Privacy Policy

Effective date: November 1, 2025

Data Controller: OfflinAI Ltd., 2 Stockwell, Sandyford Road, Dublin 16, Ireland (referred to as"OfflinAI", "we", "us", or "our"). OfflinAI is the organization that determines how and why your personal data is processed (the “data controller”). We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR) and other applicable data privacy laws.

This Privacy Policy explains how we collect, use, and protect information when you use the OfflinAI Windows application (the “App”) and when you visit our website (the “Site”). It covers data collected within the App (which extends Microsoft’s AI Dev Gallery and runs AI agents locally) and data collected through our website. We aim to use clear and plain language so you can easily understand our practices. If you have any questions or concerns, please contact us using the details in the “Contact Us” section below.

1. Data Collection and Use in the OfflinAI Application (Windows App)

No User Content Leaves Your Device. OfflinAI is designed with privacy in mind. The App does not send your prompts, chat history, AI outputs, or any content you create to OfflinAI servers or any cloud service. All AI processing and data storage happen locally on your Windows device. This means you maintain full control over your data; OfflinAI cannot access your conversations or files used in the App because they never leave your machine.

No Personal Information Required. We do not require you to create an account or provide personal details to use the App. OfflinAI does not collect any personally identifiable information (PII) through the App. There is no sign-in, and we do not collect things like your name, address, email, or payment information via the App.

Anonymized Usage Statistics. To improve the App’s functionality and user experience, OfflinAI may collect limited, anonymized usage data about how the App is used. This may include information such as which features or tools you use and how often, performance metrics, and timestamps of usage. These analytics are aggregated and do not contain any PII, so they cannot be traced back to you personally. We use this information solely to understand feature popularity and to guide future improvements. For example, knowing that a certain feature is used frequently by many users helps us prioritize updates. The legal basis for processing this usage data is our legitimate interest in improving our product and ensuring it meets users’ needs.

Crash and Diagnostic Data. OfflinAI strives to provide a stable, error-free experience. If the App crashes or encounters an error, it may generate a diagnostic report or log. With the help of Microsoft’s developer tools/APIs, the App can send us anonymous crash reports and error logs. These reports typically include technical information like error codes, device model, operating system version, and timestamps. Importantly, they do not include your content, chat text, or any personal data. We receive this diagnostic data to identify what went wrong in the App and to fix bugs or compatibility issues. This processing is based on our legitimate interest in maintaining a reliable and secure application. Crash and error data is used only for debugging and improving the App’s stability – not for marketing or profiling.

No Third-Party Tracking in the App. Aside from the crash analytics mentioned above, the App does not contain third-party analytics SDKs, ads, or tracking tools that collect your information. We do not send any data to advertisers or data brokers. All core functionality (including AI model processing via Microsoft’s AI Agent Framework and Ollama integration) runs offline on your device, using local resources. This ensures that your data remains private and under your control at all times. Even when the App uses Microsoft’s AI frameworks, these run locally; no AI queries or outputs are sent to Microsoft or OfflinAI’s servers.

2. Data Collection and Use on the OfflinAI Website

When you visit OfflinAI’s website (offlinai.com), we collect only a minimal amount of data, as detailed below. You can browse most of our Site without telling us who you are. We do not require account creation or registration for our website.

Cookies and Analytics. Our Site uses cookies and similar tracking technologies for analytics and user experience purposes. In particular, we utilize Google Analytics and Microsoft Clarity to understand how visitors use our Site and to help improve it over time. These tools may set cookies in your browser to collect usage information. The types of data collected may include:

Usage Information. Which pages on our Site you visit, how you navigate those pages, your clicks and scrolling behavior, time spent on each page, and referring page/URL (i.e., how you arrived at our Site). This helps us analyze what content is most interesting to visitors and how our site is being used.

Device and Technical Data. Information about your device and browser, such as browser type/version, operating system, screen resolution, and network provider. This helps us ensure the Site works well on different devices.

