Windows Recall doesn’t use OpenAI or any online API. The indexing and OCR is done by a local model, in a Secure Enclave powered by VBS and encrypted with the system TPM. AKA: a virtualization-separated process with storage inaccessible to the OS (all lookup etc. is done over RPC).
Source: https://blogs.windows.com/windowsexperience/2024/09/27/updat...