EU Data Act

In plain language: you can leave whenever you want, take all your data with you in open formats, and we charge nothing for it.

2. Switching or leaving#

You can ask to switch to another provider, move your data to your own systems, or erase it and leave. You do not need our help for any of these: the exports and the account deletion are in the dashboard and the API. If you want the terms of this section to apply, tell us:

• How to ask. Write to support@intramedial.com with "Data Act switching" in the subject line, from the address of an owner of the organization. Say which of the three you want and, if it matters to you, the date on which to start.
• Notice. None is required. The switch starts when we receive your request, or on a later date you name, no more than two months ahead.
• Transition period. Up to 30 days, during which your plan and these terms stay in force. We help you and the provider you name, keep the Service running as your contract provides, tell you of any risk to its continuity we know of, and keep your data secure, including while you transfer it. If 30 days is technically impossible, we tell you within 14 working days of your request, with our reasons and an alternative period of no more than seven months. You can extend the transition period once, for as long as you need.
• Retrieval period. At least 30 days after the transition period ends. Everything in the register in section 3 stays available to export, and your plan's record retention window keeps applying: we do not shorten it because your plan has ended.
• End of the contract. Your contract ends when the switch is complete, or, if you asked only for erasure, when the transition period ends. We confirm it by email.
• Erasure. When the retrieval period ends, or at a later date you agree with us, we erase all the exportable data listed in section 3 and confirm it by email, following the 30-day deletion grace period that applies to account and workspace deletion. We keep only the records the law requires, such as billing and tax records, and the records we keep to protect the Service and others, such as abuse reports and appeals and the security audit log, as the Terms of Service describe. Two more things can remain after erasure. Append-only ledger entries are kept where erasing them would break the chain that proves the others; they are reduced to hashes and reasons, and a person's identifier is removed where erasure is required. And any anchor already entered in a public timestamping service stays there, because we do not run it; it holds only a hash.

No charges. We charge nothing for switching, for exports or for data transfer, on any plan, and the Terms of Service do not allow us to start. Your plan's fees for the period in which you still use the Service, including the transition period, apply as usual, and refunds follow the Terms of Service.

3. Register of exportable data and formats#

You can export all of the following during your contract and the retrieval period, yourself, at any time and without asking us. Export files made for download stay available for 7 days (30 days for the Article 12 export and the custody log) and you can make a new one at any time.

The exit export carries a manifest with one digest per item and a Merkle root over all of them, and its root is witnessed in the ledger. Two checks can be re-run by anyone: completeness compares the manifest with the live inventory and names anything we still hold that the export does not contain, and integrity compares the contents with the recorded digests. An export is called provable only when both hold.

What you cannot export, and why:

• Secrets. We store API-key secrets only as hashes, and we never return a stored credential, such as a connector's, which we keep sealed. Create new credentials with your new provider.
• Our signing keys. The private keys that sign ledger bundles are our secrets and cannot be handed over, for you or anyone. The public keys are what a verifier needs, and you can export them.
• Data about how the Service runs internally. Abuse-detection signals, rate-limit counters and our operational logs describe our systems rather than your use of them, and exporting them would expose how we protect the Service. Leaving them out does not hold up or delay a switch.

Formats and standards#

How to check a bundle in your own code is in Verifying records and Verify in code. Because bundles and the audit chain use open, published standards, what you take with you stays verifiable with the open-source verifier or any Ed25519 and SHA-256 implementation, whichever provider you use next.

4. Where each part of the Service runs#

Seven regions are deployed for workspace data today: US East, US West, Europe Central, Europe West, Europe North, Asia-Pacific and Oceania. The wider catalogue of locations on Regions lists places we offer and that become available as capacity is turned on. The Control Plane and billing are not regional. A location hint is a placement request to Cloudflare, not a guarantee, and some Cloudflare components, such as queues and key-value caches, cannot be pinned to a region; they hold no customer content beyond short-lived tokens, counters and event payloads in transit. We do not promise that data never passes through a network edge outside the region: Cloudflare receives every connection at the location nearest the caller. Data regions gives the detail, and the sub-processors page lists every provider. A workspace stays in the region in which it was created until you rehome it, and rehoming copies a snapshot to the other region without deleting the source.

5. Protection against access by governments outside the EU#

Avonao, Inc. is a United States company, and our main providers, Cloudflare, Amazon Web Services and Stripe, are United States companies too. We are subject to United States law, including laws that allow authorities to ask for data a US company controls, wherever the data is stored. We cannot promise that no such request will ever reach us. These are the measures we take to prevent access to, or transfer of, your data held in the EU where it would conflict with EU law or the law of a Member State:

• Data minimization. The witness copies of ledger roots held outside Cloudflare contain hashes and roots, not customer content. The assistant receives a pseudonymous identifier, not your email address or IP address. A hash reveals nothing about the content it was made from.
• EU storage. Workspace data in the European region is stored under Cloudflare's EU jurisdiction.
• Review of every request. We check each request from a government or court for its legal basis, for its scope and for conflict with EU or Member State law, and challenge one that is unlawful, too broad or in conflict with EU law. A request from outside the EU for data held in the EU is met only where an international agreement in force, such as a mutual legal assistance treaty, provides for it, or where Article 32 of the Data Act otherwise allows it.
• The least data. Where we must comply, we disclose only the minimum the request lawfully requires.
• Telling you. We tell you of a request before we act on it, unless the law forbids it or the request serves law enforcement and telling you would defeat its purpose for as long as that lasts.
• Contracts. Our agreements with our providers include the European Commission's Standard Contractual Clauses where they are needed, and our Data Processing Addendum binds us to the same approach for personal data.

6. Changes and contact#

We update this page when our switching process, our formats or the location of a service change, and tell customers by email of any change that reduces their rights. Questions: support@intramedial.com.

EU notices

• Digital Services Act
• EU Data Act
• EU AI Act
• Right of withdrawal

Receipt practices

• Record Practice Statement
• Verifier Terms
• Key management
• Verifying ledger bundles
• Format versions and long-term verification
• Cryptographic agility and post-quantum status
• If Intramedial stops operating

Program terms

• Startup Program Terms
• Nonprofit Program Terms
• Education Program Terms
• Public Sector Program Terms