Approximate Location. Google Analytics provides us with general geographic regions of visitors (e.g. city or country) based on IP address, which helps us understand our global audience. However, we have enabled IP anonymization for Google Analytics, meaning your IP address is truncated/anonymized before being used or stored by Google. This prevents your precise identity or location from being determined.

Session Replays and Heatmaps. Microsoft Clarity may record anonymized interactions on our Site – for example, it can create “session replay” videos showing how an anonymous user scrolled or clicked on our pages, and heatmaps showing where users tend to click. This behavioral data helps us improve our website’s design and usability. Clarity might capture mouse movements, clicks, and page interaction information, but it does not capture sensitive fields (like passwords) and we do not use it to identify individual users. All such data is reviewed in aggregate.

We use the insights from Google Analytics and Microsoft Clarity to improve our website – for example, to optimize navigation or page layouts based on what parts of the site are most popular or where users might get confused. This constitutes a legitimate interest in understanding and enhancing user experience. However, because these tools involve placing non-essential cookies, we will only activate them with your consent.

Cookie Consent and Opt-Out. When you first visit our Site from the EU or other regions with similar laws, you will see a cookie notice or banner. We do not set analytics cookies until you explicitly allow them. You have the choice to accept or decline non-essential cookies (like those used for Google Analytics and Clarity). If you opt out or decline, our Site will still function; you just won’t be included in our analytics data. Even after accepting, you can always adjust your browser settings to delete or block cookies. For example, you can delete existing cookies and set your browser to refuse cookies from our Site or all sites.

Additionally, Google provides an opt-out browser add-on that you can install to prevent Google Analytics from collecting data on any website you visit. You can find it on Google’s website (the “Google Analytics Opt-out Add-on”). Using this tool will exclude your visits from Google Analytics measurement on our Site and others.

Please note that our Site’s essential cookies (if any) – those needed for core functionality – will operate regardless of analytics consent. For example, if we use a cookie to remember your cookie preferences, that is considered necessary. Our use of Microsoft Clarity also respects your consent choice; without consent, Clarity will not record your session.

No Profile Building or Ads. OfflinAI does not use the data from Google Analytics or Clarity to serve targeted ads, and we do not allow advertising networks to collect data through our Site. The information collected via analytics is used in aggregate form for our internal analysis and website optimization. We do not sell or rent any usage data to third parties. For more details on how Google and Microsoft handle the data they collect on our behalf, you can review the Google Privacy Policy and [Microsoft Privacy Statement】, respectively.

No Account or Login Information. Our website does not have user accounts or logins. We will not ask you to register or provide personal details just to browse information about OfflinAI. As a result, we do not collect usernames, passwords, or profile information through the Site.

Email Newsletter Subscriptions (Optional). On our website, you may have the option to subscribe to our newsletter or updates by providing your email address (for example, by entering your email in a subscription form and clicking “Subscribe”). This is entirely voluntary and requires your consent – we will explicitly ask for your email and consent before adding you to any mailing list. If you choose to subscribe, we will collect and use your email address solely for the following purposes:

Sending News and Updates. We will use your email to send you OfflinAI-related communications such as newsletters, product announcements, updates about new features, or occasional marketing/promotional emails about OfflinAI’s services. These emails are intended to keep you informed about what we’re working on and how you can get the most out of OfflinAI.

Administration of Subscription. We may also send emails to confirm your subscription or to allow you to verify your email (double opt-in), and to facilitate unsubscribe requests or changes to your subscription preferences.

We will never sell or share your email address with third-party marketers. If we use an email service provider to send out the newsletter (for example, a platform like MailChimp, SendGrid, or similar), that provider will act under our instructions and only use your email for OfflinAI’s communications. We ensure any such service provider is GDPR-compliant and will protect your data.

