Privacy Policy
Last updated: June 5, 2026
Avior is a brand of Avior Technology, Inc. ("Avior", "we", "us" or "our"), a financial technology company. This Privacy Policy describes how we process personal information that we collect through our website, mobile application, and related services that link to this Privacy Policy (collectively, the "Service"), as well as through our marketing and other activities described here. We may provide additional or supplemental privacy notices for specific products at the time we collect personal information.
For clarity, this Privacy Policy does not apply to any decentralized aspect of the public blockchains we interact with that we do not control.
European users: please see the "Notice to European Users" section below for additional GDPR / UK GDPR information.
Personal information we collect
Information you provide to us.
- Contact data, such as your first and last name, email address, mailing address, and phone number.
- Demographic data, such as your city, country of residence, postal code, and age.
- Profile data, such as username, password, avatar, date of birth, company details, and information you add to your account.
- Business data (for business accounts), such as company name, registration details, beneficial-ownership information, and authorised-signatory details.
- Communications data based on our exchanges with you.
- Marketing data, such as your preferences for receiving our communications.
- Transactional data, such as information relating to your transactions, including transaction numbers and history.
- Blockchain activity data, such as wallet address, transaction number, sender and recipient, amount, and on-chain history associated with your account or wallet.
- Financial data, such as your account or wallet balance and associated information.
- Government-issued identification data, such as national identification number, tax identification number, passport or ID number, and an image of the relevant document, collected for identity verification.
Identity verification and biometric data. To verify your identity (KYC/KYB), we use a third-party service provider, Sumsub, which collects and uses biometric information, including facial data, from your ID document to match against your live image. Avior does not directly store this biometric data. It is held by Sumsub pursuant to its privacy notice, and retained for the period required by applicable anti-money-laundering law (typically up to five years after the end of the business relationship), after which it is deleted.
Third-party sources. We may combine information you provide with information from public sources (government agencies, public records, public blockchains), private sources (data providers, sanctions and screening lists), our service providers, and business-transaction partners.
Automatic data collection. We and our providers automatically log device data (device type, OS, browser, IP address, identifiers, general location), online activity data (pages viewed, navigation, access times, email opens and clicks), and communication-interaction data.
How we use your personal information
- Service delivery and operations: to provide and operate the Service, enable security features, establish and maintain your account, communicate with you, and provide support.
- Personalization: to understand your needs and tailor your experience.
- Improvement and analytics: to analyse usage and improve the Service.
- Marketing: to send you communications, which you can opt out of at any time.
- Compliance and protection: to comply with applicable law (including anti-money-laundering, KYC/KYB, sanctions and tax-reporting obligations), respond to lawful requests, enforce our terms, and prevent and investigate fraud and illegal activity.
- Aggregated/de-identified data: to create and use anonymized data for lawful business purposes.
How we share your personal information
- Corporate affiliates.
- Service providers that operate the Service or our business, including account and payment infrastructure (Due), self-custodial wallet technology (Dfns), card issuing and processing (Rain / Signify Holdings, Inc.), identity verification (Sumsub), hosting, analytics, and communications.
- Third parties designated by you, including for KYC/KYB and AML checks.
- Partners with whom we jointly offer or co-promote products.
- Authorities and others, where necessary to comply with law or protect rights, safety and property.
- Business transferees, in connection with a merger, acquisition, financing, or insolvency.
- Other users and the public: due to the nature of blockchain, any data written to a public blockchain will be visible to others and may be used to identify you through your public wallet address. We are not responsible for such use.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including legal, accounting, regulatory and fraud-prevention requirements. AML/KYC records are retained for the period required by law (typically up to five years after the end of the business relationship). When no longer required, we delete, anonymize, or isolate the data from further processing.
Your choices
- Access or update your account information by logging in.
- Opt out of marketing via the unsubscribe link in our emails.
- Cookies: manage preferences via our Cookie Policy.
- Declining to provide information: we need certain information to provide the Service and to meet legal obligations; without it we may not be able to provide some or all of the Service.
Note: due to the nature of blockchain, neither you nor Avior may be able to delete transactions already recorded on a public blockchain.
Security
We employ technical, organizational and physical safeguards designed to protect personal information. However, no system is completely secure and we cannot guarantee absolute security.
International data transfers
Avior Technology, Inc. is based in the United States (Delaware) and may use service providers in other countries. Your personal information will be processed in the United States and may be transferred to other countries whose laws may not be as protective as those in your country. European users should read the transfer information in the Notice to European Users below.
Children
The Service is not intended for anyone under 18. If we learn we have collected personal information from a child without required consent, we will delete it in accordance with applicable law.
Changes to this Privacy Policy
We may modify this Privacy Policy at any time. Material changes will be notified by updating the date and posting on the Service or by other appropriate means.
How to contact us
Email: legal@useavior.com
Avior Technology, Inc., [registered address]
Notice to European Users
This section applies to individuals in the European Economic Area (EEA) or United Kingdom.
Personal information in this Policy includes "personal data" as defined in the EU GDPR and UK GDPR.
Controller. Avior Technology, Inc. is the controller in respect of the processing covered by this Policy.
Legal bases for processing:
- Contractual necessity, where we need to process your data to deliver the Service.
- Legitimate interests, where processing is necessary for our legitimate interests and not overridden by your rights (e.g., security, service improvement, marketing of our own services).
- Compliance with law, including AML/KYC, sanctions and tax-reporting obligations.
- Consent, where required (e.g., certain marketing and optional cookies).
Your rights. Subject to applicable law, you may request access, correction, deletion, transfer (portability), restriction, and may object to processing or withdraw consent. To exercise these rights, contact us at legal@useavior.com. We aim to respond within one month.
Right to complain. You may lodge a complaint with your local supervisory authority (EEA: edpb.europa.eu; UK: ico.org.uk).
Transfers outside Europe. Where we transfer data outside Europe, we rely on adequacy decisions or appropriate safeguards (such as Standard Contractual Clauses), or, in limited cases, a permitted derogation such as your explicit consent.
No sensitive information. Please do not provide sensitive personal data except where specifically requested as part of identity verification.
No solely automated decision-making with legal effect is carried out as part of the Service.