Privacy Policy

Our representative in the European Union. Our representative in the European Union under Article 27 GDPR, and our data protection officer for the European Union, is NUICORN, Chausseestraße 86, 10115 Berlin, Germany. You can contact them, and us at privacy@intramedial.com, on all matters about your personal data.

This policy applies to Intramedial, the Agent Coordination Plane operated by Avonao, Inc.: the website at intramedial.com, the REST API (api.intramedial.com), the MCP server (mcp.intramedial.com), the dashboard (app.intramedial.com), the assistant and the other pages of the service (together, the "Service"). Read it with the Terms of Service, the Cookie Policy and the list of Sub-processors.

Avonao ID. Sign-up and sign-in to the Service are handled by Avonao ID (id.avonao.com), the account service of Avonao, Inc. The Service has no sign-in methods of its own. Avonao ID collects and keeps your email address, name, sign-in methods, security log, country and age confirmation, and Avonao, Inc. is the controller of that data. Avonao ID publishes its own privacy notice for it. The Service receives only the OpenID Connect claims described in section 2, and reports your subscription state back to Avonao ID (section 5).

Customer content. For personal data that you or your users put into the Service, including the records the Service keeps about the agents you run and the people who operate or approve them (for example agent identities and owners, leases, mandates, approvals, admission decisions, ledger entries and labels), you decide the purpose and we act on your behalf as your processor, under the Data Processing Addendum that forms part of the Terms of Service. For account, billing, security and website data, and for our own purposes described below, we are the controller.

In plain language: we collect what we need to run, secure and bill the Service. We do not use your content to train models or for any purpose of our own. We do not sell your data. The coordination record is built to be append-only so that it stays credible as evidence, and section 7 explains exactly what that means for deletion.

2. What we process, and where it comes from#

The coordination record can contain personal data if it is in what your agents or your systems submit, for example a person's name in a label or in a repository action. Do not submit special categories of personal data (health, biometric, political, religious and similar data) or data about children to the Service unless your contract with us covers it.

If you are a person named in a record by someone else (for example as the owner of an agent), the workspace owner is the source. You can use the rights in section 8 against us for that data.

If you met Intramedial through one of our customers. You may be named as the owner or approver of an agent, approve an action in the dashboard, or have your work performed or blocked by an agent that a customer governs with the Service. The customer decides why, and is the controller; we keep only what the table above lists, as its processor. Ask the customer first; you can also use the rights in section 8 against us, and we will pass your request to the customer where it concerns their records.

3. What we do not store#

We do not store:

• the prompts, documents or model outputs of your agents. The Service records decisions about what agents may do and hashes and references that you supply, not the work product itself, unless you choose to attach it to a record;
• your card number; or
• your password, because the Service holds none.

One exception: if you send an Idempotency-Key on a request, the gateway keeps the response for 24 hours so a retry returns the same answer. It is scoped to your workspace and then expires on its own. See Data and privacy for the technical detail.

4. Why we process it, and on what basis#

Email lists. We send newsletters, product updates and "notify me" emails only to addresses that asked for them and then confirmed by clicking the link in our confirmation email (double opt-in). Each list is separate: you receive only the lists you chose. Every such email carries an unsubscribe link and a List-Unsubscribe header, so you can leave a list in one click or from your mail app. You can also write to privacy@intramedial.com and we will remove you. Unsubscribing does not stop service notices about an account you hold (security, billing, changes to terms), which we send under the contract. We keep a record of your confirmation and of your unsubscribe so that we can show your consent and honour your choice.

Where we rely on legitimate interests you can object (section 8). Where we rely on consent you can withdraw it at any time.

We do not train models on your content. We do not use Customer content to train models, and we do not use it for any secondary purpose. The model provider behind the assistant is bound by its commercial terms not to train on content sent through its API.

California and other US states. We collect the categories above for the business purposes listed in this section. In the language of the CCPA, we collect identifiers (email, name, IP address, keys), customer records and commercial information (plan, billing status), internet and network activity (requests, logs, analytics if you consent) and approximate location derived from IP address. We do not collect sensitive personal information to infer characteristics about you. We do not sell personal information and we do not share it for cross-context behavioral advertising, and we have not done either in the past 12 months. We do not knowingly sell or share the personal information of anyone under 16.

