IWV Digital Solutions

Privacy Policy

Applies to the NotesXML application and the IWV Chat AI application.


Publisher	IWV Digital Solutions LLC
Products Covered	NotesXML (all platforms); IWV Chat AI (all platforms)
Effective	May 28, 2026
Version	1.7
Document	https://iwvdigitalsolutions.com/legal/privacy
Contact	legal@iwvdigitalsolutions.com
Jurisdiction	State of California, United States

1. Introduction

IWV Digital Solutions LLC ("IWV Digital Solutions," "we," "our," or "us") operates two software applications covered by this Privacy Policy:

NotesXML ("NotesXML"), a productivity and note-taking application available on Android (Google Play Store), Windows (Microsoft Store), and as a direct download for desktop platforms.
IWV Chat AI ("IWV Chat"), a free, offline AI assistant application available on Android (Google Play Store), Windows (Microsoft Store), and as a direct download for desktop platforms.

"The App" or "the Apps" refers to either or both applications, as context requires. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and the rights you have regarding your information for both applications.

Both Apps are designed around a local-first, privacy-first architecture. The data you create or process within either App — your notebook content in NotesXML; your chat conversations, voice recordings, and AI inputs in IWV Chat — is stored locally on your device by default and is never transmitted to IWV Digital Solutions servers. This is a binding technical commitment, not merely a marketing claim.

By downloading, installing, or using either App, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Apps.

1.1 IWV Chat AI: Specific Privacy Commitments

IWV Chat AI is a separate application from NotesXML and operates under additional, stronger privacy commitments specific to its design as a free offline AI assistant:

No accounts. IWV Chat AI does not require an account, sign-up, login, or user profile. The App does not know who you are.
No license keys, no payment. IWV Chat AI is permanently free of charge. The App does not transmit license keys, purchase tokens, or any payment information to IWV Digital Solutions or to third parties.
No analytics, no telemetry. IWV Chat AI contains no analytics SDKs, no crash reporting services, no usage tracking, and no advertising infrastructure. The App does not transmit usage metrics, performance metrics, error reports, or any behavioral data.
No advertising. IWV Chat AI is permanently ad-free. There are no banner ads, interstitials, sponsored suggestions, or advertising identifiers.
No cloud sync. IWV Chat AI does not synchronize conversation data to any cloud provider. Conversations are stored exclusively in standard JSON files on your local device.
No conversation transmission. Your chat messages, the AI's responses, your voice recordings, and any images you submit for AI Vision analysis remain on your device. They are not transmitted to IWV Digital Solutions or to any third party at any time during normal operation.

The only network activity IWV Chat AI generates during normal use is described in Section 4.4 below.

2. Data Controller Identity


Legal Entity	IWV Digital Solutions LLC
State	California Limited Liability Company
Address	c/o Northwest Registered Agent 2108 N St Ste N, Sacramento, CA 95816 United States
Privacy Email	legal@iwvdigitalsolutions.com
Support Email	support@iwvdigitalsolutions.com
Website	https://iwvdigitalsolutions.com
Privacy Page	https://iwvdigitalsolutions.com/legal/privacy

3. Zero-Exposure Protocol: Your Notebook Data

NotesXML implements a Zero-Exposure Protocol for your notebook data. Specifically:

Your notebook data (notes, notebooks, pages, drawings, audio recordings, contact records, calendar events, task lists, images, and all other content you create in the App) is stored exclusively on your local device in the NotesXML NXL file format.
IWV Digital Solutions does not operate any servers that receive, store, process, or have access to your notebook data.
IWV Digital Solutions does not have the technical capability to access your notebook data, even if compelled by legal process, because we do not receive or store it.
Cloud synchronization (Google Drive, Dropbox) is an optional, user-initiated feature that transfers your data directly between your device and your own personal cloud storage account. IWV Digital Solutions does not have access to your cloud storage credentials or your cloud-stored files.

This Zero-Exposure Protocol applies to all platforms and all versions of NotesXML.

3.1 NotesXML Ad-Free Commitment

NotesXML contains no advertising of any kind in any tier (Free, Trial, Professional, Academic, Beta, or VIP) and on any platform (Android, Windows, Linux, Web). Specifically, NotesXML:

Contains no advertising SDKs, including but not limited to Google AdMob, Meta Audience Network, Unity Ads, AppLovin, ironSource, or any other mobile advertising network.
Does not collect or transmit advertising identifiers, including the Google Advertising ID (GAID) on Android or the Identifier for Advertisers (IDFA) on Apple platforms.
Does not engage in ad tracking, behavioural profiling for advertising purposes, or sharing of personal data with advertising partners.
Does not contain banner ads, interstitial ads, video ads, native ads, or sponsored content of any form.

