can revoke this permission at any time in your device's Settings. The App uses Apple's PhotosPicker, which provides scoped access only to photos you explicitly select.

You are never required to grant any permission. The App functions fully with URL and text input alone.

7.3 Rights Under GDPR (EU/EEA Users)

If you are located in the European Economic Area, you have the right to:

• Access the personal data we hold about you (we hold none on our servers)
• Request rectification or erasure of your data
• Object to or restrict processing of your data
• Data portability
• Withdraw consent at any time
• Lodge a complaint with your local Data Protection Authority

Since all data processing occurs locally on your device and we do not collect or store personal data on our servers, these rights are inherently fulfilled by the App's architecture. The legal basis for any on-device processing is your explicit consent (by choosing to scan a document) and the performance of the contract (providing the service you requested).

7.4 Rights Under CCPA/CPRA (California Users)

California residents have the right to:

• Know what personal information is collected (we collect none on our servers)
• Request deletion of personal information
• Opt out of the sale or sharing of personal information (we do not sell or share any data)
• Non-discrimination for exercising privacy rights
• Correct inaccurate personal information
• Limit the use of sensitive personal information (we do not process sensitive personal information)

7.5 Rights Under LGPD (Brazilian Users)

Users in Brazil have similar rights under the Lei Geral de Proteção de Dados, including access, correction, anonymization, deletion, portability, and information about sharing. Our privacy-first architecture ensures these rights are respected by design.

7.6 Rights Under PIPA (South Korean Users)

Users in South Korea have rights under the Personal Information Protection Act, including notification of data collection purposes, access, correction, suspension of processing, and deletion. Since no personal data is collected on our servers, these rights are inherently satisfied.

7.7 Rights Under APPI (Japanese Users)

Users in Japan have rights under the Act on the Protection of Personal Information. We comply with APPI requirements through our privacy-by-design approach.

8. CHILDREN'S PRIVACY

Avalw Vision is not directed at children under the age of 13 (or 16 in the EU/EEA, or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. Since the App does not collect personal information from any user on our servers, no special risk exists.

If you believe a child has used the App in a way that concerns you, please contact us at office@avalw.com.

9. INTERNATIONAL USERS

Avalw Vision is available worldwide and supports 32 languages. Since all data processing occurs locally on your device, no cross-border data transfers take place. Your data remains on your device in your jurisdiction at all times.

This means:

• No data is transferred to servers in other countries
• No Standard Contractual Clauses or adequacy decisions are needed
• Your data is subject only to the device security of your own phone or tablet

10. DATA RETENTION

Since we do not collect data on our servers, there is no server-side data retention.

On your device:

• Scan Results: Stored until you delete them or uninstall the App.
• Alerts: Stored until cleared or the App is uninstalled.
• Preferences: Stored until the App is uninstalled.
• Scan Counter (Keychain): Persists across reinstallation. Contains only a numeric value (e.g., "3"), not personal data.
• Share Extension Data: Automatically expires after 5 minutes.

11. SHARE EXTENSION

Avalw Vision includes a Share Extension that allows you to scan privacy policies directly from Safari or other apps. When you use the Share Extension:

• The shared URL or text is temporarily stored in a secure App Group container on your device.
• The data is passed to the main App for local analysis.
• Temporary data is automatically cleaned up and has a validity window of 5 minutes.
• No data from the Share Extension is transmitted to any server.

12. DO NOT TRACK

Avalw Vision honors Do Not Track signals by design. The App does not track users in any way, regardless of browser or device settings. There are no analytics, no tracking pixels, no fingerprinting, and no behavioral profiling.

13. AUTOMATED DECISION-MAKING

The App performs automated analysis of privacy policies and terms of service to generate privacy scores, identify dangerous clauses, and detect data collection practices. This analysis:

• Is performed entirely on your device
• Is provided for informational purposes only
• Does not constitute legal advice
• Does not affect your legal rights or obligations
• Can be reviewed and interpreted by you at any time

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Updating the "Last Updated" date at the top of this document
• Posting the updated policy at vision.avalw.ai/privacy

We encourage you to review this Privacy Policy periodically. Continued use of the App after changes constitutes acceptance of the updated policy.

15. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email: office@avalw.com
Website: https://vision.avalw.ai

For GDPR-related inquiries, you may also contact your local Data Protection Authority.