Last Updated: August 31, 2025

INTRODUCTION

TCS Digital, LLC ("Skwad," "we," "us," or "our") is committed to protecting the privacy and security of the personal information we collect from our users. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website and use our mobile application (collectively referred to as the "Platform").

By accessing or using the Platform, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

1. INFORMATION WE COLLECT

1.1 Personal Information

When you sign up for Skwad, we may collect certain personal information from you, such as your name, email address, and payment details, in order to create and manage your account. We collect this information directly from you when you voluntarily provide it to us.

1.2 Usage Data

We may automatically collect information about your interactions with our Platform, including the features you use, the pages you visit, and your device information. This information may include your IP address, browser type, operating system, referring URLs, and other similar data.

1.3 Email Inbox Data

Skwad Scan is a feature that allows us to parse and categorize spending alerts and statements sent to a dedicated email inbox on your behalf or uploaded directly via the app or third-party integrations. We may share this information with our partners for processing purposes only. Our partners are strictly prohibited from storing this data or using it to train AI models.

For more information on how our partners handle your data, please refer to:

• OpenAI's privacy policy
• Google Gemini's privacy policy

Important Note: Skwad does not sell this information to any third parties, and we do not use your data to develop, improve, or train generalized AI models and/or ML models.

1.4 Receipt Information

If you choose to use our receipt or statement scanning feature, we may collect and store images and text of your uploads for expense tracking and processing purposes. We do not sell this information to any third parties.

1.5 Financial Information

Through our integration with SimpleFIN or Plaid, we may collect and process your financial account information, including account balances, transaction history, and account details, to provide you with financial insights and expense tracking services. This information is collected with your explicit consent and only for the purposes outlined in this policy.

1.6 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on Skwad and gather information about your usage patterns. Cookies are small data files stored on your device that help us recognize you and remember your preferences. You can manage your cookie preferences through your browser settings.

2. HOW WE USE YOUR INFORMATION

2.1 Personalization

We may use the information we collect to personalize your experience on Skwad, including providing tailored recommendations and insights based on your spending habits. This helps us deliver a more relevant and enjoyable experience for you.

2.2 Account Management

We use your personal information to create and manage your Skwad account, process transactions, and communicate with you about your account status. This includes sending you important updates, security alerts, and other administrative messages.

2.3 Platform Improvements

We analyze usage data to improve the functionality, performance, and user experience of Skwad. This helps us identify and fix bugs, optimize our Platform, and develop new features and services that meet the needs of our users.

2.4 Marketing Communications

With your explicit consent, we may use your contact information to send you promotional materials and updates about Skwad and its features. You can opt-out of receiving these communications at any time by following the unsubscribe instructions provided in the messages or by contacting us directly.

3. DATA SECURITY

We take the security of your information seriously and implement a variety of industry-standard measures to protect it against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, firewalls, access controls, and regular security audits.

4. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining the appropriate retention period, we consider:

• The nature and sensitivity of the information
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the information
• Any applicable legal requirements

If you wish to delete your account or request the deletion of your data, please contact us at [email protected]. We will promptly process your request, subject to any legal obligations we may have to retain certain information.

5. THIRD-PARTY SERVICES AND SUB-PROCESSORS

Skwad may integrate with third-party services or platforms, such as payment processors or analytics providers, to facilitate certain features or functions of our Platform. These third-party services may have their own privacy policies governing the collection, use, and disclosure of your information. We encourage you to review the privacy policies of these third-party services before using them in conjunction with Skwad.

Our current third-party service providers include:

Stripe (Stripe, Inc) We use Stripe for payment processing services for transactions made on the Platform. Privacy Policy: https://stripe.com/privacy

OpenAI (OpenAI, L.L.C.) We use OpenAI's language models for data parsing, analysis, and related functionalities. Privacy Policy: https://openai.com/privacy

Google (Google LLC) We use Google's services for data processing, analytics, and related functionalities. Privacy Policy: https://policies.google.com/privacy

Amazon Web Services (Amazon.com, Inc.) We use Amazon Web Services (AWS) for cloud infrastructure, hosting, and related computational services. Privacy Policy: https://aws.amazon.com/privacy/

Sinch (Sinch) We use Sinch's communication APIs for sending and receiving emails. Privacy Policy: https://www.sinch.com/privacy-policy/

SimpleFIN (One Part Rain, LLC) We use SimpleFIN's financial data aggregation and access to banking or financial information for enhanced functionality. Privacy Policy: https://beta-bridge.simplefin.org/info/privacy

Plaid Inc. We use Plaid's financial services infrastructure to securely connect to your bank accounts and retrieve financial data for account and transaction aggregation. Privacy Policy: https://plaid.com/legal/

6. UPDATES TO PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time, without prior notice, by posting the revised version on our website. The updated Privacy Policy will be effective as of the date it is posted. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If we make any material changes to this Privacy Policy, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our website prior to the change becoming effective.

7. CONTACT US

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us at:

TCS Digital, LLC Attn: Skwad Privacy Policy Email: [email protected]

We will make every effort to respond to your inquiries in a timely and satisfactory manner.

8. LEGAL BASIS FOR PROCESSING (GDPR - EEA AND UK USERS)

8.1 Legal Basis

If you are an individual from the European Economic Area (EEA) or United Kingdom (UK), our legal basis for collecting and using your personal information will depend on the specific context in which we collect it. Generally, we will collect personal information from you only where:

(a) We have your consent to do so,

(b) Where we need the personal information to perform a contract with you,

(c) Where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or

(d) Where we need to comply with a legal obligation.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

8.2 Legitimate Interests

Where we rely on legitimate interests as our legal basis for processing, our legitimate interests include:

• Operating and improving our Platform
• Providing customer support
• Fraud prevention and security
• Marketing our services (where you have not opted out)
• Complying with legal obligations

9. YOUR RIGHTS (GDPR - EEA AND UK USERS)

If you are an individual from the EEA or UK, you have certain rights under the General Data Protection Regulation (GDPR) and UK GDPR with respect to your personal information, including the right to:

• Access: Request access to your personal information and information about how we process it
• Rectification: Request correction of inaccurate personal information
• Erasure: Request erasure of your personal information (right to be forgotten)
• Restriction: Request restriction of processing your personal information
• Data Portability: Request transfer of your personal information in a structured, commonly used format
• Object: Object to processing of your personal information, including for direct marketing purposes
• Withdraw Consent: Withdraw consent where we rely on consent to process your personal information
• Lodge a Complaint: Lodge a complaint with a supervisory authority

To exercise these rights, please contact us at [email protected]. We will respond to your request within one month and in accordance with applicable data protection laws.

If you have any unresolved concerns, you have the right to lodge a complaint with a data protection authority in the country where you live, work, or where you believe your rights have been infringed.

10. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

10.1 Applicability

This section applies to California residents and supplements the information in this Privacy Policy. It describes how we collect, use, and share California residents' personal information and the rights available to California residents under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

10.2 Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

• Identifiers: Name, email address
• Commercial Information: Transaction history, purchasing behavior, expense data
• Financial Information: Payment information, bank account details, financial transaction data
• Internet/Network Activity: Usage data, device information, IP address, browsing behavior

10.3 Sources of Personal Information

We collect personal information from:

• Directly from you when you provide it to us
• Automatically through your use of our Platform
• From third-party service providers (such as Plaid for financial data)
• From publicly available sources

10.4 Business/Commercial Purposes for Processing

We process personal information for the following business/commercial purposes:

• Providing our services and Platform functionality
• Account management and customer support
• Security and fraud prevention
• Marketing and communications (with consent)
• Analytics and Platform improvement
• Legal compliance

10.5 Categories of Third Parties We Share With

We may share personal information with:

• Service providers and vendors who assist in our operations
• Payment processors
• Financial data providers
• Cloud infrastructure providers
• Analytics providers
• Professional advisors (lawyers, accountants, etc.)
• Law enforcement when required by law

10.6 Sale and Sharing of Personal Information

We do not sell your personal information and have not sold personal information in the past 12 months. We may share personal information for targeted advertising purposes, which under California law may be considered "sharing." You have the right to opt out of such sharing.

10.7 Your California Privacy Rights

California residents have the following rights:

Right to Know: You have the right to request information about:

• Categories of personal information we collect
• Categories of sources from which we collect personal information
• Business/commercial purposes for collecting personal information
• Categories of third parties with whom we share personal information
• Specific pieces of personal information we have collected about you

Right to Delete: You have the right to request deletion of personal information we have collected about you, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate personal information.

Right to Opt-Out: You have the right to opt out of the sale or sharing of your personal information for targeted advertising.

Right to Limit: You have the right to limit the use and disclosure of sensitive personal information (if applicable).

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

10.8 How to Exercise Your Rights

To exercise your California privacy rights, please:

• Email us at [email protected] with "California Privacy Request" in the subject line
• Include your full name and email address associated with your account
• Specify which right(s) you wish to exercise

We will verify your identity before processing your request and respond within 45 days (with the possibility of a 45-day extension if needed).

10.9 Authorized Agents

You may designate an authorized agent to make requests on your behalf. The authorized agent must provide proof of authorization, and you may be required to verify your identity directly with us.

10.10 Sensitive Personal Information

We may collect sensitive personal information including:

• Financial account information

We use this information only for the purposes disclosed in this Privacy Policy and as permitted by law.

11. INTERNATIONAL DATA TRANSFERS

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there.

For EEA and UK users, we ensure that international transfers are protected by appropriate safeguards, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions
• Certification schemes
• Codes of conduct

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

12. CHILDREN'S PRIVACY

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we discover that a child under 18 has provided us with personal information, we will promptly delete such information from our systems. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

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BY ACCESSING OR USING THE PLATFORM, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST NOT ACCESS OR USE THE PLATFORM.