Privacy Policy

In short: Your files and your search index stay on your computer. There are no user accounts, no tracking and no advertising. In “Recommended” mode, only the text or voice recording needed for answers, suggestions, voice input, read-aloud and search by meaning is sent to the AI, encrypted; we do not store this content. In “Private” mode, nothing leaves your computer. We do not sell or share your personal information.

Who is responsible

Umbolement UG (haftungsbeschränkt), Ulmenweg 10, 85221 Dachau, Germany. Email: info@filespal.com

The app on your computer

FilesPal reads the folders you select and builds a search index from them on your computer. Your files, the index, text recognition, your settings and what the app learns from your filing stay there and are not sent to us.

Registering the app and the free allowance

So that the free allowance applies per device and cannot be bypassed by reinstalling, the app registers with our server once you use “Recommended” mode or enter a license – not before, for example during setup. It sends a device ID: a one-way hash that the app calculates from the Windows device ID (MachineGuid) and a fixed value. Our server hashes it again and stores only that result. During registration, the app also solves a short computing task; it contains no data about you and makes mass registrations harder.

Per device, we store a random token, the hash, the registration date, the number of AI requests per month and how much of each allowance has been used (for example, when your documents are first learned). To prevent misuse, we also store a one-way hash of the IP address that changes daily; it is deleted after two days. If a device has not been used for AI requests for 13 months, we delete its data; the app registers again when needed. Legal basis: Art. 6(1)(b) GDPR (providing the free version) and Art. 6(1)(f) GDPR (our legitimate interest in preventing misuse).

AI service in “Recommended” mode

For an answer, the app sends your question and the passages found (if none are found, only the question, for general guidance); for a name suggestion, the recognized text of that document – encrypted (HTTPS) to our server filespal.com. To make search more accurate, the app may first have your question rephrased into search terms the same way. The server passes the text to an AI provider as our processor and returns the result to the app. We do not store or log the content.

Text is processed primarily by Anthropic (Anthropic, PBC, San Francisco, USA, or Anthropic Ireland, Limited, Dublin, Ireland). If Anthropic has an outage or is overloaded, OpenAI (OpenAI Ireland Ltd., Dublin, Ireland, and OpenAI, L.L.C., San Francisco, USA) automatically takes over, then Mistral AI SAS (Paris, France) – with the same content, the same way.

So that search also understands meaning (for example, “car insurance” finds “auto policy”), the app sends the text of the documents in sections, each with the document’s name, sender, date and type, as well as your search queries, the same way; OpenAI turns them into numeric vectors. The app learns the folders you select or – only if you choose “Whole PC” in the app – all available drives; system and program folders and the exceptions you set are always left out. The app stores the vectors only on your computer; we store neither text nor vectors.

If you use voice input, the app sends the recording (usually a few seconds) and, to help recognition, the names of your folders the same way; Mistral turns the recording into text, or OpenAI during outages. We do not store recordings or the recognized text.

For the voice assistant, the app sends the spoken or typed command and only what is needed: the page you have open, the name, folder and key details (date, sender, type) of the selected document, and your folder names; for a command to organize a folder, also how many files of which type and which subfolders it contains. Document content is not included; questions about content are answered by search as described above. The command is processed like text.

When the app reads a reply aloud – at the touch of a button or as a spoken reply from the voice assistant – it sends the reply text in sections the same way; OpenAI generates the speech. The text may include names and excerpts from your documents. The app keeps the audio in memory only; we store neither text nor audio. In “Private” mode, without internet or during outages, the Windows voice speaks on your computer and nothing is sent.

According to the providers, data sent through their APIs is not used to train models and is deleted after a short period; at Mistral, this use is switched off in our account. Processing in the USA is possible with Anthropic and OpenAI; it is based on the EU-U.S. Data Privacy Framework and standard contractual clauses.

Legal basis: Art. 6(1)(b) GDPR (providing the feature you use). If you use FilesPal for work with Business, we process this content on behalf of your company under the Data Processing Agreement.

Scanning with your phone

When you scan with your phone, the app shows a QR code. The phone encrypts each page with a key only your app knows and uploads it to our server; the app then collects the pages. Our server cannot read the pages. It keeps the encrypted pages for at most 30 minutes and deletes them as soon as the app has collected them. For each session, it also stores the time, number of pages and size, and the access codes only as a one-way hash. Legal basis: Art. 6(1)(b) GDPR.

Your own inbox address

If you set up the inbox address, your device gets its own email address with us; for this we store the address and your device’s public key. Our mail server receives email sent to this address and immediately encrypts it with this key, including sender, subject and attachments. Only your app can decrypt it. During delivery, the mail server may briefly hold a message unencrypted. We keep the encrypted messages for at most seven days and delete them as soon as the app has taken them over. Email to unknown addresses is discarded. Legal basis: Art. 6(1)(b) GDPR.

“Private” mode and your own key

In “Private” mode, AI and speech recognition run on your computer and no content is sent. If you choose “Own OpenAI key”, the app sends text and recordings directly to OpenAI under the terms of your own contract with OpenAI. Your key is stored encrypted on your computer only.

Premium and Business: purchase, payment and license

Orders and payments are handled by Stripe (Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Dublin 2, Ireland). You enter your payment details directly at Stripe; we never receive full card or account details. Stripe also processes data under its own responsibility, for example to prevent fraud and to meet legal obligations; processing in the USA is possible (EU-U.S. Data Privacy Framework, standard contractual clauses). Details: Stripe’s privacy policy. The customer portal for invoices, payment method and cancellation is also run by Stripe; you sign in with a link sent to your email address.

