Privacy Notice

1. Controller

EFUPAL LLC ("we", "us"), operator of AVENUEOS™ ULTRA (the "Service"), is the data controller responsible for personal data processed through the Service.

2. Categories of personal data we collect

• Account data: name, email address, authentication identifiers.
• Support data: messages you send us and their contents.
• Usage and telemetry: product events, feature usage, log data.
• Device data: IP address, browser type, device identifiers.
• Billing metadata: plan, subscription status, invoice references (payment card and tax details are collected and processed directly by Paddle as Merchant of Record).

3. Purposes and legal bases

• Creating and managing your account and providing the Service — performance of contract.
• Customer support — performance of contract and legitimate interests.
• Security, abuse and fraud prevention — legitimate interests and legal obligation.
• Product improvement and analytics — legitimate interests.
• Service-related communications — performance of contract.
• Marketing communications (where applicable) — consent, which you may withdraw at any time.

4. Sharing

We share personal data with the following categories of recipients:

• Service providers / subprocessors: hosting, database, email delivery, analytics and support tooling providers acting on our instructions.
• Merchant of Record: Paddle handles the sale of subscriptions, subscription management, payments, tax compliance and invoicing.
• Professional advisers: legal, accounting and similar advisers, under confidentiality.
• Authorities: where required by law or to protect rights, property or safety.

5. Retention

We keep personal data only for as long as necessary for the purposes described above, to comply with legal obligations, or to resolve disputes. When no longer needed, data is deleted or anonymized.

6. Security

We use appropriate technical and organisational measures, including encryption in transit, access controls, and least-privilege administration, to protect personal data.

7. Your rights

Subject to applicable law, you may have the right to access, correct, delete, restrict, or port your personal data, to object to certain processing, and to withdraw consent where processing is based on consent. Where GDPR or UK GDPR applies, you also have the right to lodge a complaint with your local supervisory authority. We aim to respond to requests within one month.

8. International transfers

Personal data may be processed in countries outside your own, including the United States. Where such transfers occur from the UK/EEA, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.

9. Cookies

We use strictly necessary cookies to operate the Service (authentication, security). Where we use analytics or marketing cookies, we request consent and provide controls to manage your preferences.

10. Contact

To exercise your rights or ask questions about this notice, contact EFUPAL LLC at privacy@avenueos.space, or by mail at 1001 S. Main St. #7973, Kalispell, MT 59901, USA.