Privacy Policy

1. Introduction

This Privacy Policy describes how AVALW SRL ("AVALW," "we," "us," or "our"), a company registered in Romania, handles information in connection with the Avalw Vision mobile application ("App" or "Avalw Vision") and our related website (collectively, the "Service").

We are committed to protecting your privacy and being transparent about our data practices. This Privacy Policy applies to all users of Avalw Vision, regardless of where they are located. We designed Avalw Vision with a privacy-first architecture, meaning the App functions without collecting or transmitting your personal data.

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

2. Company Information

The data controller for the purposes of applicable data protection laws is:

• Company Name: AVALW SRL
• Jurisdiction: Romania, European Union
• Contact Email: office@avalw.com

3. Information We Do NOT Collect

Avalw Vision is designed from the ground up to protect your privacy. We want to be explicitly clear about what we do not do:

• No Personal Data Collection: We do not collect your name, email address, phone number, mailing address, or any other personally identifiable information.
• No Account Required: You do not need to create an account, register, or sign in to use Avalw Vision. There are no usernames, passwords, or profiles.
• No Document Storage: Documents, text, and images you scan or input are processed entirely on your device. We never transmit, upload, copy, or store your documents on any server.
• No Analytics or Tracking: We do not use any analytics SDKs, tracking pixels, session recording tools, or any other technology to monitor your behavior within the App.
• No Usage Data: We do not collect data about how you use the App, including which features you use, how often you use them, session duration, or navigation patterns.
• No Device Information: We do not collect your device model, operating system version, unique device identifiers, IP address, mobile network information, or any other technical data about your device.
• No Location Data: We do not collect, access, or store your geographic location, whether precise (GPS) or approximate (network-based).
• No Advertising: The App contains no advertisements. We do not use advertising identifiers (IDFA/GAID), and we do not participate in any advertising networks or data exchanges.
• No Cookies or Tracking Technologies: The App does not use cookies, web beacons, pixel tags, or similar tracking technologies.
• No Contact List Access: We do not access, read, or collect your contacts or address book.
• No Social Media Integration: The App does not connect to any social media platforms and does not collect any social media data.
• No Third-Party Data Sharing: Since we collect no data, there is no data to share, sell, rent, or disclose to any third party.

4. How the App Works

Avalw Vision is designed to analyze documents (privacy policies, contracts, terms of service, and similar legal documents) to help you understand what you are agreeing to. Here is how the App processes information:

4.1 On-Device Processing

All document analysis is performed locally on your device using on-device processing capabilities. When you scan a document or input text:

1. The text is extracted and processed entirely within the App on your device.
2. The analysis algorithms run locally, using your device's processing power.
3. Results are displayed to you directly within the App.
4. No data is transmitted to our servers or any third-party servers during this process.
5. Once you close the analysis or leave the screen, processed data is discarded from memory.

4.2 No Servers

AVALW SRL does not operate, maintain, or use any servers for the purpose of processing, storing, or transmitting user data in connection with Avalw Vision. The App is fully self-contained, and all functionality is delivered on-device.

5. Device Permissions

Avalw Vision may request access to certain device features. Below is a transparent explanation of each permission:

5.1 Camera Permission

The App requests camera access for two specific purposes:

• Document Scanning: To capture images of physical documents for text extraction and analysis. The camera feed is processed in real-time on your device. Individual camera frames are never stored, saved, cached, or transmitted outside the App.
• QR Code Scanning: To scan QR codes that may link to online privacy policies or terms of service. The camera feed is used solely for QR code detection. Frames are processed in real-time in memory and immediately discarded. No images are retained.

You can deny camera access and still use the App by manually pasting text for analysis. Camera access can be revoked at any time through your device's Settings.

5.2 Photo Library (Optional)

If offered, photo library access allows you to select an existing image of a document for analysis. Selected images are processed on-device and are not stored, copied, or transmitted by the App. Access to your photo library can be revoked at any time through your device's Settings.

5.3 Internet Access

The App may use an internet connection for the following limited purposes:

• Subscription Validation: To verify your subscription status through Apple's App Store infrastructure.
• QR Code URLs: If you scan a QR code containing a URL, the App may fetch the content at that URL so you can analyze it. This request is made directly from your device; it does not pass through our servers.

