Privacy Policy & Cookie Notice

Avian Labs, Inc. and its affiliates (“we,” “us,”  “our,” or we just say “Avian Labs”) value the privacy of individuals who use our mobile applications, websites, and related services (collectively, our “Services”).

This policy covers Avian Labs, Inc. and its affiliates. This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users,” “you,” and/or “your”). If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “information” means any information relating to an identified or identifiable individual.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it. 

1. Information You Provide to Us.

Registration and Profile Information. When you sign up, register to use our Services, sign up for notifications or updates, or participate in our user research or feedback surveys, or at other times in connection with our Services, we ask you for your name, address, email address, phone number, identity documents such as a passport or driver’s license, address verification documentation, photographs and other biometrics.

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.  If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. 

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience.

Payment Information. If you make a transaction through our Services, your payment-related information, such as debit card number, bank account numbers, or other financial and account information, is collected by us or our third-party payment processor on our behalf. 

2. Information We Collect When You Use Our Services.

Location Information. We infer your general location information, for example by using your internet protocol (IP) address.

Device Information. We receive information about the device and software you use to access our Services, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, transactions you enter into, and other information related to your usage of the services.

Your Contacts. If you permit us to access the address book on your device or give us permission to import your contacts from an email account associated with your account, we will access and store names and contact information from your address book to facilitate interactions that you initiate through our Services and for other purposes described in this privacy policy or at the time of consent or collection. We also collect your contacts if you invite them to use our Services or share information or content with them from our Services. This is referred to as Sling Directory.

Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on our Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details.

Below is an overview of the types of Cookies we and third parties may use to collect information.

Strictly Necessary Cookies. Some Cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of Cookies. These cookies stay on your browsing device until they expire or are deleted. We do not have any Necessary Cookies on this website, at this time.

Functional Cookies. Functional Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region. We do not use any Functional Cookies on this website, at this time.

Analytical or Performance Cookies. We use Cookies for website analytics purposes in order to operate, maintain and improve our Services. We do not use any Analytical or Performance Cookies on this website, at this time.

Advertisement Cookies: We could use Cookies to customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns. We do not use any Advertisement Cookies on this website, at this time.

Data Collection through Measurement and Optimization SDKs: Our app integrates the Measurement and Optimization Software Development Kits (‘SDK’), such as the Facebook SDK, to optimize advertisements we place in order to acquire new users or deepen our engagement with existing users, and to analyze app usage. We may share some limited, anonymized data with Facebook in order to optimize ads for Sling that run on Facebook. Doing this helps us reduce our customer acquisition costs, allowing us to provide the Sling service at a lower cost to you and others like you. Please note that Meta and Facebook, as third-parties, have their own data use policies.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

3. Information We Receive from Third Parties. 

Information from Third Party Services. To use our Services, you may be required to allow us to access information held in a third-party account held by you, such as when you login to your account with us using your credentials with Google or Apple. In this case, we will receive information about you, including your profile information and your photo, and your use of the third party account. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.

Other Third Parties. We may receive additional information about you, from third parties such as data or marketing partners and combine it with information we have about you. We may receive information about you from our partners in connection with fraud, identity verification , and other purposes related to legal compliance.

How We Use the Information We Collect

We use the information we collect: 

• To provide, maintain, improve, and enhance our Services;

• To personalize your experience on our Services such as by providing tailored content and recommendations; 

• To verify your personal information to allow access to our products and Services; 

• To understand and analyze how you use our Services and develop new products, services, features, and functionality;

• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;

• To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for any lawful purpose;

• To send you text messages and push notifications;

• To facilitate transactions and payments;

• To find and prevent fraud and abuse, and respond to trust and safety issues that may arise; 

• For compliance purposes;

  • including enforcing our Terms of Service or other legal rights,

  • as may be required by applicable laws and regulations, such as the Transfer of Funds Regulations 'Travel Rule',

  • or as requested by any judicial process or governmental agency; and

• For other purposes for which we provide specific notice at the time the information is collected.

Legal Bases For Processing European Information

If you are located in the European Economic Area (EEA) or the United Kingdom, we only process your information when we have a valid “legal basis,” including as set forth below.

• Consent. We may process your information where you have consented to certain processing of your information. For example, we may process your information to use Cookies where you have consented to such use.

• Contractual Necessity. We may process your information where required to provide you with our Services. For example, we may need to process your information to respond to your inquiries or requests.

• Compliance with a Legal Obligation. We may process your information where we have a legal obligation to do so. For example, we may process your information to comply with tax, labor and accounting obligations.

• Legitimate Interests. We may process your information where we or a third party have a legitimate interest in processing your information. Specifically, we have a legitimate interest in using your information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

  
  

How We Disclose the Information We Collect

We do not disclose information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may disclose any information we receive to our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Third Party Service Providers. We may disclose any information we receive to vendors and third party service providers retained in connection with the provision of our Services.

Third Party App Integrations. If you connect a third-party application to our Services, such as our third-party identity verification partners, we may disclose certain information about you including your identification card, name, date of birth, and address, to such third parties.

Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

Advertising Practices. While we do not display ads within our app, we may engage in advertising activities on other platforms. We may use tracking and interest-based mechanisms on our website and app to improve ad targeting to specific audiences. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you prefer not to receive personalized ads, you can visit their opt-out pages to learn how to opt out of web-based personalized ads from member companies. Additionally, you can utilize settings provided by your mobile operating system to limit ad tracking, or install the AppChoices mobile app to learn more about opting out of personalized ads in mobile apps.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Consent. We may also disclose your information with your permission.

Your Choices

Account Settings. If you create an account with us, you may edit, update or delete your account by accessing your account settings in the application or on the website. We may retain some information to provide you with support, resolve disputes, and comply with our legal obligations.

Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.

Contacts. You may enable or disable the sharing of contacts information through your account settings and your device’s operating system settings.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the information we maintain about you, update and correct inaccuracies in your information, restrict or object to the processing of your information, have your information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your information to another company. In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. By using our Services, you consent to our use of Cookies and our processing of information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Services may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

Third Parties

Our Services will contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Retention

We take measures to delete your information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When we process information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and applicable law.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

To use our Services, you must be 18 years of age. We do not knowingly collect, maintain, or use information from children under 18 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with information in violation of this Privacy Policy, then you may alert us at [email protected].

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Additional Privacy Disclosures

For more information about how we collect, use, and share your Biometric Data, please review our Biometric Privacy Notice available at https://sling.money/legal/biometric-privacy-notice.

Contact Information

Avian Labs is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at [email protected] or write to us at Avian Labs Inc., 8 The Green Suite #12690, Dover, DE 19901.