This commitment is binding. The Google Play Data Safety Form for NotesXML reflects zero ad-related data collection. The Microsoft Store Privacy Statement for NotesXML reflects the same. Any future change to this commitment would require a new app version, an updated Privacy Policy, an updated Data Safety Form, and explicit user consent prior to taking effect.

4. Information We Collect

We collect the minimum information necessary to provide the App and its services. We do not sell your personal information.

4.1 Information You Provide Directly

License Key Purchase (Direct Sales)

When you purchase a Professional or Academic license directly from iwvdigitalsolutions.com, we collect:

Email address (for license key delivery and customer support)
Payment information (processed by Stripe; IWV Digital Solutions does not store full payment card numbers)
License key record (key identifier, license type, issue date, activation count)
For Academic licenses: educational institution email address (.edu) for verification

License Key Activation

When you activate a license key in the App, the App transmits your license key and a platform identifier to our verification server to confirm its validity. We record the activation count associated with your key. We do not collect device identifiers or link your key to identifiable hardware beyond what is inherent in the platform identifier (e.g., "android" or "desktop").

Beta Waitlist

If you sign up for the NotesXML Beta Program through the IWV Digital Solutions website, we collect your email address for the sole purpose of sending you beta access communications and notifications about the Beta program. You may unsubscribe from beta communications at any time using the unsubscribe link in any email we send. We do not use beta waitlist email addresses for unrelated marketing purposes.

Support Communications

If you contact us at support@iwvdigitalsolutions.com or legal@iwvdigitalsolutions.com, we collect the information you include in your message, including your email address. We use this to respond to your inquiry.

4.2 Information Collected Automatically by the App

Audio Recordings (Audio Notes)

If you use the Audio Notes feature, the App records audio from your device's microphone. Audio data is stored locally in your NXL file. IWV Digital Solutions does not receive your audio recordings.

Crash Reports and Diagnostic Data

The App may generate diagnostic logs stored locally on your device. Log files are sanitized to remove file names and personal identifiers. These logs are never transmitted automatically. If you choose to submit a bug report, you may optionally share these sanitized logs with us.

App Activity (Analytics)

NotesXML does not currently implement analytics. If analytics are added in a future version, this Privacy Policy will be updated before that version is released, and the analytics system will be clearly disclosed in the App.

4.3 Information Collected by Third-Party Services

Google Play Store (Android)

If you download NotesXML from Google Play, Google collects information in accordance with its own privacy policy, including purchase history for paid licenses and subscriptions. IWV Digital Solutions receives aggregate anonymized statistics from the Play Console (install counts, crash rates). We do not receive personally identifiable information from Google about individual users unless you contact us directly.

Google Play Billing

Subscription ($4.99/month), annual ($29.99/year), and lifetime license ($49.99) purchases on Android are processed by Google Play Billing. Your payment information is handled by Google. We receive a purchase token confirming your entitlement. We do not receive your payment card details.

Direct Website Purchases (Stripe)

Direct purchases from iwvdigitalsolutions.com — Professional Annual ($24.99/year), Professional Lifetime ($39.99), and Academic Lifetime ($24.99) — are processed by Stripe. Your payment card information is collected by Stripe on its hosted checkout page; we do not receive or store your full payment card number. We receive only the information necessary to deliver your license key (your email address, an order reference, and a confirmation that payment succeeded).

Microsoft Store (Windows)

If you download NotesXML from the Microsoft Store, Microsoft collects information in accordance with its own privacy policy. We receive aggregate statistics from Partner Center. We do not receive personally identifiable information from Microsoft about individual users unless you contact us directly.

Cloud Sync Providers (Google Drive, Dropbox)

If you enable cloud synchronization, the App communicates directly with your chosen cloud provider using OAuth 2.0 authentication. Your credentials are stored locally on your device and are never transmitted to IWV Digital Solutions. The cloud provider's privacy policy governs how they handle your stored data.

4.4 IWV Chat AI: Network Activity and Data Flows

IWV Chat AI generates a deliberately minimal set of network requests. The following list is exhaustive — IWV Chat AI does not generate any other network traffic during normal operation.

Initial AI Model Download

On first launch, IWV Chat AI prompts you to download AI model files required for on-device inference. Model files are hosted by Hugging Face Inc. (huggingface.co) and downloaded directly to your device. IWV Digital Solutions does not host the model files and does not receive your download request. Hugging Face's privacy policy governs information collected during the download. The bundled model set is:

Llama 3.2 1B Instruct (text model, the platform default) is downloaded from Hugging Face under Meta's Llama 3.2 Community License.
Ministral 3 3B (vision-capable) is downloaded from Hugging Face under the Apache License 2.0.

