Privacy Policy

1. Introduction

Avanza Energy (a DBA of Agilito, LLC) ("we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at avanza.energy (the "Site") and use our services.

By using the Site, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information You Provide

We may collect personal information that you voluntarily provide to us when you:

• Subscribe to our newsletter
• Create an account or subscribe to paid content via Substack
• Contact us via email or contact forms
• Register for events or webinars
• Download resources or reports

This information may include:

• Name
• Email address
• Company name and role (if provided)
• Professional interests and preferences
• Payment information (processed through Substack)

2.2 Automatically Collected Information

When you visit our Site, we automatically collect certain information about your device and browsing behavior, including:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referring website addresses
• Date and time of visits
• Device information

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Site. Cookies are small data files stored on your device. We use:

• Essential Cookies: Required for the Site to function properly
• Analytics Cookies: Help us understand how visitors use our Site (e.g., Google Analytics)
• Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. However, disabling cookies may affect your ability to use certain features of the Site.

3. How We Use Your Information

We use the information we collect to:

• Deliver newsletter content and strategic analysis to subscribers
• Process subscriptions and manage your account
• Respond to your inquiries and provide customer support
• Improve and personalize your experience on the Site
• Analyze Site usage and trends to enhance our services
• Send marketing communications (with your consent)
• Comply with legal obligations
• Prevent fraud and ensure Site security

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), our legal basis for collecting and using your personal information depends on the information concerned and the context in which we collect it:

• Consent: You have given us explicit consent to process your personal information for a specific purpose
• Contract: Processing is necessary to fulfill a contract with you (e.g., subscription services)
• Legitimate Interests: Processing is in our legitimate interests and not overridden by your rights (e.g., analytics, fraud prevention)
• Legal Obligation: Processing is necessary to comply with the law

5. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Substack: Our newsletter and content delivery platform (see Substack's privacy policy at https://substack.com/privacy)
• Email service providers: For sending newsletters and communications
• Analytics providers: Such as Google Analytics, to understand Site usage
• Payment processors: For handling subscription payments (via Substack)

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, subpoenas, government regulations).

5.3 Business Transfers

If Agilito, LLC or Avanza Energy is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Site of any change in ownership or use of your personal information.

5.4 With Your Consent

We may share your information for any other purpose with your explicit consent.

6. Third-Party Links and Services

Our Site may contain links to third-party websites and services, including Substack. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Substack: When you subscribe to our newsletter or paid content, you will be redirected to Substack, which operates as an independent platform. Your interactions with Substack are governed by Substack's Privacy Policy and Terms of Service.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Newsletter subscribers: Until you unsubscribe
• Account information: Until you request deletion or close your account
• Analytics data: Typically retained for 26 months (Google Analytics default)

8. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

8.1 General Rights

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Objection: Object to our processing of your personal information
• Restriction: Request restriction of processing your personal information
• Portability: Request transfer of your personal information to another service
• Withdraw Consent: Withdraw consent at any time (does not affect prior processing)

8.2 Unsubscribe from Communications

You can unsubscribe from our newsletter at any time by:

• Clicking the "unsubscribe" link in any email
• Contacting us at legal@agilito.com
• Managing your preferences in your Substack account

8.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: legal@agilito.com

We will respond to your request within 30 days (or as required by applicable law).

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit (SSL/TLS)
• Secure server infrastructure
• Access controls and authentication
• Regular security assessments

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from your country.

When we transfer your personal information internationally, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Privacy Shield certification (where applicable)
• Other legally recognized transfer mechanisms

11. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.

12. California Privacy Rights (CCPA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You can request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete: You can request deletion of your personal information (subject to exceptions)
• Right to Opt-Out: You have the right to opt-out of the sale of your personal information. Note: We do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

To exercise these rights, contact us at legal@agilito.com. We will verify your identity before responding to your request.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification to subscribers (for significant changes)

We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: