EU Data Act

1. What this page is#

Regulation (EU) 2023/2854, the Data Act, gives customers of data processing services, which include software offered as a service, the right to switch to another provider or to their own systems, and requires providers to publish certain information. Agined Attestor, provided by Avonao, Inc., is such a service. This page sets out the switching terms that section 12.6 of our Terms of Service makes part of your agreement, the register of the data you can export and its formats, and the information Article 28 requires. We apply the same terms to every customer, wherever they are.

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 export 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@agined.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 receipt 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, receipts included, and confirm it by email. 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 section 12.4 of the Terms of Service describes. One more thing stays after erasure: any SBOM you asked sbom.notarize to keep. It stays in locked storage in your data region for its ten years, and nobody, including us, can delete it earlier.

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 section 7.5 of 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:

A receipt export also contains a manifest.json, a SHA256SUMS file and a verify.mjs script, so that whoever receives it can check that the archive is complete and that every receipt verifies, without us.

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, an api.witness credential or a payment.event webhook secret, which we keep sealed. Create new credentials with your new provider.
• Our signing keys. The private keys are held as encrypted secrets and are never exported, for anyone. The public keys are in every export, which is all a verifier needs.
• 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#

The documentation of each receipt type is in Receipts, and how to check a receipt in your own code is in Verifying receipts. Because every receipt is signed over a published standard form, a receipt you take with you stays verifiable with any Ed25519 implementation, whichever provider you use next.

4. Where each part of the Service runs#

A location hint is a placement request to Cloudflare, not a guarantee. Cloudflare receives every connection at the location nearest the caller, which can be anywhere. Data regions gives the detail, and the sub-processors page lists every provider. A workspace stays in the region in which it was created.

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 (through Avonao Billing), 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. Relayed request and response bodies are hashed, not stored, unless you turn retention on, and many receipts hold hashes rather than content. People recorded by the consent, terms-acceptance, decision, exam, erasure and disclosure tools are identified only by a hash salted with a key we keep for your workspace and give out only to it. Without the salt, a hash cannot be linked back to a person. A hash reveals nothing about the content it was made from.
• EU storage. On the Free, Starter, Pro, Pro+ and Team plans, data in the three European regions (Europe Central, Europe West and Europe North), receipts included, is stored under Cloudflare's EU jurisdiction. On the Scale and Enterprise plans and with the isolation add-on, it is stored, receipts and their write-once copy included, in the workspace's own Amazon Aurora database, in the AWS region the workspace chose.
• 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, 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@agined.com.