5. Who receives it#

• Service providers that process data on our behalf, listed on the Sub-processors page: Cloudflare (hosting, databases, storage, queues, email, bot protection and assistant retrieval), Amazon Web Services (where enabled, a witness copy of Merkle roots, key management for the secrets we store for the control plane, archive storage and, for dedicated-location workspaces, database hosting), Resend (email fallback), Anthropic (the language model behind Number One, which receives your questions to it and, in the dashboard, the workspace records it reads for you) and Google (analytics only with your consent). Avonao Billing and Stripe receive billing data as set out below.
• Avonao ID. It is the identity provider for sign-up and sign-in and is operated by Avonao, Inc. It sends us the claims listed in section 2. We send it, when your subscription starts, changes or ends: whether your subscription is none, free or paid, its renewal date and a link to manage it. We send no prices and no billing data. It may also tell us that you have asked to delete, or have deleted, your Avonao ID, which starts the deletion described in section 7.
• Avonao Billing and Stripe. Payments, invoices and plan changes are handled in Avonao Billing (Avonao Wallet). Stripe is the merchant of record there and processes your payment details on its own account under its own terms.
• Authorities and advisers. Courts, regulators and law enforcement where the law or a valid legal process requires, and our professional advisers under confidentiality.
• A successor, if we merge with or sell the business, on terms that keep this policy's protections for your data.
• Anyone you give a ledger bundle to. Ledger bundles are evidence meant to be shown. A bundle you hand to an auditor or a third party, or publish, shows them everything in it, and they can check it offline with our published verifier and public keys.
• Destinations you choose. When you stream audit events to a system you configure, or connect an enforcement point or connector to a system you name, that system receives the data you direct to it. It is your recipient, not our sub-processor.

We do not sell personal data to anyone.

6. International transfers#

We are based in the United States. Account data, sign-in links, billing records and the dashboard are served from the Cloudflare region that is the home region of your account; the public website and documentation, which hold no customer data, are served from the United States. Cloudflare terminates network connections at the location nearest the visitor, which can be outside your region; stored data stays in the region. Workspace data (the coordination record, the audit chain and the ledger) is processed and stored in the data region you choose for the workspace. Seven regions are deployed today: US East, US West, Europe Central, Europe West, Europe North, Asia-Pacific and Oceania. Further locations in the catalogue become available as capacity is turned on; see Data regions and the regions page. The three European regions are created under Cloudflare's EU jurisdiction, so that their stored data stays in the European Union (Cloudflare chooses the datacenter inside it); the other regions use a location hint, which is a request and not a guarantee. We do not promise that traffic never leaves the European network edge. Some components (the control plane, billing, configuration and queue infrastructure and the language model) are not regional, as the Security page and the Sub-processors list explain. If you are in the EEA, the UK or Switzerland, your personal data is transferred to the United States when you use the Service.

We protect these transfers with the European Commission's Standard Contractual Clauses (and, for the UK, the UK International Data Transfer Addendum, and for Switzerland the Swiss adaptations of the clauses), which form part of our Data Processing Addendum and our agreements with sub-processors. Where a recipient is certified under the EU-US Data Privacy Framework, the UK Extension and the Swiss-US Data Privacy Framework, that certification is an additional basis, and we rely on the Standard Contractual Clauses where it is not. You can ask for a copy of the clauses at privacy@intramedial.com.

You choose the data region when a workspace is created. You can move a workspace to another region by rehoming it; rehoming copies a snapshot to the new region and does not delete the source, so the source is erased only under the rules in section 7. Choosing a region outside the United States does not move account data, billing records or the pointer that lets us send you to the right region, which stay in the United States.

7. Retention#

What persistence of records means for you. A ledger is worth something only if it stays unchanged. We therefore do not alter coordination records on request through the product; they are deleted when they pass your plan's window, or earlier when you delete the workspace. If a request concerns personal data inside a record, we assess it individually, tell you in our answer what we can remove and what we must retain and why, and do so within the deadlines in section 8. We keep records on the basis of our contract with you and the legitimate interest in evidence that stays reliable, and, where a law allows, for the establishment, exercise or defense of legal claims. Keep personal data out of labels and free-text fields. Export the ledger bundles you need before they pass your plan's window, and before you delete an account.

