Tchola

Tchola Privacy Policy

Last Updated: April 16, 2026 Version: 1.0 (Phase 1 — Coordination Only)

Important: This is a working draft prepared for beta onboarding. It must be reviewed by a licensed fintech attorney before public launch or before Tchola begins moving funds on behalf of users (Phase 2), when GLBA and expanded state financial privacy rules will apply.

1. Introduction

This Privacy Policy explains how Tchola LLC ("Tchola," "we," "us," or "our") collects, uses, shares, and protects information when you use the Tchola mobile application and related services (the "Service"). By using the Service, you agree to the practices described here and to our Terms of Service.

If you do not agree with this Policy, do not use the Service.

2. Who This Policy Applies To

This Policy applies to all Users of the Service in the United States who are 18 years of age or older. Tchola does not knowingly collect information from children under 13, and the Service is not directed to Users under 18. If we discover that we have collected personal information from a child under 13, we will delete it promptly.

3. Information We Collect

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information We Do Not Collect in Phase 1

Because Tchola does not move money in Phase 1, we do not currently collect:

When we expand to Phase 2 (money movement), additional categories of data will be collected through regulated third-party providers such as Plaid (bank linking) and Persona (identity verification). We will update this Policy and notify you before that change takes effect.

4. How We Use Your Information

We use the information described above to:

We do not sell your personal information. We do not use your personal information for third-party advertising.

5. Legal Basis for Processing

Where required, we process your information based on: (a) your consent (marketing, optional features); (b) the performance of our contract with you (providing the Service); (c) our legitimate interests (security, fraud prevention, product improvement); and (d) compliance with legal obligations.

6. How We Share Your Information

We share information only in the following limited circumstances.

6.1 With Other Users

Your display name, profile photo, bio, Trust Tier badge, and activity you choose to share are visible to other Users consistent with your Default Privacy setting (Public, Friends Only, or Private). Sol Group activity is visible to members of that Group.

6.2 With Service Providers

We share information with vendors who process it on our behalf under confidentiality obligations, including:

6.3 Legal and Safety

We may disclose information when we believe in good faith it is necessary to: comply with law, legal process, or government request; enforce our Terms; protect the rights, property, or safety of Tchola, Users, or the public; or investigate fraud, security, or abuse.

6.4 Business Transfers

If Tchola is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.

6.5 With Your Consent

We share information for any other purpose disclosed to you and with your consent.

7. Your Rights and Choices

7.1 Access, Correction, and Deletion

You may access and edit most of your information in-app under Profile → Edit Profile. You can delete your account at any time in-app. Upon deletion, we will delete or de-identify your personal information within 30 days, except where retention is required by law, for fraud prevention, or for resolving disputes. Content you posted to Sol Groups or the social feed may be retained in anonymized form where necessary to preserve the integrity of Group records for other members.

7.2 Notification Preferences

You can control push notifications in Profile → Notifications and at the operating system level.

7.3 Default Privacy

You control the default audience of your activity in Profile → Default Privacy (Public, Friends Only, or Private). You can override the default on a per-post basis.

7.4 California Residents (CCPA / CPRA)

California residents have the right to: know what personal information we collect, use, and share; request deletion; correct inaccurate information; opt out of the sale or sharing of personal information (we do not sell or share for cross-context behavioral advertising); and not be discriminated against for exercising these rights. To make a request, email privacy@tchola.app.

7.5 Other State Privacy Rights

Residents of states with comprehensive privacy laws (including but not limited to Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Iowa, Tennessee, Indiana, and others as enacted) have similar rights. Contact privacy@tchola.app to exercise them.

7.6 Do Not Track

Our website does not respond to Do Not Track signals at this time.

8. Data Retention

We retain your information for as long as your account is active and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. Backup copies are typically purged within 90 days of account deletion.

9. Data Security

We use reasonable administrative, technical, and physical safeguards to protect your information, including encryption in transit (TLS), hashed password storage, role-based access controls, and infrastructure provided by reputable vendors. No system is perfectly secure. If you believe your account has been compromised, contact support@tchola.app immediately.

10. Children

The Service is for Users 18 and older. We do not knowingly collect personal information from anyone under 13. We anticipate offering accounts for Users ages 13–17 with verified parental consent in a future release, governed by supplemental terms compliant with COPPA.

11. International Users

The Service is offered to Users in the United States only. If you access the Service from outside the United States, you acknowledge that your information will be transferred to and processed in the United States, which may have different data protection laws than your country.

12. Changes to This Policy

We may update this Policy. For material changes, we will provide at least 30 days' notice via in-app notification or email. The "Last Updated" date at the top reflects the most recent revision. Continued use of the Service after the effective date constitutes acceptance.

13. Contact Us

Tchola LLC Privacy inquiries: privacy@tchola.app General support: support@tchola.app Legal: legal@tchola.app Website: https://tchola.app