PRIVACY POLICY

Last updated: March 2026

This privacy notice for Avery Technology LLC (our United States entity) and its European affiliate Eagle Ventures Ltd (our European entity, registered in Ireland) (collectively "we", "us", or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you provide to us when you register on the Services, express an interest in obtaining information, participate in activities, or otherwise contact us.

Personal Information Provided by You:

Sensitive Information:

We do not process sensitive personal information.

Payment Data:

Our payment processing is handled by different providers depending on your region and the contracting entity. Avery Technology LLC (our US entity) processes payments via Stripe and facilitates bank account linking via Plaid. Eagle Ventures Ltd (our European entity) processes payments via GoCardless using SEPA or local direct debit. See their privacy notices:

Information automatically collected

We collect device and usage data such as:

2. HOW DO WE PROCESS YOUR INFORMATION?

We use your information to:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

If you are in the EEA or UK, we rely on the following legal bases:

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We share your data only when necessary:

We do not sell your personal data.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We use cookies and similar tracking technologies (such as pixels and local storage) to operate, secure, and improve our Services. Cookies fall into: (a) Strictly Necessary, for site functionality and security; (b) Functional, to save your preferences; (c) Analytics, to understand usage patterns. We do not use cookies for third-party advertising.

You can control or disable cookies through your browser settings. Disabling certain cookies may affect functionality. Where required by law, we obtain your consent before placing non-essential cookies.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain your data for as long as necessary to fulfil the purposes in this notice: (a) Account data is retained while your account is active and deleted within 30 days of closure; (b) Billing and transaction records are kept for up to 7 years for tax and legal compliance; (c) Usage and analytics data is retained in aggregated or anonymised form; (d) Support correspondence is retained for up to 2 years after your last interaction. When data is no longer needed, we securely delete or anonymise it.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We implement industry-standard organizational and technical safeguards. However, no digital transmission or storage can be guaranteed 100% secure. INTERNATIONAL DATA TRANSFERS: Because we operate through both Avery Technology LLC (US) and Eagle Ventures Ltd (Ireland), your personal data may be transferred between the United States and the European Economic Area. Where such transfers occur, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission to ensure your data receives an adequate level of protection.

8. DO WE COLLECT INFORMATION FROM MINORS?

No. Our services are not intended for individuals under 18. If we learn we have collected information from a minor, we will delete it.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your location, you may:

To exercise these rights, email support@averyapp.ai.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Some browsers offer a "Do Not Track" (DNT) setting. Currently, no standard exists for responding to DNT signals, so we do not respond to them at this time. CALIFORNIA RESIDENTS (CCPA/CPRA): If you are a California resident, you have additional rights under the California Consumer Privacy Act and the California Privacy Rights Act, including: the right to know what personal information we collect and how it is used; the right to request deletion of your personal information; the right to opt out of the sale or sharing of personal information (we do not sell or share your data); and the right to non-discrimination for exercising your privacy rights. To exercise these rights, contact support@averyapp.ai.

11. DO WE MAKE UPDATES TO THIS NOTICE?

Yes. We will update this privacy notice as needed to stay compliant. Any significant changes will be communicated.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Avery Technology LLC (United States)

Email: support@averyapp.ai

EU Representative:

Eagle Ventures Ltd (Ireland)

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Email us at support@averyapp.ai or submit a data subject access request.

14. HOW DO YOU USE GOOGLE USER DATA?

Compliance: Avery’s use of Google APIs complies with the Google API Services User Data Policy, including Limited Use requirements.

15. FREE TRIALS AND SUBSCRIPTION CONSENT — By activating a free trial of our Services, you acknowledge and agree that you have read, understood, and consent to be bound by this Privacy Policy and our Terms of Service. Your use of the Services during the trial period constitutes acceptance of these terms. If your trial converts to a paid subscription (whether automatically or through your continued use), you acknowledge that the same privacy practices described herein will continue to apply to your paid subscription. For full details on trial terms, billing, and refund policies, please refer to Section 3 of our Terms of Service.