Unsubscribing. You have the right to withdraw your consent and unsubscribe from our emails at any time. Every marketing or newsletter email we send will include an “unsubscribe” link at the bottom. By clicking that, you can remove yourself from the mailing list. You can also contact us directly (see “Contact Us” below) to request removal. Once you unsubscribe, we will stop sending you newsletter/marketing emails. (Please note it might take a few days to process an unsubscribe request, but we will do so as quickly as possible.) Withdrawing consent does not affect the lawfulness of any emails we sent you before your withdrawal; it only stops future communications.

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4. Data Sharing and International Transfers

No Selling of Data. OfflinAI does not sell, rent, or trade your personal information to third parties for their own marketing or any other purposes. We understand that your data is yours, and we treat it with confidentiality.

Service Providers. We may share data with a few trusted third-party service providers (processors) who help us run our operations – only to the extent necessary for them to provide their services to us. Examples include:

Email Service Provider. If we use a third-party platform to send newsletters (e.g., a mailing service), your email address would be stored with and transmitted through that provider for the sole purpose of sending you OfflinAI communications. Such providers are contractually obligated to protect your data and not to use it for anything other than delivering our emails.

Analytics Services. As described, we use Google Analytics and Microsoft Clarity on our Site. These involve sending usage data to Google and Microsoft systems. Google and Microsoft act as data processors for us, meaning they are only allowed to use the data to provide analytics information back to us, and they must protect the data under their agreements. We have accepted Data Processing Addendums with these providers where applicable, which include Standard Contractual Clauses for data transfers (see below).

Microsoft App Platforms. The OfflinAI Windows App is distributed via the Microsoft Store. Microsoft may collect certain information (such as crash reports, device info) through their platform and developer APIs which they then share with us (as described in the App section). Microsoft is bound by its own privacy policies and developer terms to handle this data appropriately. OfflinAI only uses that information to debug and improve the App.

All third-party service providers acting on our behalf are subject to data protection agreements and must comply with high standards of security and confidentiality. They cannot use your personal data for their own purposes or share it further without authorization.

Legal Disclosures. We may disclose information about you if we are compelled to do so by law or legal process, or if we have a good-faith belief that such disclosure is necessary to (for example) investigate fraud, respond to a government request, protect our rights, or protect the safety of users or the public. We will only do this when permitted by data protection law. Where possible and lawful, we would inform you of such requests.

International Transfers. OfflinAI is based in Ireland, but we have a global user base and some of our service providers are located in other countries. Whenever we transfer personal data out of the European Economic Area (EEA), we take steps to ensure it remains protected. For instance, data collected via Google Analytics may be transferred to Google’s servers in the United States. In such cases, we rely on mechanisms such as the European Commission’s Standard Contractual Clauses (SCCs) or other approved measures to ensure an adequate level of protection for the data. Both Google and Microsoft have committed to complying with GDPR when handling EU data, and they implement safeguards like encryption and pseudonymization.

We will also monitor developments in data transfer law (such as the EU–U.S. Data Privacy Framework) and adjust our practices if needed to stay compliant. If you’d like more information about the safeguards for international transfer of your data, feel free to contact us.

In summary, any third party receiving personal data from us will only get the minimum necessary data, and only for the specific purpose we’ve contracted them for. We remain responsible for protecting your data in these contexts.

5. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. Because OfflinAI’s data collection is limited, our retention practices are as follows:

