This policy describes how Avalori (Gruppo Suma LLC) handles the personal data of platform users (name, email, session activity). Institutional data uploaded to the platform (COUNTER reports, proxy logs, etc.) is governed by the Data Processing Agreement.
1. Data controller
Gruppo Suma LLC, Florida, United States. Privacy contact: [email protected].
2. Data we collect
| Data | Purpose | Legal basis |
|---|---|---|
| Name and email address | Account creation and service communications | Performance of contract |
| IP address and user agent | Security and fraud detection | Legitimate interest |
| Access and activity logs | Security audit and technical support | Legitimate interest |
| Application preferences | Personalization of experience | Performance of contract |
We do not collect sensitive personal information (health, financial, racial or ethnic origin, etc.).
3. Use of data
We use your personal data to:
- Create and manage your user account.
- Provide the Service and deliver technical support.
- Send operational notices (maintenance, critical updates).
- Comply with legal obligations.
We do not use your personal data for third-party advertising or commercial profiling.
4. Sub-processors and transfers
| Provider | Function | Location |
|---|---|---|
| Supabase, Inc. | Database and authentication | United States |
| Vercel, Inc. | Application hosting and delivery | United States |
All sub-processors operate under data processing agreements and maintain appropriate security safeguards.
5. Retention
We retain personal data for the life of the account and up to 90 days after deletion. Activity logs are deleted after 12 months.
6. Your rights
Depending on your state of residence, you may have the following rights:
- Access: request a copy of the personal data we hold about you.
- Correction: request correction of inaccurate or incomplete data.
- Deletion: request deletion of your personal data.
- Portability: receive your data in a structured, machine-readable format.
- Opt-out: where applicable, opt out of specific processing activities.
To exercise these rights, email [email protected]. We will respond within 30 calendar days.
If you are a California resident, you may have additional rights under the CCPA. We do not sell personal information as defined by the CCPA.
7. Cookies
The Service uses only strictly necessary cookies for authenticated session management. We do not use tracking or third-party advertising cookies.
8. Security
We implement reasonable technical and organizational measures including encryption in transit (TLS 1.2+), encryption at rest (AES-256), role-based access control, and audit logging of administrative access.
9. Changes to this policy
We will notify users of material changes by email at least 15 days before they take effect. The current version is always available at avalori.net/legal/privacy.
10. Governing law
This Privacy Policy is governed by the laws of the State of Florida. For users in other jurisdictions, we comply with applicable local privacy laws to the extent required.
11. Contact
[email protected] · Gruppo Suma LLC · Florida, United States.