12 Oct 2023

Biometric Privacy Notice

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?

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? 

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.

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.

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

Our service providers 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.