  • App Usage Data: Anonymous usage analytics from the App (e.g. feature usage frequency) are typically collected in aggregate form. We may keep aggregated data indefinitely since it contains no personal identifiers and is used for long-term trend analysis. However, any raw diagnostic logs or detailed telemetry from the App are either not stored at all on our end (in many cases we only see aggregated metrics), or if stored, are kept only as long as needed to analyze and resolve performance issues. For example, crash logs stored in Microsoft’s App Center or Dev Portal may be retained for a certain period (e.g., 1 year) for troubleshooting and then automatically deleted. We do not keep identifiable app usage logs perpetually.
  • Crash Reports. Crash and error reports received via Microsoft’s systems are used to fix bugs and improve stability. We generally will not retain identifiable crash report data longer than 12 months. Often, once an issue is fixed, the relevant crash log is archived or deleted. We rely on Microsoft’s retention settings for crash data as well; for instance, if Microsoft automatically purges crash data after a set time, we adhere to that. All crash reports are technical in nature and contain no personal content, so they are typically safe to store, but we still do not keep them longer than necessary.
  • Website Analytics Data. ata collected through Google Analytics is retained by Google for a default period which we have set to 14 months for user-level and event-level data associated with cookies and other identifiers. This means any analytics data linked to a cookie or user ID will be automatically deleted by Google after ~14 months. We have configured our Google Analytics to not retain data longer than this. Aggregate statistics (which no longer have personal identifiers) may be kept longer than 14 months, as Google allows retention of aggregated reports without user-level data. Microsoft Clarity’s session recordings and related data are retained for a much shorter period – as of now, Clarity recordings are kept for up to 30 days (unless we mark certain sessions to keep longer for analysis) and aggregated Clarity insights (like heatmaps) are retained up to 13 months. After these periods, the data is deleted from those systems and is no longer available to us. In any case, since our analytics data is anonymized, retention is mainly a technical consideration, but we do not keep it longer than necessary.
  • Email Addresses: If you subscribe to our mailing list, we will retain your email address for as long as you remain subscribed. We periodically clean our email list, and if emails bounce repeatedly or appear inactive over a long time, we may remove them to be respectful. If you choose to unsubscribe or ask us to delete your email, we will promptly remove you from the active mailing list. We may, however, retain a suppression list of emails that have unsubscribed or opted out, to ensure we do not accidentally send you further emails – this is a standard practice to honor opt-outs. Such a list would be used only for that compliance purpose. If you want your email completely erased from our records, we will do so (unless preventing us from emailing you again is itself a legal requirement, in which case we’d inform you).
  • Legal and Backup Retention: In certain cases, we might need to retain data for longer if required by law or for legitimate business purposes. For example, if there’s an ongoing dispute or we are required to keep records for regulatory compliance, we will keep the necessary data until that purpose is resolved. We also maintain secure backups of our systems; any personal data in backups will be deleted as those backups cycle out, and all backups are protected. We will not keep personal data in backups beyond the retention period needed (except that it may persist until the backup is overwritten with new data, in which case it remains protected in the meantime).

After the applicable retention period expires, we will securely delete or anonymize your personal data. For physical deletion, we use industry-standard practices to erase or destroy data such that it cannot be recovered. For anonymization, we remove personally identifying elements so the data can be used for statistical purposes without identifying you.

6. Your Rights Under GDPR and Other Privacy Laws

As a user of OfflinAI (especially if you are in the European Union or a similar jurisdiction), you have certain rights regarding your personal data. We are committed to upholding these rights. Below is a summary of your key data subject rights:

