Privacy Policy

Last updated: March 5, 2026

This Privacy Policy applies to Avalw Shield for macOS and Windows ("the App"), developed and published by Avalw SRL ("Avalw", "we", "us", "our"), a company registered in Romania.

At Avalw, your privacy is not just a feature — it is the foundation of everything we build. This Privacy Policy describes in detail how Avalw Shield collects, uses, stores, and protects your information across all supported platforms.

1. Definitions

For the purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, as defined by applicable data protection laws including the GDPR.
• "Biometric Data" means data resulting from specific technical processing relating to the physical characteristics of a natural person, including facial geometry and recognition data.
• "Processing" means any operation performed on data, whether automated or not, such as collection, recording, storage, adaptation, retrieval, use, disclosure, or erasure.
• "Device" means the Mac or Windows computer on which the App is installed.
• "Face Embedding" means a mathematical vector representation derived from facial features, used solely for recognition purposes.

2. Data Controller

The data controller for any information processing associated with the App is:

However, because Avalw Shield processes all data exclusively on your device and transmits no data to Avalw or any third party, Avalw does not act as a data controller in the traditional sense under the GDPR. You, the user, maintain full and exclusive control over all data processed by the App.

3. Data We Collect

We collect no personal data whatsoever. Avalw Shield does not collect, store, transmit, or share any personal information, biometric data, usage data, device identifiers, IP addresses, location data, or telemetry of any kind.

3.1 Data NOT Collected

To be explicit, the following data is never collected, stored on our servers, or transmitted:

Data Type	Collected?
Name, email, phone number	No
Camera images or video	No
Face embeddings or biometric data	No (stored locally only)
Device identifiers (UDID, serial number)	No
IP address	No
Location data	No
Usage analytics or telemetry	No
Crash reports	No
Browsing or app usage history	No
Advertising identifiers	No
Keystroke or input data	No
Screen content or screenshots	No

4. Camera Data

Avalw Shield requires access to your device's camera (built-in or external) to provide face detection, face recognition, and shoulder detection features. Camera data is handled with the following strict safeguards:

• Real-time processing only: Camera frames are processed in volatile memory (RAM) and immediately discarded after each processing cycle. No frames are ever written to disk, saved to a file, or stored in any persistent format.
• Zero retention policy: On macOS, each frame is processed within an autoreleasepool that guarantees immediate memory deallocation. On Windows, equivalent memory management ensures no camera data persists between processing cycles.
• No recording or capture: The App never records video, captures screenshots, creates image files, or stores camera footage in any format (JPEG, PNG, HEIC, MP4, or otherwise).
• No transmission: Camera data is never sent over any network interface — not to Avalw servers, not to Apple or Microsoft servers, not to any third party, and not to any local network device.
• No display: The camera feed is never rendered on screen. Unlike video conferencing apps, the App processes camera data entirely in the background without displaying it.
• Hardware LED indicator: On Mac, the hardware-controlled camera LED is active whenever the camera is in use and cannot be disabled by software. This provides a visible, tamper-proof indicator of camera activity.

5. Face Recognition Data

During the enrollment process, Avalw Shield creates mathematical representations (embeddings) of your facial features. These embeddings are numerical vectors used solely for face matching and cannot be used to reconstruct, generate, or approximate an image of your face.

5.1 Storage

• macOS: Face embeddings are stored exclusively in the macOS Keychain, which provides hardware-backed encryption using the Secure Enclave (on supported Mac models) or software encryption.
• Windows: Face embeddings are stored in the Windows Credential Manager with encryption provided by the Data Protection API (DPAPI), tied to your Windows user account.

5.2 Properties of Face Embeddings

• Non-reversible: It is mathematically infeasible to reconstruct a face image from the stored embedding vectors.
• Non-transferable: Embeddings are encrypted and tied to your device's keychain/credential store. They cannot be exported, copied, or transferred to another device.
• Never transmitted: Face embeddings never leave your device — not to Avalw, not to Apple, not to Microsoft, not to any third party.
• User-deletable: You can delete all enrolled face data at any time from the App's Settings. Deletion is immediate and irreversible.

5.3 Adaptive Enrollment

Avalw Shield may update stored face embeddings over time as it recognizes you successfully (adaptive enrollment). This process occurs entirely on-device, uses the same secure storage, and is subject to the same privacy protections described above. Adaptive enrollment helps the App adapt to changes in your appearance such as new glasses, hairstyles, or lighting conditions.

6. On-Device Processing

All face detection, recognition, matching, and shoulder detection is performed entirely on your device using proprietary AI models bundled with the App. No cloud-based AI, no remote API calls, and no server-side processing is involved at any point. The App functions fully without an internet connection.

7. Network Usage

Avalw Shield makes zero network connections for its core functionality. The only network activity occurs for:

• In-App Purchases (macOS): Processing subscriptions and purchases through Apple's StoreKit framework. All payment processing is handled entirely by Apple. Avalw never sees, processes, or stores your payment information, Apple ID, or transaction details.
• In-App Purchases (Windows): Processing subscriptions and purchases through the Microsoft Store commerce platform. All payment processing is handled entirely by Microsoft. Avalw never sees, processes, or stores your payment information or Microsoft account details.

No other network connections are made. The App does not connect to Avalw servers, analytics services, CDNs, advertising networks, or any other remote service. You can verify this using network monitoring tools such as Activity Monitor (macOS), Little Snitch, Lulu, or Wireshark.

8. Third-Party Services and SDKs

Avalw Shield does not integrate, bundle, or communicate with any third-party services, including but not limited to:

• Analytics platforms (Google Analytics, Mixpanel, Amplitude, etc.)
• Crash reporting services (Crashlytics, Sentry, Bugsnag, etc.)
• Advertising networks or demand-side platforms
• Attribution or tracking SDKs
• Social media SDKs
• Cloud storage providers (AWS, Google Cloud, Azure, etc.)
• Remote configuration services (Firebase Remote Config, LaunchDarkly, etc.)