You may also choose not to download a model, in which case IWV Chat AI generates no model-download traffic.

Optional Catalog Update Check

IWV Chat AI performs a non-blocking, periodic check for an updated model catalog file from https://iwvdigitalsolutions.com/iwvchat/catalog/iwvchat-model-catalog.json. This request transmits standard HTTPS connection data (your IP address, a User-Agent string identifying the App and version, and the timestamp of the request) to IWV Digital Solutions' web infrastructure provider. The catalog file describes available models and their parameters; it does not contain any data about you or your conversations. We retain web server access logs (which include IP addresses) for up to 30 days for the limited purposes of operational diagnostics and abuse prevention, after which they are automatically deleted. The catalog update check is non-blocking and does not transmit any usage data, telemetry, or personal information about you or your use of the App.

Conversations, Voice, Vision: Stay On Your Device

The following data is processed exclusively on your device by IWV Chat AI and is never transmitted to IWV Digital Solutions or to any third party:

The text of your messages to the AI assistant and the AI's responses
Voice recordings made when you use the microphone button (transcribed locally on-device by whisper.cpp)
Images you submit to the AI Vision feature (analyzed locally by the on-device multimodal model)
Your conversation history, conversation titles, and any conversation metadata
The list of which models you have downloaded and which model is currently selected
Any application settings (theme preference, voice settings, etc.)

This data is stored exclusively on your local device in standard JSON files that you may inspect, back up, copy, or delete at any time using your operating system's file manager.

Diagnostic Logs

IWV Chat AI generates diagnostic logs locally on your device. These logs are never transmitted automatically. If you choose to email a bug report to feedback@iwvdigitalsolutions.com using the App's "Generate Bug Report" feature, you may optionally attach these logs. Bug reports are sent only when you explicitly initiate them.

App Updates

If you installed IWV Chat AI from Google Play, app updates are delivered by Google Play. If you installed from Microsoft Store, updates are delivered by Microsoft. If you installed via direct download (Linux AppImage, Windows portable executable), the App does not auto-update; you check for updates manually at iwvdigitalsolutions.com. The App itself does not contact IWV Digital Solutions for update checks beyond the optional catalog update check described above.

5. How We Use Your Information

Purpose	Legal Basis
Deliver license keys and confirm purchases	Contract performance
Verify license key validity on activation	Contract performance
Respond to customer support inquiries	Legitimate interests
Verify academic eligibility for Academic licenses	Contract performance
Prevent license key fraud and abuse	Legitimate interests
Comply with applicable law and legal process	Legal obligation
Operate and improve the NotesXML application	Legitimate interests
Send transactional communications (license delivery)	Contract performance
Send Beta Waitlist communications (with your consent)	Consent
Aggregate analytics (anonymized, if implemented)	Legitimate interests

We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.

6. How We Share Your Information

We do not sell your personal information. We share your information only in the following limited circumstances:

Payment Processors: Stripe (direct sales) and Google Pay / Google Play Billing (Android) process payments. We share only the information necessary to complete your transaction. These processors are contractually bound to protect your information.
Cloud Storage Providers: If you use cloud sync, your notebook data is transferred directly from your device to your Google Drive or Dropbox account. IWV Digital Solutions is not party to this transfer and does not have access to the transferred data.
Legal Compliance: We may disclose your information if required by law, court order, or government demand. We will notify you of such demands to the extent permitted by law.
Business Transfers: If IWV Digital Solutions LLC is acquired, merged, or undergoes a similar transaction, your information may be transferred to the successor entity, which will be bound by this Privacy Policy.
With Your Consent: We may share your information for any other purpose with your explicit consent.

7. Data Retention

License key records are retained for the life of the license (perpetual licenses) or until subscription cancellation, plus an additional seven years for legal compliance purposes.
Support communications are retained for three years from the date of last contact.
Academic verification records (email address, verification code) are retained only for the duration of the verification session. Verified status is recorded against the license key record only.
Beta Waitlist email addresses are retained until you unsubscribe or request deletion.
Payment records are retained as required by applicable financial regulations (generally seven years).
Your notebook data is stored on your device. We have no copies and cannot delete it on your behalf; you control it entirely.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

8.1 California Residents (CCPA / CPRA)

California residents have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: You may request a description of the categories and specific pieces of personal information we have collected about you in the past 12 months.
Right to Delete: You may request deletion of personal information we have collected about you, subject to certain exceptions.
Right to Correct: You may request correction of inaccurate personal information.
Right to Opt Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising. No opt-out action is required.
Right to Limit Use of Sensitive Personal Information: NotesXML does not collect sensitive personal information. The App does not request access to your device location or contacts, and any information you enter is stored locally on your device and is never received by IWV Digital Solutions. This right therefore has no applicable data on our part.
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise these rights, submit a verifiable consumer request to legal@iwvdigitalsolutions.com or visit https://iwvdigitalsolutions.com/support/privacy-request. We will respond within 45 days.

