Pennie AI Privacy Policy

This Privacy Policy describes how TIPGUARD LLC ("Pennie AI", "we", "our", or "us") collects, uses, and discloses information collected through websites and mobile applications owned and operated by us that link to this Privacy Policy, such as the Pennie AI mobile app and www.pennie.ai, and any other interactions (e.g., customer service and other communications) that you may have with Pennie AI (collectively, the "Services").

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

1. INFORMATION WE COLLECT

Information You Provide Directly. We collect information that you provide when you use the Services or otherwise communicate with us. For example, when you:

• Create an account to use the Services, we may collect contact and registration information, such as your name and email address. We may also collect payment information for subscriptions.
• Interact with the Services, we may collect the information that you upload or provide, including financial information such as your account balance, descriptions of financial transactions, budget names and amounts (“Financial Information”), credentials to facilitate integrations with Financial Data Sources, and any prompts, questions, or commands related to your Financial Information for our AI to process.
• Contact us with questions, comments, or for customer service, we may collect contact information, such as your name and email address, as well as any information you provide in connection with your outreach.
• Participate in promotions, events, and surveys, we may collect basic contact information and any other information you provide.

Information You Provide via Integration with Financial Data Sources. We collect information about you when you connect your Pennie AI account to financial institutions and other third-party data sources (“Financial Data Sources”). To sync information from these sources, we will collect your Financial Information including your account balance, transactions, and holdings. We use third-party data sources, such as Plaid, to assist in this process. By connecting your Pennie AI account to a Financial Data Source, you agree to all applicable third-party terms and privacy policies.

Information from Other Sources. We also obtain information from other sources, like payment service providers, analytics services, and security service providers. If you access the Services through a third-party connection or log-in (e.g., Sign in with Apple or Google), you may allow us to access and store certain information from such services, depending on your settings on that service.

Automatically Collected Information. We may automatically receive and store certain information about the device you use to access the Services, including:

• Device Information: Technical information associated with your device, including browser, operating system, IP address, and unique device identifiers.
• Usage Information: Information about how you use our Services, such as features used, time spent, and error logs.

2. HOW WE USE YOUR INFORMATION

We use your information to provide the Services and to operate our business. In particular, we may use your information to:

• Provide, maintain, and improve the Services;
• Process your inquiries and generate responses, insights, and analysis using artificial intelligence;
• Provide customer service and personalize your experience;
• Engage in transactions, including billing and account communications;
• Contact you with operational information or promotional content (in accordance with your preferences);
• Analyze and improve the functionality and security of the Services;
• Comply with legal obligations and defend our legal rights.

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected so that it can no longer be linked to you. We may use this information for any purpose, including research and marketing.

3. COOKIES AND SIMILAR TECHNOLOGIES

We and our service providers use cookies, SDKs, and similar technologies to collect information, offer you a more tailored experience, and assist with security and administrative functions. You can manage cookies through your browser's "Help" section, but blocking them may impact Service functionality.

4. ONLINE ANALYTICS AND ADVERTISING

We may use third-party analytics services (like Google Analytics) to analyze usage information and assist with fraud prevention. We may also work with third parties to market our services to you on other websites. We do not currently respond to Do Not Track (“DNT”) signals.

5. HOW WE SHARE YOUR INFORMATION

We do not share your Financial Information with third parties for their own marketing purposes. We may share your information in the following circumstances:

• Service Providers: With third parties who provide services to us, such as cloud hosting, payment processing, and analytics.
• AI Service Providers: We share your Financial Information and prompts with our AI service providers, such as OpenAI, for the sole purpose of providing the AI-powered features of the Services. In line with their commitment to privacy, OpenAI will not use data submitted via their API to train or improve their models. You can review their policy for more details here: OpenAI's API Data Usage Policies. We have contractual agreements in place designed to protect the confidentiality and security of your data.
• Financial Data Sources: With services like Plaid to help establish or maintain an integration you have chosen.
• To Comply with Laws and Protect Our Rights: To comply with applicable law, respond to legal requests, enforce our Terms of Service, and protect the rights, privacy, safety, or property of our company, you, or others.
• Corporate Transactions: In connection with a merger, sale of assets, or other business transfer.
• With Your Consent or At Your Direction.

6. HOW WE PROTECT YOUR INFORMATION

We implement a variety of security safeguards designed to protect your information. However, no electronic system is completely secure. You are responsible for maintaining the confidentiality of your account password.

7. RETENTION OF INFORMATION

We retain your information for as long as your account is active or as needed to provide you the Services, comply with legal obligations, resolve disputes, and enforce our agreements.

8. THIRD PARTY LINKS AND FEATURES

The Services may contain links to third-party sites. We are not responsible for the privacy practices of such third parties. We urge you to read their privacy policies.

9. CHILDREN'S PRIVACY

The Services are not intended for children under 13. We do not knowingly collect personal information from children under 13. If we learn we have, we will promptly delete it.

10. YOUR CHOICES

• Marketing Communications: You may opt-out of promotional emails by contacting us at help@pennieai.com. You may not opt out of operational emails (e.g., transaction or relationship-based messages).
• Account Information: To keep your information accurate or to request deletion, please contact us through the app or at help@pennieai.com.

11. NOTICE TO CALIFORNIA RESIDENTS

California's "Shine the Light" law allows residents to request information regarding the sharing of certain personal information with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

12. NOTICE TO NEVADA RESIDENTS

Nevada law allows certain consumers to opt out of the sale of "personally identifiable information." We do not engage in such activity. However, you may submit a request to opt out of any potential future sales by contacting us at nevadarequests@pennie.ai.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. We will make the revised policy accessible through the Services and will notify you of material changes in accordance with legal requirements.

14. CONTACT INFORMATION