The only external frameworks used are Apple's StoreKit (macOS) and Microsoft Store APIs (Windows) for processing in-app purchases.

9. Data Sharing and Disclosure

We do not sell, rent, lease, trade, license, or share any data with any third party. Because we collect no data, there is no data to share. Specifically:

• We do not sell personal information to data brokers or advertisers.
• We do not share data with business partners, affiliates, or parent companies.
• We do not provide data to government agencies or law enforcement (as we have no data to provide).
• We do not use data for profiling, targeted advertising, or behavioral analysis.

10. Cookies and Tracking

Avalw Shield does not use cookies, web beacons, pixel tags, local storage, or any other tracking technologies. The App does not track your behavior, usage patterns, or interactions in any way.

11. Children's Privacy

Avalw Shield does not knowingly collect, store, or process data from children under 13 (or under 16 in jurisdictions where the GDPR applies). The App does not collect data from users of any age. Face recognition accuracy may be reduced for users under 13 as facial features are still developing. If you believe a child has provided personal information to Avalw (though this should not be possible given our architecture), contact us immediately at office@avalw.com.

12. Data Security

Although we collect no data on our servers, we implement comprehensive security measures to protect the data processed locally on your device:

12.1 Encryption

• Face embeddings encrypted in macOS Keychain with hardware-backed protection (Secure Enclave where available)
• Face embeddings encrypted via Windows DPAPI tied to user credentials
• All local data at rest is encrypted using platform-native encryption

12.2 Memory Security

• Zero camera data retention — immediate memory cleanup after each processing cycle
• Autoreleasepool-based memory management on macOS prevents data lingering in RAM
• No temporary files, caches, or swap files containing camera data

12.3 Application Security

• Software integrity verification (code signature validation) to detect tampering
• Code signing through Apple's Developer Program (macOS) and Microsoft's code signing (Windows)
• App Sandbox isolation on macOS limits access to system resources
• Screen capture protection — App windows are protected against screenshots and screen recording by third parties
• Anti-spoofing measures including liveness detection (eye-open verification)
• Lockout mechanism after 5 failed face recognition attempts, requiring system password

12.4 Distribution Security

• Distributed exclusively through the Apple App Store and Microsoft Store
• Both stores perform security reviews before publishing updates
• Binary integrity verified through platform code signing

13. Your Rights

Since Avalw does not collect personal data on any server, traditional data subject rights (access, rectification, portability, restriction) do not apply in the conventional sense. However, you retain full control over all data on your device:

13.1 Right to Delete

• Delete your enrolled face data at any time from the App's Settings
• Uninstall the App to remove all associated local data

13.2 Right to Restrict Processing

• Revoke camera permission at any time through System Settings (macOS) or Windows Settings
• Disable the App at any time — no residual processing occurs when the App is disabled

13.3 Right to Information

• This Privacy Policy provides complete transparency about all data practices
• The App provides a "Security & Trust" section where you can verify all claims
• You can independently verify our privacy claims using network monitoring tools

13.4 Right to Object

• You may stop using the App at any time by disabling or uninstalling it
• No data persists after uninstallation beyond what is managed by the OS keychain

14. International Data Transfers

Avalw Shield does not transfer any data internationally because it does not transfer any data at all. All processing occurs exclusively on your local device. There are no cross-border data flows associated with the use of this App.

15. GDPR Compliance (European Economic Area)

For users in the European Economic Area (EEA), the United Kingdom, and Switzerland:

• Avalw Shield is GDPR-compliant by design and by default (Privacy by Design, Article 25 GDPR).
• No personal data is collected, processed, or stored on Avalw's servers, making traditional GDPR obligations regarding data controllers largely inapplicable.
• Biometric data (face embeddings) is processed exclusively on your device under your sole control, pursuant to Article 9(2)(a) GDPR (explicit consent given during enrollment).
• Data Protection Impact Assessment (DPIA): Given the on-device-only architecture, the risk to data subjects is minimal. No high-risk processing as defined by Article 35 GDPR occurs.
• No Data Protection Officer (DPO) appointment is required given the nature of our processing activities.

16. California Privacy Rights (CCPA/CPRA)

For California residents under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Avalw does not sell, share, or disclose personal information as defined by the CCPA/CPRA.
• Avalw does not collect personal information from California consumers.
• There is no data to disclose, delete, correct, or opt out of selling/sharing.
• Avalw does not use sensitive personal information for purposes beyond what is reasonably necessary.
• Avalw does not engage in cross-context behavioral advertising.

17. Brazilian Data Protection (LGPD)

For users in Brazil: Avalw Shield complies with the Lei Geral de Proteção de Dados (LGPD). No personal data is collected, processed, or transferred to Avalw's servers. All biometric processing occurs locally on your device.

18. Data Retention

Avalw does not retain any data on its servers because it does not collect any data. Locally on your device:

• Camera frames: Retained for zero seconds — processed and immediately discarded.
• Face embeddings: Retained until you delete them from Settings or uninstall the App.
• App preferences: Retained locally (UserDefaults on macOS, Registry on Windows) until App uninstallation.

19. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or App functionality. When we make material changes:

• We will update the "Last updated" date at the top of this policy.
• We will notify users through the App for significant changes.
• The updated policy will be published at shield.avalw.ai/privacy.

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

20. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, contact us:

We will respond to all privacy-related inquiries within 30 days. If you are located in the EEA and are not satisfied with our response, you have the right to lodge a complaint with your local Data Protection Authority.