  • Right to Access: You have the right to request a copy of the personal data we hold about you, and to obtain information about how we process it. This is commonly known as a Subject Access Request. We will provide you with a copy of your data in a readable format, usually within one month of your request (unless an extension is permitted by law). Access is provided free of charge, but if you request additional copies or the request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse (with an explanation).
  • Right to Rectification: If you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. For example, if you had provided an email address and it has changed, you can ask us to update to the new address. We will make the corrections as soon as possible.
  • Right to Erasure: You have the right to request deletion of your personal data in certain circumstances. This “right to be forgotten” means we must erase your data if: the data is no longer necessary for the purpose we collected it, you withdraw consent (and no other legal basis applies), you object to processing and we have no overriding legitimate interest, or we are required to delete it to comply with law. Note that this right is not absolute – for instance, if we must keep certain data to comply with a legal obligation or to establish/exercise legal claims, we may refuse deletion for that purpose. We will inform you of the reason if any data cannot be deleted. In practice, because OfflinAI collects minimal personal data, erasure would typically involve removing your email from our systems and deleting any associated records.
  • Right to Restrict Processing: You have the right to ask us to limit or “pause” the processing of your personal data under certain conditions. For example, you can request restriction if you contest the accuracy of your data (while we verify it), or if you object to our processing and we are considering that objection. During restriction, we will store your data but not actively use it. We’ll notify you before any restricted processing is resumed.
  • Right to Object: You have the right to object to our processing of your personal data in certain situations. You can always object to processing for direct marketing – for example, if we were sending marketing emails beyond what you signed up for, you can opt-out, and we will stop. You can also object when we base processing on legitimate interests (or public interest) and you have a specific reason to object based on your particular situation. In such cases, we will stop processing your data unless we have compelling legitimate grounds that override your rights or if we need to continue processing for legal claims. We have tried to outline above where we rely on legitimate interests (improving the app, etc.); know that you always have the right to object to those uses. Practically, if you object to, say, our collection of anonymized app usage data, you might choose not to use the app telemetry features (or disable them, if an option is provided in-app) – and you can always contact us to discuss any concerns.
  • Right to Data Portability: For any data that you have provided to us and which we process by automated means under consent or for the performance of a contract, you have the right to request that we give you that data in a structured, commonly used, machine-readable format, or to transmit it directly to another data controller where technically feasible. This right primarily applies to data you actively provided (e.g., if in the future you gave us some profile info or similar – which currently we do not collect). In the context of OfflinAI, this right might not have much application since we don’t have user accounts or extensive provided data. However, if you want a copy of, say, the emails you exchanged with us or any data you sent, we will provide it in a simple format. If in future OfflinAI offers a service where you upload data, we will ensure portability rights can be honored for those uploads.
  • Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This typically applies to things like our newsletter or analytics cookies. As described earlier, you can unsubscribe from emails or opt out of analytics, and we will cease the processing going forward. Withdrawal of consent does not affect the legality of processing done before you withdrew.
  • Right to Lodge a Complaint: We want to resolve any concerns you have directly, but you also have the right to complain to a Data Protection Supervisory Authority if you believe we have violated your rights or GDPR. Since OfflinAI is based in Ireland, our lead supervisory authority is the Irish Data Protection Commission (DPC). You can contact the DPC via their website (www.dataprotection.ie) or by other means. If you reside in another country, you may prefer to contact your local authority; for example, in the EU you can complain to the authority in your country of residence, and they will coordinate with the DPC. This right exists in addition to any other administrative or judicial remedies you might have. We would appreciate the chance to address your concerns first, but you are absolutely entitled to go to a regulator.
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We will do our best to facilitate your rights. To exercise any of the above rights, please contact us (see “Contact Us” below). We may need to verify your identity for security purposes before fulfilling your request (for example, to ensure that someone else isn’t trying to steal your data rights). We will respond to requests without undue delay, and within one month at the latest, although we may extend that deadline by up to two further months for particularly complex or multiple requests (we will inform you if an extension is needed and why). There is generally no fee for exercising your rights, but as noted, a reasonable fee could be charged or a request refused if it’s repetitive or manifestly unfounded/excessive, per GDPR guidelines.

No Fee Usually Required. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). We do not believe in charging for these basic rights. The only exception could be if a request is repetitive or excessive, in which case GDPR allows a fee or refusal – but we have never had to do this, and we will aim to honor your requests free of charge.

7. Data Security Measures

OfflinAI takes data security seriously. We have implemented various technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These include:

Secure Infrastructure. Any personal data we do hold (such as email addresses for newsletters) is stored on secure servers with up-to-date security measures. We use encryption where appropriate and ensure proper access controls. Only authorized personnel at OfflinAI or our processors (who are bound by confidentiality) can access data as needed for their job functions.

