Privacy Policy

Definitions

• DATA: Data about a living individual who can be identified from those data.
• DATA CONTROLLER: A natural or legal person who determines the purposes for which and the manner in which any personal data are processed. For the purpose of this Privacy Policy, Half Dome Labs LLC (d/b/a Avalinta) is the Data Controller of your data.
• DATA PROCESSOR (OR SERVICE PROVIDER): Any natural or legal person who processes data on behalf of the Data Controller.
• DATA SUBJECT / THE USER: Any living individual using our website or service whose Personal Data is collected.

Data Controller Identity

Legal Context & GDPR Compliance

We abide by the regulatory framework established by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and any other applicable laws relating to personal data protection.

Under the GDPR, Half Dome Labs LLC acts as a Data Controller for personal information collected through our website (such as waitlist registrations and customer inquiries). We determine the purposes and means of processing your data to manage and operate our services effectively.

What kind of personal information do we process?

We strictly collect and process personal data that is relevant, adequate, and necessary for the intended purpose:

• Contact Data: Your email address provided when signing up for our pre-launch waitlist or contacting support.
• User Interest Data (Optional): Service interest selections (e.g. DNV renewal, first application, Non-resident NIF) and any optional notes you voluntarily provide.

We do not collect sensitive data, biometric credentials, or full identity documentation on this pre-launch website.

How do we use your personal information & Legal Basis

Your personal information will never be processed for incompatible purposes. We process data strictly for explicit and legitimate purposes:

• Waitlist Registrations & Product Updates: To notify you when Avalinta opens, share early access information, and provide relevant updates regarding your selected interest.
  → Legal Basis: Explicit Consent (Article 6(1)(a) GDPR). You may withdraw consent at any time.
• Client Support & Outreach: To respond to inquiries sent directly to us by potential clients.
  → Legal Basis: Legitimate Interest (Article 6(1)(f) GDPR).

We do not use automated decision-making or profiling without your knowledge, nor do we sell, rent, or trade your personal information.

Who can access your personal information?

We carefully select third-party recipients who support our business operations:

• Authorized Employees & Contractors: Granted access strictly on a need-to-know basis to fulfill operational duties.
• Brevo (Sendinblue SAS): CRM and email automation platform used for managing waitlist subscriptions.
• Cloudflare, Inc. (Turnstile): Automated security and bot protection service to prevent form spam abuse.
• Google LLC: Cloud workspace and email hosting.

All data processors are bound by Data Processing Agreements (DPAs) in accordance with Article 28 of the GDPR.

Where do we transfer your personal information?

Because Half Dome Labs LLC is a US-registered company (Wyoming), personal data submitted on this website is directly transferred to and processed in the United States by the Data Controller. International data transfers to the US are safeguarded by appropriate measures, including European Commission-approved Standard Contractual Clauses (SCCs) pursuant to Article 46 of the GDPR and explicit user consent provided upon registration.

Our third-party service providers operate as follows:

• Brevo (Sendinblue SAS): Based in France. Primary data storage and processing occur within the European Union.
• Cloudflare, Inc.: Located in the United States. Used for bot verification via Cloudflare Turnstile in invisible mode. Processing is governed by Cloudflare’s Turnstile Privacy Addendum and the EU-U.S. Data Privacy Framework.
• Google LLC: Located in the United States. Transfers rely on the EU-U.S. Data Privacy Framework and Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to Article 46 of the GDPR.

How long do we store your personal information?

Waitlist contact data is retained until you request deletion, withdraw your consent, or when waitlist outreach concludes. Upon fulfillment of these purposes, personal data is securely erased or anonymized.

How do we protect your personal information?

We implement technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure in compliance with GDPR safety guidelines.

What are your rights and how to exercise them?

Under Articles 12 to 23 of the GDPR, you hold the following rights over your personal data:

• Access: Request access to and a copy of your personal data.
• Rectification: Request modification of inaccurate or incomplete data.
• Erasure: Request deletion of your data where legal grounds apply.
• Object (Article 21 GDPR): Object at any time to the processing of your personal data where we rely on legitimate interests as our legal basis.
• Restriction: Request restriction of processing under certain conditions.
• Withdrawal of Consent: Opt-out from previously given consent at any time without affecting prior lawful processing.
• Data Portability: Request transfer of your data to yourself or a third party in a structured format.

You may exercise any of these rights by emailing support@avalinta.com.

Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children.

Policy Changes

This Privacy Policy may be updated periodically to maintain compliance with legal updates. Material changes will be posted directly on this page with an updated “Last updated” date.

Contact Us

If you have any questions or requests regarding this Privacy Policy, please reach out to us at:

Email: support@avalinta.com