Privacy policy

1. Controller

Andre Andorfer, Andorfer Webdesign
Mozartstr. 11, 94060 Pocking, Germany
Phone: +49 8531 1387471
Email: kollaboration@andorfer-webdesign.de

No data protection officer has been appointed, as there is no legal obligation to do so.

2. This website

Hosting

The website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit, Vercel processes technically necessary data (server log files): IP address, date and time, page requested, amount of data transferred, referrer, browser and operating system, for secure and stable delivery (Art. 6(1)(f) GDPR). A data processing agreement is in place with Vercel. Transfers to the USA are based on the EU-US Data Privacy Framework, supplemented by the EU Standard Contractual Clauses. Logs are deleted automatically after a short time.

No cookies, no analytics, no third-party content

We use no cookies, no analytics or advertising services and no embedded third-party content. Nothing is stored on or read from your device beyond what is strictly necessary to display the page (Section 25 TDDDG). Fonts and images are served from the same server as the page.

Downloading the app

The download button leads to GitHub (GitHub B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands; parent company GitHub Inc., USA), where the installer is stored. GitHub processes your IP address and technical data under its own privacy statement.

Contact by email or phone

If you write to or call us, we process your details to handle your request (Art. 6(1)(b) GDPR for questions about a contract or use, otherwise (f)) and delete them once the matter is closed and no retention obligations apply.

3. The AVALON app: what stays on your device

Memory, conversations, knowledge store including uploaded documents, reminders, lists, calendar entries, settings and access to your devices are stored only locally on your PC or AVALON device. There is no user account and no usage statistics; we do not receive this data.

• Voiceprint (optional): if you switch it on, AVALON stores a numeric pattern of your voice locally to tell you apart from guests. Recordings are not stored. As a biometric feature it is processed only with your explicit consent (Art. 9(2)(a) GDPR) and never leaves your device. You can delete it at any time in the settings.
• Windows Hello: for unlocking, AVALON uses the Windows sign-in. Windows checks face, fingerprint or PIN itself; AVALON only receives “confirmed” or “not confirmed”.
• Text recognition: scanned documents and photos of documents are read directly on your device (Windows text recognition or Tesseract) without being sent anywhere.
• Sensitive details (for example about health, finances, religion, politics, sexuality or origin) are deliberately not remembered permanently.

In the settings you can download everything as a file (data export) and delete it completely.

4. Online AI for open questions

Commands such as timers, lists, weather, appointments or switching devices are handled by AVALON itself without an AI provider. For open questions AVALON uses a language model: either the local language model on your PC (then nothing leaves your device) or an online AI. With an online AI, your question, the conversation so far and the matching excerpts from memory and knowledge store are sent encrypted to the provider so it can answer (Art. 6(1)(b) GDPR). There are three routes:

4.1 Start: free online allowance via AVALON

In the free Start edition, AVALON provides a small daily online allowance. Your request goes via our access service at Cloudflare, Inc. (USA) to one of the following providers, which we use in their free tier; when one provider’s allowance is used up, the next takes over:

• Cerebras Systems Inc. (USA)
• Google LLC / Google Ireland Ltd., Gemini API (free tier)
• OpenRouter Inc. (USA), which forwards the request to the provider of a free model

Important: in these free tiers, providers may store and analyse requests under their own terms, for example to improve their models; at Google, humans may review content. Do not enter very personal information there. You can switch off the free online allowance at any time under “Settings” → “Edition” → “Free for longer”; AVALON then answers with your own accounts or the local language model. Transfers to the USA are based on the EU-US Data Privacy Framework where the provider is certified.

To share the allowance fairly, our access service only stores daily counters: for a random ID of your installation and for a non-reversible fingerprint of your internet connection (derived from the IP address or its network range and a secret value; the IP address itself is not stored). It does not store the content of your requests. The counters are deleted after a few days (Art. 6(1)(f) GDPR, abuse prevention).

4.2 Your own accounts (optional)

You can add your own free or paid accounts, for example with Groq Inc. (USA), Cerebras Systems Inc. (USA), Google (Gemini API), OpenRouter Inc. (USA), OpenAI or Anthropic PBC (USA). Your request then goes directly from your device to that provider, not via us. You are that provider’s customer, and its terms apply, including on analysing requests in free tiers. The keys are stored only on your device.