Local Processing Reduces Risk. Because our App processes all your content locally and doesn’t transmit it to our servers, certain security risks (like data interception or breaches on our server) are greatly minimized. In other words, we’ve architected the product in a way that inherently protects your data privacy. Your own device holds the data, so our responsibility is to ensure we never pull that data off the device without your knowledge. We also encourage you to keep your device’s operating system and OfflinAI App updated to the latest versions, to benefit from the latest security improvements.

Encryption. Our website is served exclusively over HTTPS, which means data transmitted between your browser and our site is encrypted in transit (to prevent eavesdropping). If we ever handle sensitive info, we would also encrypt it at rest. While your use of the OfflinAI App is offline, if the App ever connects for updates (model downloads, etc.), we utilize secure protocols.

Best Practices and Testing. We regularly review our practices and keep up with industry best practices for cybersecurity. Our team tests the App and Site for vulnerabilities and promptly installs security patches on our systems. We also limit the amount of data we collect in the first place (data minimization), which is a key security principle – what’s not collected can’t be stolen or misused.

Third-Party Security. When using third-party services (Microsoft, Google, email senders), we choose reputable providers known for strong security, and we ensure they commit to protecting data (for example, Microsoft and Google have robust security for their cloud services). We also enable additional protections like two-factor authentication on accounts that have access to personal data.

Despite all this, it’s important to note that no system can be 100% secure. We cannot guarantee absolute security of data, especially any data transmitted over the internet. However, we strive to protect information to the best of our ability. You also play a role: we advise that you use a secure network when using our Site (beware of insecure public Wi-Fi), and protect your devices with good practices (e.g., using strong passwords or PINs, and not sharing your device with untrusted individuals). If you believe your interaction with OfflinAI or your data might be compromised (for example, if you suspect a vulnerability), please notify us immediately so we can investigate and fix it.

In the unfortunate event of a data breach that affects your personal data, OfflinAI will follow all applicable breach notification laws. This means we would notify the relevant supervisory authority, and if required, notify you as well, especially if the breach poses a high risk to your rights and freedoms. We hope to never have such an incident, but we have a response plan in place just in case.

8. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time. As our product and website evolve or as privacy regulations change, we might need to adjust our practices. If we make material changes, we will let you know by posting the updated Policy on our website and adjusting the “Effective Date” at the top. For significant changes, we may also provide a more prominent notice (such as a banner on our Site or a notification in the App) so that you are informed. We encourage you to review this Policy periodically to stay informed about how we are protecting your data.

Rest assured, we will not reduce your rights under this Privacy Policy without your consent. Any changes will comply with applicable privacy laws. If you continue to use OfflinAI after a Privacy Policy update, it will signify acceptance of the revised terms (to the extent permitted by law). For major changes that require your consent, we will seek consent accordingly.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact us. We are here to help and we take your privacy inquiries seriously. You can reach us in the following ways:

  • Email: privacy@offlinai.com
  • Mail: Privacy Officer, OfflinAI Ltd., 2 Stockwell, Sandyford Road, Dublin 16, Ireland

OfflinAI Ltd. is the data controller responsible for the processing of personal data described in this Policy. When you contact us, we may ask you to verify your identity before addressing your request, to ensure we protect personal data from unauthorized access. For example, if you email asking for deletion of data, we need to be sure it’s really you.

We will endeavor to respond to all legitimate requests as quickly as possible, and certainly within any timeframes required by law. If you have made a request and haven’t heard back in a reasonable time, please feel free to send a reminder – it’s never our intention to ignore any privacy-related request.

Thank you for trusting OfflinAI. Your privacy is central to our values, and we will continue working hard to keep your information safe and secure. We appreciate you taking the time to read this Privacy Policy. If anything is unclear, let us know – we welcome feedback on how to make our explanations even more accessible.