No personal data, documents, or analysis results are transmitted over the internet by the App.

6. Subscriptions and Payments

Avalw Vision offers optional subscription plans that are processed entirely through Apple's App Store. We want to be clear about how payment data is handled:

• All purchases and subscriptions are managed by Apple through the App Store.
• We never receive, access, process, or store your payment information, credit card numbers, billing address, or any other financial data.
• Apple handles all payment processing, billing, receipts, and refunds in accordance with their own privacy policy and terms.
• We may receive anonymized, aggregated sales data from Apple (such as total number of subscriptions or revenue) that cannot be used to identify individual users.

For information about how Apple handles your payment data, please review Apple's Privacy Policy.

7. Children's Privacy

Avalw Vision does not knowingly collect personal information from children under the age of 13 (or the applicable age of consent in your jurisdiction). Since we do not collect personal data from any user, this protection extends to all users regardless of age.

The App does not:

• Require age verification (as no data is collected).
• Contain content directed at children under 13.
• Include any social or interactive features that could expose children to risks.
• Display advertisements of any kind.
• Collect, use, or disclose personal information from any user, including children.

Parents and guardians can feel confident that the App poses no data privacy risk to their children, as no data collection mechanisms exist within the App.

If you are a parent or guardian and believe that your child has somehow provided personal information to us, please contact us at office@avalw.com, and we will investigate and take any necessary action.

8. GDPR Compliance (European Economic Area)

As a company registered in Romania, a member state of the European Union, AVALW SRL is subject to and fully compliant with the General Data Protection Regulation (EU) 2016/679 ("GDPR"). Since Avalw Vision does not collect, process, or store any personal data, most GDPR provisions regarding data processing do not apply. However, we address key GDPR principles below for transparency:

8.1 Legal Basis for Processing

Since we do not process personal data, there is no legal basis required. However, if any incidental data processing were to occur (such as temporary in-memory processing during document scanning), the legal basis would be:

• Legitimate Interest (Article 6(1)(f)): Processing document text in memory to provide the analysis service you requested.
• Consent (Article 6(1)(a)): You provide explicit consent by choosing to scan or input a document for analysis.

8.2 Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data. While we do not hold any personal data, we respect and acknowledge these rights:

• Right of Access (Article 15): You have the right to request confirmation of whether we process your personal data. We confirm that we do not.
• Right to Rectification (Article 16): You have the right to correct inaccurate personal data. Since we hold no data, there is nothing to correct.
• Right to Erasure (Article 17): You have the right to request deletion of your personal data. Since we store no data, uninstalling the App removes all locally stored preferences.
• Right to Restrict Processing (Article 18): You have the right to restrict processing. As we do not process personal data, this right is inherently fulfilled.
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured format. Since we hold no data, there is nothing to export.
• Right to Object (Article 21): You have the right to object to processing. As no processing occurs, this right is inherently respected.
• Right Not to Be Subject to Automated Decision-Making (Article 22): The App's analysis is a tool to assist your understanding. It does not make automated decisions that produce legal effects concerning you.

To exercise any of these rights, or if you have questions about GDPR compliance, please contact us at office@avalw.com.

8.3 Data Protection Officer

Given that we do not process personal data on any meaningful scale, we have not appointed a formal Data Protection Officer. However, all privacy inquiries can be directed to office@avalw.com and will be handled promptly and in accordance with GDPR requirements.

8.4 International Data Transfers

Since we do not collect or transmit any personal data, no international data transfers occur. All data processing happens locally on your device, within whatever jurisdiction you are physically located in.

9. CCPA Compliance (California Residents)

The California Consumer Privacy Act ("CCPA") and its amendment, the California Privacy Rights Act ("CPRA"), grant California residents specific rights regarding their personal information. Although Avalw Vision does not collect personal information as defined by the CCPA, we provide the following disclosures for transparency:

9.1 Categories of Personal Information

In the preceding 12 months, we have not collected, sold, shared, or disclosed any categories of personal information from any consumer, including California residents.

