This biometric privacy notice explains how Avian Labs Inc. Inc. (“we, “us,” our, or “Avian Labs”) collects, uses, shares, retains, and destroys your Biometric Data when you use our services.

“Biometric Data” includes: (i) “Biometric Identifiers,” which are data generated by measurements of your biological characteristics, such as your retina or iris scan, fingerprint, voiceprint, or a scan of your hand or facial geometry; and (ii) “Biometric Information,” which is information based on a Biometric Identifier that can be used to identify you. 

Please review this notice carefully. By agreeing to our collection of your Biometric Data, you consent to the collection, use, sharing, and retention of your Biometric Data as described in this notice.

What type of Biometric Data do we collect?

Facial Geometry

How do we collect it?

During onboarding, we collect your name, date of birth, email address, phone number, and location. This data is used to create a restricted account and facilitate the subsequent identity verification process. We require our users to provide a selfie and we may require a photo of your government-issued ID as part of our onboarding process, this is to ensure verification of your identity and helps prevent fraud.

How do we use and share it? 

The personal data you provide during onboarding is used to grant you restricted access to the app. This restricted mode allows you to explore the app while ensuring that financial services remain disabled until your identity is verified.

Your data may also be shared with third-party providers to initiate verification when you proceed to enable full functionality.

We share your identity information and selfie with our third-party service provider, Persona, who can compare the face geometry extracted from your ID and selfie to securely verify your identity.

For residents of the United States, where we partner with Paxos Trust Company, your identity information and selfie is shared with them to ensure Paxos adhere to their regulatory and legal obligations.

Additionally, where we partner with Beam, your identity information and selfie is shared with them to ensure Beam adhere to their regulatory, partner and legal obligations.

How long do we retain your Biometric Data?

• Avian Labs maintains a copy of your ID and selfie for identity verification purposes and to comply with our legal record keeping requirements up to five years from your account closure.

• Our service provider, Persona, deletes your information within three years from your last interaction with Persona.

• Our partner, Paxos, maintains your information for up to five years from your last interaction with them.

• Our partner, Beam, maintains your information for up to five years from your last interaction with them.

What happens to your Biometric Data at the end of the retention period?

Data collected during onboarding will be retained for a three (3) years for users who do not complete the identity verification process. If verification is not pursued or completed within this timeframe, the data will be securely deleted unless otherwise required by legal or regulatory obligations.

Our service providers and partners permanently erase your Biometric Data at the end of the applicable retention period described above such that it cannot be recovered or reconstructed.

Additional Privacy Disclosures and Your Rights

For more information about how we collect, use, and share your personal information, as well as your rights and choices concerning our data practices, please review our Privacy Policy available at https://sling.money/legal/privacypolicy-cookienotice.