See Retention and erasure for how deletion works in practice.

8. Your rights#

Depending on where you live, you may have the right to:

• access the personal data we hold about you and receive a copy, and know the categories, sources, purposes and recipients;
• correct inaccurate data;
• delete your personal data (erasure), subject to the retention rules in section 7;
• port data you gave us in a structured, machine-readable format;
• object to processing based on legitimate interests, and restrict processing;
• withdraw consent at any time, without affecting earlier processing;
• opt out of sale, sharing and targeted advertising (we do none of these);
• limit use of sensitive personal information (we do not use it to infer characteristics);
• not be subject to a decision based solely on automated processing with legal or similarly significant effects (we make none about you, and you can ask for a review of any automated decision, section 13);
• not be discriminated against for using your rights; and
• complain to a supervisory authority.

These rights come from the GDPR, the UK GDPR, the Swiss Federal Act on Data Protection, the California Consumer Privacy Act as amended (CCPA/CPRA) and the comparable laws of other US states, and apply to the extent those laws apply to you.

8.1 How to make a request#

Use the privacy request form, which covers GDPR requests and requests under California and other US state laws, or write to privacy@intramedial.com. If you are signed in, you can also use Account > Data rights in the dashboard to export your data or delete your account, and the form covers access, portability, erasure, rectification, restriction, objection, review of an automated decision and withdrawal of consent. For the data Avonao ID holds (email addresses, name, sign-in methods, security log, country and age confirmation), use the tools in your Avonao ID dashboard or write to us. If you need us to find ledger entries, give the entry ids or the hash, because we often cannot tell from a hash whom an entry concerns.

• Verification. We confirm that the request comes from you, normally by a message to the email address on the account, and we ask for no more than we need. If we cannot verify you, we tell you why.
• Response times. We confirm receipt within 10 days and answer within one month (GDPR and UK GDPR) or 45 days (US state laws). If a request is complex or numerous we may extend by up to two further months (GDPR and UK GDPR) or 45 further days (US state laws), and we tell you before the first deadline and say why.
• Cost. Free. We may charge a reasonable fee or refuse only for manifestly unfounded or excessive requests, and we then explain.
• Authorized agents. An agent may act for you with your signed permission, and we may verify that with you.
• If we say no. We give our reasons. You can appeal by replying to our answer or writing to privacy@intramedial.com with "Appeal" in the subject, and a person who did not take the first decision will answer within 45 days (60 days where state law gives us that long) and tell you how to contact your state's attorney general or other regulator.
• Complaints to us. You can complain to us about how we use your personal data, by writing to privacy@intramedial.com with "Complaint" in the subject or through the privacy request form. We acknowledge a complaint within 30 days, look into it without undue delay and tell you the outcome. This is also the complaints procedure that UK data protection law requires.
• Complaints to a regulator. You may complain to the data protection authority where you live, work or where you think an infringement occurred, for example your national authority in the EEA, the Information Commissioner's Office in the UK, or the Federal Data Protection and Information Commissioner in Switzerland. We would appreciate the chance to resolve it first.

9. Information for people in particular countries#

9.1 Brazil#

For people in Brazil, the Lei Geral de Proteção de Dados (LGPD, Law No. 13,709/2018) applies to the processing described in this policy. The rights in section 8 include the rights in Article 18 LGPD, among them confirmation that we process your data, anonymisation, blocking or deletion of unnecessary or excessive data, information about the public and private entities we share it with, and information about the possibility of refusing consent and what follows from refusing.

Requests under the Brazilian General Data Protection Law (LGPD) go to our privacy contact at privacy@intramedial.com. You can also complain to the Autoridade Nacional de Proteção de Dados (ANPD). Personal data is transferred to the United States and to the data region chosen for the workspace, with the safeguards described in section 6.

9.2 Japan#

For people in Japan, the Act on the Protection of Personal Information (APPI) applies.

• Business operator. Avonao, Inc., 254 Chapman Rd, Ste 208 #21918, Newark, Delaware 19702, USA, represented by its Chief Executive Officer, whose name is given in the Imprint.
• Purposes of use. The purposes in section 4.
• Your requests. You can ask us to disclose the personal data we hold about you, including records of its provision to third parties, to correct, add to or delete it, to stop using or erase it, and to stop providing it to third parties, as described in section 8.1. We charge no fee.
• Security control measures. People who handle personal data are bound by confidentiality and get access only where their work needs it. The Service runs in the data centres of Cloudflare and Amazon Web Services, which are responsible for physical security. Technical measures include encryption in transit, hashed credentials, sealed secrets, per-workspace isolation, access controls and an append-only security audit log, as described in section 14 and in Security model.
• Transfers to other countries. Personal data is stored and processed in the United States and in the data region chosen for the workspace (section 6). The service providers that receive it are bound by contract to handle it with measures equivalent to those the APPI requires of business operators. On request we provide information about those measures and about the data protection systems of the countries concerned.
• Questions and complaints. privacy@intramedial.com. You can also contact the Personal Information Protection Commission of Japan.

10. Global Privacy Control and tracking#

We honor the Global Privacy Control signal as an opt-out. A browser that sends it is treated as "Only necessary": Statistics stay off unless you switch them on yourself in the cookie settings. The Service does not respond to the older Do Not Track header, because it does not track you across other sites.

11. California "Shine the Light"#

California Civil Code section 1798.83 lets California residents ask which categories of personal information a business has disclosed to third parties for their direct marketing. We make no such disclosures. You can still write to privacy@intramedial.com to ask.

12. Children#

The Service is for businesses and developers and is not directed to anyone under 18. Avonao ID, through which you sign up and sign in, asks you to confirm the minimum age and does not ask for a date of birth. If we learn that someone under 18 created an account, we delete it. We do not knowingly collect personal data from children. If you believe a child has given us personal data, write to privacy@intramedial.com and we will delete what we can, as described in section 7.

13. Automated decisions, agents and the assistant#

The Service makes automated decisions, but about agents and actions that you govern, not about you as a person. Admission and enforcement decisions are made by rules and mandates that you or your administrators set; the admission function runs without a network call and without a model. If an automated decision could affect you as an individual, for example because an agent that you operate was refused, you can ask for a review through the privacy request form or by writing to privacy@intramedial.com, and a person will look at it. Automated checks flag unusual usage for a person at Intramedial to review; they do not suspend an account by themselves.

The assistant, Number One, is an artificial intelligence system. It tells you that it is one, can make mistakes and does not give legal advice. It answers questions about the Service and, in the dashboard, about your own workspace. Data-subject requests are routed to the request channels in section 8 and not answered by the model.

14. Security#

We protect personal data with technical and organizational measures described in Security model, including encryption in transit, hashed credentials, per-workspace isolation, sealed stored secrets, dual control for sensitive administrative scopes and access controls. No system is perfectly secure. If a personal data breach affects you, we notify you without undue delay and, as a processor, no later than 72 hours after becoming aware of it, and we notify the authorities as the law requires. Report suspected incidents to security@intramedial.com.

15. Changes to this policy#

We update the date at the top when we change this policy. We announce material changes by email to account owners or in the dashboard at least 30 days before they take effect. If you do not agree, you may delete your account before the change takes effect.

16. Contact#

• Privacy and data requests: privacy@intramedial.com
• General and legal questions: support@intramedial.com, or the contact page
• Security: security@intramedial.com
• Avonao, Inc., 254 Chapman Rd, Ste 208 #21918, Newark, Delaware 19702, USA (legal address)
• Mailing address, for general correspondence only: Avonao, Inc. • 2261 Market Street PMB 10671, San Francisco, CA, 94114, United States. It is not our legal address: all legal correspondence must be sent to the legal address in Delaware, and legal correspondence sent only to the mailing address is not treated as received by us.
• EU representative and data protection officer: NUICORN, Chausseestraße 86, 10115 Berlin, Germany
• Imprint

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