TERNWHEEL, INC. PRIVACY POLICY
Effective Date: September 3, 2026
Last Updated: September 3, 2026
Ternwheel, Inc. (“Ternwheel,” “we,” “us,” or “our”) respects your privacy.
This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use Ternwheel websites, applications, software, products, financial technology features, communications, and related services, collectively, the “Services.”
This Privacy Policy also describes privacy rights available to individuals under applicable law.
SCOPE
This Privacy Policy applies to personal information processed by Ternwheel through:
• ternwheel.com
• Ternwheel web applications
• Ternwheel mobile applications
• Customer and account services
• Tour and event management tools
• Guest-list functionality
• Budgeting and settlement tools
• Financial account integrations
• Ternwheel banking-related functionality
• Communications with Ternwheel
• Marketing activities
• Customer support
• Other Ternwheel Services that reference this Privacy Policy
Certain banking and financial services are subject to additional privacy notices or policies provided by the applicable bank or financial-services provider.
TERNWHEEL AND BANKING SERVICES
Ternwheel is a financial technology company. Ternwheel is not a bank.
Banking services made available through Ternwheel are provided by i3 Bank, Member FDIC, through Unit and applicable service providers.
Deposit accounts are issued by i3 Bank, Member FDIC.
Visa® business debit cards are issued by i3 Bank pursuant to a license from Visa U.S.A. Inc.
Information processed in connection with financial services might also be subject to privacy notices provided by i3 Bank, Unit, payment networks, financial-data providers, or other applicable financial institutions.
PERSONAL INFORMATION WE COLLECT
The information we collect depends on how you interact with Ternwheel.
We collect information directly from you, from organizations using Ternwheel, automatically from devices and browsers, and from service providers and other third parties.
ACCOUNT AND IDENTITY INFORMATION
We might collect:
• Name
• Email address
• Telephone number
• Username
• Profile information
• Company or organization
• Job title or role
• Artist or group affiliation
• Account credentials
• Profile photograph
• User permissions
• Subscription information
BUSINESS AND PROFESSIONAL INFORMATION
We might collect:
• Employer
• Management company
• Agency
• Artist affiliation
• Tour affiliation
• Professional role
• Crew position
• Business contact information
• Business relationships
• Organizational permissions
TOUR, EVENT, AND LOGISTICS INFORMATION
Users might provide information concerning:
• Shows
• Venues
• Rehearsals
• Schedules
• Run-of-show information
• Tour routing
• Transportation
• Flights
• Hotels
• Booking confirmations
• Travel schedules
• Crew assignments
• Contacts
• Production information
• Tour documents
Some of this information might relate to other individuals.
GUEST-LIST INFORMATION
Ternwheel guest-list functionality might process:
• Guest names
• Email addresses
• Telephone numbers
• Guest type or access level
• Plus-one information
• Event information
• RSVP information
• Communications associated with a guest list
Organizations operating guest lists are responsible for providing appropriate privacy notices and obtaining permissions required by applicable law.
FINANCIAL INFORMATION
Depending on the Services you use, we might process:
• Bank account information
• Account identifiers
• Routing information
• Account balances
• Transaction information
• Merchant information
• Payment information
• Expense information
• Budget information
• Settlement information
• Revenue information
• Financial reports
• Card transaction information
• Financial-account connection information
Payment-card information used solely to purchase a Ternwheel subscription might be processed directly by our payment provider rather than stored by Ternwheel.
BANKING AND IDENTITY VERIFICATION INFORMATION
When you apply for or use banking-related Services, