Privacy Policy

This Privacy Notice for Tethered Software LLC (“we,” “us,” or “our”), which operates Tethered, describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at www.jointethered.com, or any website or mobile application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@jointethered.com.

This summary provides key points from our Privacy Notice. You can find more detail on any of these topics by following the link after each key point or by using the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Yes. To provide the Services, we process financial data from the bank accounts you choose to connect, as well as your account login information. We do so with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? Yes, but only from Plaid Inc., which retrieves transaction data from the financial institutions you choose to connect. We do not buy data from data brokers, marketing partners, or social media platforms. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We share information with the accountability partner you designate, with Plaid, and with the service providers that help us run the Services. We never sell your personal or financial data. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way is to email us at support@jointethered.com. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?
2. How do we process your information?
3. When and with whom do we share your personal information?
4. Do we use cookies and other tracking technologies?
5. How long do we keep your information?
6. How do we keep your information safe?
7. Do we collect information from minors?
8. What are your privacy rights?
9. Controls for Do-Not-Track features
10. Do United States residents have specific privacy rights?
11. Do we make updates to this notice?
12. How can you contact us about this notice?
13. How can you review, update, or delete the data we collect from you?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

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

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. It may include:

• names
• phone numbers
• email addresses
• passwords
• contact or authentication data
• the name, email address, and phone number of the accountability partner you designate, used to invite them and deliver alerts and check-ins

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• financial data, including transaction amounts, dates, merchant names, and categories from accounts you connect
• account login information for your Tethered account

Payment Data. When you subscribe, your card or other payment details are collected and stored by our payment processors, Stripe (on our website) and Apple (in our iOS app). We never receive or store your full card number or security code. We keep the identifiers they give us, such as your Stripe customer and subscription IDs or your Apple transaction ID, along with your plan, subscription status, renewal and trial dates, and who pays for the subscription. You can find their privacy notices here: stripe.com/privacy and apple.com/legal/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected from other sources

In Short: We collect financial data from the institutions you connect, through Plaid. We do not buy data from data brokers or marketing partners.

Tethered uses Plaid Inc. (“Plaid”) to connect to your financial institutions and retrieve read-only transaction data, such as transaction amounts, dates, merchant names, and categories, from the accounts you choose to connect. Tethered never views, handles, or stores your bank login credentials, and we cannot move, withdraw, or otherwise touch your money.

“Tethered uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our service, you grant Tethered and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid End User Privacy Policy.”

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We process your financial data to track deposit budgets and streaks, and to identify wagering activity or connection issues that your accountability partner should know about.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our Services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information to send alerts, check-ins, and approval requests between you and your accountability partner.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

In Short: We share information with your accountability partner, with Plaid, and with the categories of service providers listed below. We do not sell, rent, or broker your personal or financial data.

Your Accountability Partner. Sharing with a partner you choose is the core of the Services. Once your partner confirms their invitation, they can see your name and contact details, flagged transactions (including amount, merchant, date, and the account it came from), your budget and streak status, requests you make to change your limits, and notices when a linked account is added, removed, or disconnected. Your partner cannot see your bank login credentials and cannot move your money.

Your partners are also told when your subscription is cancelled, when a payment for it is refunded or disputed, when you remove a partner who was paying for it, and when monitoring stops. If a partner pays for your subscription, they can see its plan, status, and renewal date, and you can see who pays for it.

Payment Processors. We share the information needed to start and manage a subscription, such as your email address and the identifiers described in Personal information you disclose to us, with Stripe for purchases on our website and with Apple for purchases in our iOS app.

Plaid. We share information with Plaid as needed to connect and maintain your linked accounts, as described in Information collected from other sources.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services
• Communication & Collaboration Tools
• Data Storage Service Providers
• Finance & Accounting Tools
• Financial Data Aggregators (Plaid)
• Payment Processors
• Performance Monitoring Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situation:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

In Short: We use only the cookies needed to keep you signed in and your account secure, and we note which of our ads or links brought you to us. We do not use advertising or third-party tracking cookies.

We use a small number of strictly necessary cookies to authenticate you, keep your session secure, and require you to sign in again after your browser is closed. In our mobile applications, we use secure on-device storage for the same purpose. These technologies are required for the Services to work and are not used to track you across other websites or apps.

How you found us. When you arrive at our website from one of our ads or from a link on another website, we save a note in your browser's local storage of where you came from, such as the ad campaign or the other website's address, for up to 30 days. If you create an account, we keep that note with your account so we can tell which of our ads and links bring people to Tethered. We don't share it with advertisers or use it to follow you on other websites.

We use Vercel Web Analytics to count page visits in aggregate. It doesn't use cookies, doesn't follow you across other websites, and doesn't identify you. We do not permit third parties to place advertising or cross-site tracking technologies on our Services, and we do not use your information for targeted advertising. Our Cookie Policy lists each cookie we use and why.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which you have an account with us.

If you disconnect a linked bank account, we revoke our Plaid access to it and stop collecting new data from it. Transaction history already collected from that account remains part of your activity record while your account is open, and is deleted along with the rest of your data when you delete your account.

When monitoring stops. If your subscription, free trial, or other free access ends and monitoring stops, we remove our Plaid access to your linked accounts right away. If monitoring stays stopped for 90 days, we delete your monitoring history (transactions, weekly reports, budget history, and streaks) even if you keep your account, after emailing you a warning about a week beforehand. Your account, goal, and partners are kept so you can pick up again by subscribing.

Stripe and Apple keep their own records of your payments under their privacy policies, including after you delete your Tethered account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@jointethered.com.

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the details in the section “How can you contact us about this notice?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account, or delete it.
• Contact us using the contact information provided.

When you delete your account, we delete your account and information from our active databases and revoke our Plaid access to your linked accounts. If you have an active accountability partner, they are notified that you deleted your account. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. Because our cookies are required for sign-in, rejecting them will prevent you from logging in to the Services.

If you have questions or comments about your privacy rights, you may email us at support@jointethered.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. Because we do not track you across other websites or use targeted advertising, this has no practical effect on how your data is handled. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section “What information do we collect?”.

We only collect sensitive personal information as defined by applicable privacy laws for the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services, and for Categories A, B, D, and L, for as long as the user has an account with us.

Sources of Personal Information

Learn more about the sources of personal information we collect in “What information do we collect?”.

How We Use and Share Personal Information

Learn more about how we use your personal information in the section “How do we process your information?”.

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more in the section “When and with whom do we share your personal information?”.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information
• Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “When and with whom do we share your personal information?”.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can email us at support@jointethered.com, write to us at 6718 Sage Grass Lane, Spring, TX 77379, or refer to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@jointethered.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How can you contact us about this notice?”.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at support@jointethered.com or contact us by post at:

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. You can review and update your information, or delete your account, from your account settings. For any other request, please email us at support@jointethered.com.