4.3 AVALON Plus and AVALON Gold

With the paid editions, answers, speech recognition and voice run via our access service (Cloudflare, Inc., USA), using these providers as processors or under their business terms: language model and speech recognition: Groq Inc. (USA), with Google’s Gemini API (Google Ireland Ltd.) in the paid tier as a reserve, where Google does not use requests to improve its products; AVALON Gold main answers: Anthropic PBC (USA); voice: Microsoft Azure Speech (Germany West Central), for AVALON Gold the natural voice of ElevenLabs Inc. (USA). For your access code the service stores only edition, status, term, monthly usage counters and the resulting costs, not the content of your requests. Short, frequent standard voice sentences without digits (“Done.”, “Timer is running.”) are cached as audio for at most 30 days. Transfers to the USA are based on the EU-US Data Privacy Framework or the EU Standard Contractual Clauses.

We do not use your requests to train our own AI models.

5. Speech, voice and phone

• Speech recognition in the desktop app: on your PC (Whisper, offline package) or via your edition or own account (see section 4).
• Speech recognition in the browser: if you use AVALON in Chrome, Edge or Safari, AVALON may use the browser’s speech recognition; the browser then sends your recording to its maker (Google, Microsoft or Apple). In the settings you can choose recognition via AVALON instead.
• Voice: on your PC (Piper voices or your device’s voice) or via your edition (section 4.3).
• Phone: a paired phone connects directly to your PC on your home Wi-Fi. If you switch on “Also reachable on the go”, your phone’s requests travel encrypted via our relay at Cloudflare, Inc. (USA) to your PC. The relay only passes them on and stores just a checksum of your PC’s secret, no content and no logs.

6. Mailbox, calendar and smart home

• Mailbox and calendar: direct connection to your own mail and calendar provider; credentials stay on your device. Emails are only sent with your explicit approval; AVALON does not follow instructions contained in emails.
• Devices on your home network (for example Philips Hue, Shelly, IKEA, Sonos, Govee, Nanoleaf, LG TVs, FRITZ!Box, Matter devices) are controlled directly on your network, not via us. When setting up new Matter devices via Bluetooth, AVALON passes your Wi-Fi password only to the device and does not store it.
• Tuya and Smart Life: for setup, AVALON retrieves your device list with device keys once from the Tuya cloud via your own Tuya developer project (data centre of your choice). After that, AVALON controls the devices directly on your home network. Tuya’s terms apply.
• Home Assistant: direct connection to your own installation.

7. Public services without an account

For some questions AVALON queries public services without sending data from your memory: weather from Open-Meteo (Switzerland) with the place you ask about; place search via Nominatim of the OpenStreetMap Foundation (UK) and travel times via the OSRM project; research via DuckDuckGo and Bing (Microsoft) with your search query, Wikipedia (Wikimedia Foundation) and Tagesschau news. Your exact location is used only with your consent and only on your device.

8. Updates and downloads

The app regularly checks andorfer-webdesign.de for a new version; files are stored at GitHub. Add-on packages (local language model, voices, speech recognition, thesaurus) are downloaded on request from GitHub or Hugging Face. IP address and app version are transmitted technically, but no content from AVALON.

9. The AVALON device

On the AVALON device (touch display) everything above applies accordingly: data is stored on the device’s memory card, Wi-Fi is set up on the device itself, and there is no remote access for us and no data transfer to us.

10. Retention

Data on your device stays until you delete it. At the access service: daily counters of the free allowance for a few days; data on Plus and Gold codes for the duration of the contract and afterwards as required by law; cached standard voice sentences for at most 30 days. Online AI providers store requests under their own terms.

11. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future. Most data is on your device only, so you can view, export and delete it there; for anything else, just email us. You may also lodge a complaint with a data protection authority, for example the Bavarian Data Protection Authority (BayLDA), Promenade 18, 91522 Ansbach, Germany.

12. Artificial intelligence

AVALON is an AI assistant. Answers are generated automatically and may be wrong or incomplete; check important information, especially on health, law and money. AVALON makes no automated decisions with legal effect within the meaning of Art. 22 GDPR.