PRIVACY POLICY

Last updated: March 2025

This privacy notice for Avery Technology LLC and its European affiliate Eagle Ventures Ltd (“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:

• Visit our website at https://averyapp.ai, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

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:

• Email addresses
• Billing addresses
• Payment information (handled securely by Stripe or GoCardless)
• Google account information (email, spreadsheet access)

Sensitive Information:

We do not process sensitive personal information.

Payment Data:

Payment details are handled by Stripe (for global users) and GoCardless (for EU/UK users). See their privacy notices:

• Stripe Privacy Policy
• GoCardless Privacy Policy

Information automatically collected

We collect device and usage data such as:

• IP address
• Browser/device characteristics
• OS and settings
• Referrer URL
• Country/location
• Activity on our Services

2. HOW DO WE PROCESS YOUR INFORMATION?

We use your information to:

• Create and manage your account
• Provide services and customer support
• Send administrative info (terms updates, etc.)
• Request feedback
• Send marketing content (if opted-in)
• Detect and prevent fraud
• Analyze service usage trends
• Protect health/safety in emergencies

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:

• Consent
• Performance of a Contract
• Legal Obligations
• Legitimate Interests
• Vital Interests

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

We share your data only when necessary:

• Stripe for payment processing (non-EU)
• GoCardless for SEPA/eurozone payments
• Plaid to securely link banking accounts (Plaid Privacy Policy)
• Google Authentication to authorize Google Sheets access (Google API Policy)

We do not sell your personal data.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We use cookies and similar tools to:

• Maintain platform security
• Save user preferences
• Improve usability and functionality

You can control cookies via your browser settings.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain your data only as long as necessary for service provision and legal compliance. When no longer needed, we delete or anonymize your data securely.

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.

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:

• Access or correct your data
• Request deletion
• Withdraw consent
• Object to processing
• File a complaint with a regulator

To exercise these rights, email charlie@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.

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

Email: charlie@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 charlie@averyapp.ai or submit a data subject access request.

14. HOW DO YOU USE GOOGLE USER DATA?

• Access primary Google Account email to set up Avery account
• Enable daily transaction syncing to Google Sheets
• View/edit Sheets to update balance and transaction data
• Display embedded app interfaces in sidebars or pop-ups via Google Workspace

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

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