Avery Privacy Policy

1) Scope & Roles

• Controller vs. Processor. For data about our own relationships (e.g., our website visitors, prospects, and your account with us), Starlight acts as a business/controller. For data we handle inside Avery on behalf of property-management customers (e.g., tenant/owner/vendor data), we typically act as a service provider/processor under applicable U.S. privacy laws and our customer agreements govern.
• U.S. focus. We operate and host the Services in the United States and do not target users outside the U.S.

2) Information We Collect

We collect information (a) directly from you, (b) automatically from your device/interactions, and (c) from third parties/integrations you or our customers enable.

A. Information you (or your organization) provide

• Identifiers & contact: name, email, phone number, postal address.
• Account & profile: role (property manager/owner/vendor/tenant), units, properties, apartment preferences.
• Payments: details needed to process rent/fees. Payments are processed by partners such as Stripe. We generally receive limited payment metadata (e.g., last-4 digits, card brand, expiration), and we do not store full primary account numbers.
• Communications & uploads: messages, photos, videos, and documents (e.g., work-order images, inspection files, invoices) submitted via app, email, phone/voice, and SMS/MMS.
• Government IDs or similar if you choose to provide them via our communication channels (e.g., for screening/verification handled by your property manager).

B. Information collected automatically

• Device/usage: IP address, device identifiers, browser/OS info, app version, referring/exit pages, pages viewed, links clicked, session timestamps, and general location inferred from IP.
• Cookies & similar: We use cookies/local storage for authentication and to operate/improve the Services (see §4).

C. Information from third parties/integrations you enable

• Integrations you connect or use: We receive/share data as needed to operate integrations such as QuickBooks, Zillow, Apartments.com, Twilio, Google Maps, Stripe, Facebook, and others you or our customers enable.

3) How We Use Information

We use information to:

• Provide and operate the Services (accounts, authentication, role-based access, property/unit records, move-ins, work orders, maintenance workflows, payments, communications).
• Communicate with you, including transactional notices (login codes, work-order updates, rent reminders) and, where permitted, marketing emails/SMS.
• Support & safety (customer support, troubleshooting, reliability, fraud/abuse prevention, enforcing terms, and legal compliance).
• Improve and develop the Services (analytics, performance monitoring, product research).
• AI/automation features: We use data—including messages sent and received through Avery—to develop, train, and improve AI-powered and automated features (e.g., routing, summarization, categorization, suggested responses). We apply safeguards to reduce the risk of exposing sensitive content and restrict employee access to authorized personnel. Where required by law or contract, we honor limitations or opt-out choices provided to us.

4) Cookies, Analytics, and Similar Technologies

• Cookies/local storage help with login/authentication and remembering settings. You can disable cookies in your browser, but some features may not work.
• Analytics/monitoring: We use PostHog, Sentry, Google Analytics, and Google Ads (via Google Tag Manager) to understand usage, measure advertising effectiveness, diagnose issues, and improve performance. These tools may set their own cookies or collect device/usage data as described in §2B.

5) When We Disclose Information

We disclose information as follows:

• At your (or your organization's) direction: e.g., sharing owner/tenant/vendor info within workflows; publishing listings; using enabled integrations.
• Service providers/contractors: e.g., Twilio (telephony/SMS), AWS SES (email), hosting on Google Cloud Platform and Amazon Web Services, analytics/monitoring (PostHog, Sentry, Google Analytics), advertising measurement (Google Ads), payments (Stripe). These parties may access personal information only to perform services for us and are bound by confidentiality/contractual obligations.
• Integration partners you choose: e.g., QuickBooks, Zillow, Apartments.com, Google Maps, Facebook, and similar.
• Legal, safety, and compliance: to comply with law, enforce terms, and protect rights, safety, or property of Starlight, users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of all/part of our business.

We do not sell personal data. Some U.S. laws define "share" for cross-context behavioral advertising differently from "sell." If activity qualifies as "sharing," we provide required opt-outs and honor applicable signals.

6) SMS, Voice, and Call Features

You may interact with Avery by calling or texting our phone line without creating an account.

• We may log message/call metadata (time/date, phone numbers, duration) and store message content to deliver Services.
• If calls are ever recorded, we provide legally required notice.
• Message frequency varies. Message and data rates may apply.
• To stop marketing texts, reply STOP; for help, reply HELP. Transactional texts (e.g., login codes, urgent maintenance) may continue where permitted.

7) Data Retention

We retain personal information as long as our customers need it for operational purposes and as permitted by law (e.g., to comply with legal obligations, resolve disputes, enforce agreements). Retention varies by customer and record type. When information is no longer needed, we may delete or de-identify it consistent with our policies and applicable law.

Export/Deletion: Some data can be exported or deleted on request (see §9). Certain records (e.g., legal, billing, security logs, backups) may be retained where required or permitted.

8) Security

We use administrative, technical, and physical safeguards designed to protect personal information, including least-privilege access for authorized employees, account-level controls, logging/monitoring, and encryption in transit. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9) Your Privacy Rights & Choices

Your rights and choices depend on your relationship with us and where you live.

A. Account & notification settings

• Manage notifications: You can opt out of marketing emails/SMS (unsubscribe links or reply STOP). Transactional/service-related messages may still be sent.
• Cookies/analytics: Control cookies via browser settings.

B. Requests regarding your data

Subject to verification, applicable law, and our role when acting as a service provider for our customers, you may request:

• Access/Know categories and specific pieces of personal information we have collected about you.
• Correction of inaccurate personal information.
• Deletion of personal information.
• Portability of certain information.
• Opt-out of (i) sale of personal information (we do not sell personal information) and (ii) sharing for cross-context behavioral advertising, if applicable.
• Limit use of sensitive personal information, where required.

How to submit: email privacy@avery-hq.com.

If we processed your information on behalf of a property-management customer, we may forward your request to that customer or ask you to contact them directly. Where required, we honor Global Privacy Control (GPC) or similar signals for opt-outs.

Residents of certain U.S. states (e.g., CA, CO, CT, VA, UT) may have additional rights. You may also have the right to appeal a decision we make regarding your request; appeal instructions will be provided if we deny a request.

10) Children

The Services are intended for adults and are not directed to individuals under 18. We do not knowingly collect personal information from children. If you believe a child provided information to us, contact privacy@avery-hq.com.

11) International Users

We do not target users outside the United States. If you use the Services from outside the U.S., you understand your information will be processed in the U.S., where laws may differ from those in your jurisdiction.

12) Third-Party Links & Services

The Services may link to or integrate with third-party websites, apps, and services. We are not responsible for their privacy practices. Review their privacy policies before providing personal information.

13) Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated Policy with a new "Last updated" date and, for material changes, provide additional notice (e.g., email, in-app message, or prominent notice).

14) How to Contact Us

Starlight Energy, Inc.

1606 Headway Cir STE 9312

Austin, TX 78754, United States

Email: legal@avery-hq.com