8.2 Do Not Track

California law (CalOPPA) requires we disclose our response to Do Not Track signals. NotesXML does not track users across third-party websites. The App itself does not respond to Do Not Track signals, as it is a desktop/mobile application rather than a browser-based web service. The IWV Digital Solutions website (iwvdigitalsolutions.com) honors Do Not Track signals from browsers by not enabling behavioral tracking analytics on pages where such a signal is detected.

8.3 Global Privacy Control (GPC)

The IWV Digital Solutions website (iwvdigitalsolutions.com) honors Global Privacy Control (GPC) signals as an opt-out of sale of personal information, consistent with California law. Because we do not sell personal information, this has no practical effect on your experience. Note: The NotesXML App itself is not a web browser and does not process GPC signals; this section applies exclusively to the iwvdigitalsolutions.com website.

8.4 Children's Privacy (COPPA)

NotesXML is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, please contact us at legal@iwvdigitalsolutions.com and we will promptly delete it.

8.5 Data Subject Rights (EEA / UK)

While IWV Digital Solutions LLC is a California company and NotesXML is primarily distributed in the United States, we acknowledge the following rights for users in the European Economic Area and United Kingdom under GDPR and UK GDPR: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, and right to object. To exercise these rights, contact legal@iwvdigitalsolutions.com.

9. Data Security

We implement appropriate technical and organizational measures to protect personal information we hold, including:

License key records are stored in a secured, access-restricted database. Database credentials follow a least-privilege model (the application user has no DDL privileges). Administrative access is logged. License keys are not stored in browser-accessible locations or transmitted in URLs.
HTTPS encryption for all data transmitted to our servers.
Restricted internal access to personal information on a need-to-know basis.
Optional local encryption for notebook data using AES-256-GCM with PBKDF2-SHA512 key derivation (user-controlled passphrase; IWV Digital Solutions cannot recover your passphrase or your encrypted data).
Optional Zero-Knowledge Encrypted Cloud Sync where filenames and directory structure are obfuscated using UUID-based naming; IWV Digital Solutions cannot read your cloud-synced data.

No method of data transmission or storage is 100% secure. We cannot guarantee absolute security, but we are committed to protecting your information using industry-standard methods.

10. Third-Party Services and Links

NotesXML may include links to external websites or integrate with third-party services (Google Drive, Dropbox). This Privacy Policy does not apply to those services. We encourage you to review the privacy policies of any third-party services you use in connection with NotesXML.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will:

Update the "Effective" date at the top of this document.
Post the updated policy at https://iwvdigitalsolutions.com/legal/privacy.
Notify you through the App or by email (if we have your email address) when changes are material.

Your continued use of NotesXML after the effective date of any update constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

For privacy-related inquiries, data subject requests, or questions about this Privacy Policy:


Privacy / Legal	legal@iwvdigitalsolutions.com
General Support	support@iwvdigitalsolutions.com
Privacy Request	https://iwvdigitalsolutions.com/support/privacy-request
Account Deletion	https://iwvdigitalsolutions.com/support/delete-account
Opt-Out Page	https://iwvdigitalsolutions.com/legal/do-not-sell

We will respond to privacy requests within 45 days. For California residents, the response period may be extended by an additional 45 days with notice.

This document is effective as of May 28, 2026 and supersedes all prior versions. Version 1.7.

Change log: v1.7 (May 28, 2026) — Section 4.2: removed the Location Data (Location Notes / GPS) and Contact Data (device-contact reading) collection descriptions — NotesXML does not request or use device location or contacts permissions. Section 11 (CCPA): Right to Limit Use of Sensitive Personal Information reconciled (no sensitive personal information, including precise geolocation, is collected). Aligns the policy with the shipped Android manifest and the Google Play Data Safety form (CR-2026-834 Phase 4 / audit F-029). v1.6 (May 8, 2026) — Section 9: corrected license key storage description (CR-2026-663). Prior text incorrectly stated hashed storage; actual implementation uses plaintext storage in a secured, access-restricted database for license recovery purposes. v1.5 (May 1, 2026) — Added Section 3.1 NotesXML Ad-Free Commitment per CR-2026-599 Phase 2. v1.4 (May 1, 2026) — Extended scope to cover IWV Chat AI in addition to NotesXML. Added Section 1.1 (IWV Chat AI: Specific Privacy Commitments) and Section 4.4 (IWV Chat AI: Network Activity and Data Flows). v1.3 (April 2, 2026) — prior version, NotesXML only.