From Stripe, we receive your name, email address, billing address, for Business your company and, where applicable, your tax ID, the plan, the number of seats and the payment status. For each license, we store the plan, seats, company, email address, start and end, and the IDs at Stripe. We store the license key only as a one-way hash plus its last four characters for reference. We keep the key itself for at most 24 hours so the confirmation page can show it; we send it to you by email from our mailbox.

When you enter the key in the app, our server checks it together with the device ID and stores, per seat, when it was activated and last used – so seats can be moved and become free after 30 days without use.

Legal basis: Art. 6(1)(b) GDPR (contract) and Art. 6(1)(c) GDPR (retention obligations). We keep license data for the term of the contract and delete it three years after it ends; invoices and accounting records are kept for ten years under German law.

Discount in the Umbolement family

Customers of Kesru and MeetYourSite – products of the same company, Umbolement UG (haftungsbeschränkt) – get FilesPal 20 % cheaper, and vice versa. If you enter your email address before buying, our server asks these products only whether there is an active subscription for a one-way hash (SHA-256) of your email address; the answer is only “yes” or “no”. When these products ask us, we likewise only answer “yes” or “no”. No other data is exchanged and no requests are stored. Legal basis: Art. 6(1)(b) GDPR (steps taken at your request before a contract) and Art. 6(1)(f) GDPR (our interest in giving existing customers a discount).

Requests from businesses

If you send a request through the form on the Business page, we store your company, name, email address, phone number (optional), the number of users and your message, and send you a confirmation. We use this information only to answer your request (Art. 6(1)(b) GDPR) and delete it twelve months after receipt if no contract results.

Cancellation and withdrawal on the website

If you cancel on the Cancel page or withdraw on the Withdrawal page, we store the details from the form, end the subscription at Stripe and send you a confirmation by email. We use this data only to carry out and document the cancellation or withdrawal (Art. 6(1)(b) and (c) GDPR) and delete it three years after the end of the year in which it was received.

Email

Our mailbox info@filespal.com is hosted by netcup GmbH (Karlsruhe, Germany). We forward incoming email for processing to a mailbox at Google (Google Ireland Limited, Dublin, Ireland); processing in the USA is possible (EU-U.S. Data Privacy Framework). We use your message only to reply to it (Art. 6(1)(b) or (f) GDPR).

App updates and downloads

The app regularly checks filespal.com for a new version and checks the status of your license; no content is sent. Only in “Private” mode does the app download AI models from Hugging Face and program components from GitHub; these providers technically receive your IP address in the process.

This website

This website uses no analytics or advertising services; all fonts are served from this server. Our web server keeps no access logs for this website, and our service does not log IP addresses. One small cookie is used: if you choose a language, your browser stores the cookie “lang” (value “en” or “de”) for one year so the site shows your language. If you choose dark mode, your browser stores this choice locally on your device. Nothing is sent to us in either case.

Hosting and backups

The website and the service run on a server of Hetzner Online GmbH (Gunzenhausen, Germany) in its data center in Nuremberg. We back up the service database every night, encrypted (AES-256), at Cloudflare R2 with storage location in the EU (Cloudflare, Inc., San Francisco, USA); backups are encrypted before they leave our server. Both providers are our processors.

Recipients at a glance

• Hetzner Online GmbH, Germany – server (processor)
• Anthropic, PBC / Anthropic Ireland, Limited, USA/Ireland – AI in “Recommended” mode (processor)
• OpenAI Ireland Ltd. / OpenAI, L.L.C., Ireland/USA – search by meaning, read-aloud, backup AI (processor)
• Mistral AI SAS, France – backup AI during outages (processor)
• Cloudflare, Inc., USA – encrypted backups, storage in the EU (processor)
• Stripe Payments Europe, Ltd., Ireland – orders, payment, invoices, customer portal
• netcup GmbH, Germany, and Google Ireland Limited, Ireland – email

Your rights

You have the right to access, rectification, erasure, restriction of processing and data portability. Where we process data on the basis of Art. 6(1)(f) GDPR, you can object at any time for reasons arising from your particular situation (Art. 21 GDPR). You can lodge a complaint with a data protection authority, for example the Bavarian Data Protection Authority (BayLDA) in Ansbach, Germany. Please send requests to info@filespal.com.

There is no automated decision-making within the meaning of Art. 22 GDPR. You do not have to give us any data; without a device ID, however, “Recommended” mode does not work – “Private” mode works without one.

For residents of the United States

This section applies in addition to the above for residents of California and other U.S. states with privacy laws.

• What we collect: identifiers (name, email address, the hashed device ID, license IDs), commercial information (plan, seats, payment status – payment details stay at Stripe), and the content you choose to process with the AI service, which we pass through without storing it. Sources: you, your device and Stripe. Purposes: providing the app and the AI service, licenses, billing, support and preventing misuse, as described above.
• No sale, no sharing: We do not sell personal information and do not share it for cross-context behavioral advertising. We do not use sensitive personal information to infer characteristics about you.
• Your rights: You can ask to know what personal information we hold about you, to correct it and to delete it, and you will not be treated differently for exercising these rights. Send your request to info@filespal.com; we verify it by replying to the email address on file. You may also use an authorized agent, who must show that you have authorized them.
• Retention: as described in the sections above.

Last updated: October 9, 2026