Category	Collected	Sold / Shared
Identifiers (name, email, etc.)	No	No
Personal information per Cal. Civ. Code 1798.80(e)	No	No
Protected classification characteristics	No	No
Commercial information	No	No
Biometric information	No	No
Internet or network activity	No	No
Geolocation data	No	No
Sensory data (audio, visual, etc.)	No	No
Professional or employment information	No	No
Education information	No	No
Inferences drawn from personal information	No	No
Sensitive personal information	No	No

9.2 Your Rights Under CCPA/CPRA

As a California resident, you have the following rights:

• Right to Know: You have the right to request that we disclose what personal information we collect, use, and disclose. We confirm that we collect none.
• Right to Delete: You have the right to request deletion of personal information. Since we collect no data, uninstalling the App fulfills this right.
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information as defined by the CCPA/CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
• Right to Correct: You have the right to correct inaccurate personal information. We hold no such data.
• Right to Limit Use of Sensitive Information: We do not collect sensitive personal information.

To exercise any of these rights, contact us at office@avalw.com.

10. Other International Privacy Laws

10.1 UK Data Protection Act 2018

For users in the United Kingdom, the UK Data Protection Act 2018 and the UK GDPR grant you similar rights to those described in Section 8 above. Since we do not collect personal data, these rights are inherently respected.

10.2 Brazil LGPD

For users in Brazil, the Lei Geral de Proteção de Dados (LGPD) grants you rights regarding your personal data. Since Avalw Vision collects no personal data, your rights under the LGPD are inherently fulfilled.

10.3 Canada PIPEDA

For users in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies. Since we do not collect, use, or disclose personal information, we comply with PIPEDA's principles by design.

10.4 Australia Privacy Act 1988

For users in Australia, the Privacy Act 1988 and the Australian Privacy Principles (APPs) apply. Since we do not collect personal information, we comply with these requirements by design.

11. Data Security

Even though we do not collect or store personal data on our servers, we take the security of our App seriously:

• On-Device Security: The App relies on the security features provided by Apple's iOS and iPadOS platforms, including the secure enclave, data protection classes, and App sandboxing.
• No Data at Rest: Since the App does not store documents or analysis results permanently, there is no data at rest to be compromised.
• No Data in Transit: Since the App does not transmit personal data, there is no data in transit to be intercepted.
• Regular Updates: We regularly update the App to address any potential security vulnerabilities and to ensure compatibility with the latest security features of the operating system.
• Secure Development: We follow industry best practices for secure software development, including code reviews and security testing.

12. Third-Party Services

Avalw Vision integrates with the following third-party services:

12.1 Apple App Store

The App is distributed through Apple's App Store. Apple may collect data in accordance with their privacy policy when you download or update the App. In-app purchases and subscriptions are processed by Apple. We recommend reviewing Apple's Privacy Policy for details.

12.2 No Other Third-Party SDKs

13. Data Retention

Since we do not collect personal data, there is no data retention policy required. However, for clarity:

• Scanned Documents: Processed in memory only, discarded immediately after analysis. Not saved to disk.
• Analysis Results: Displayed to you in the App. Not stored permanently unless you explicitly choose to save or share them using your device's built-in functionality.
• App Preferences: Minimal, non-personal settings (such as display preferences) may be stored locally on your device using Apple's standard storage mechanisms. This data is removed when you uninstall the App.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through one or more of the following methods:

• Posting the updated Privacy Policy on our website with a new "Last Updated" date.
• Providing notice within the App.
• Updating the App Store listing description.

We encourage you to periodically review this Privacy Policy for any changes. Your continued use of the App after the posting of changes constitutes your acceptance of such changes.

If we ever change our data practices to collect personal data (which we currently have no plans to do), we will provide you with clear notice and obtain any required consent before implementing such changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, our data practices, or your rights, please contact us at:

• Email: office@avalw.com
• Company: AVALW SRL
• Jurisdiction: Romania, European Union

We will respond to all privacy-related inquiries within 30 days, or sooner as required by applicable law.

16. Supervisory Authority

If you are located in the European Economic Area and believe that we have violated your data protection rights, you have the right to lodge a complaint with a supervisory authority. The lead supervisory authority for AVALW SRL is:

17. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Romania, without regard to its conflict of law provisions, and in accordance with the GDPR for users in the European Economic Area.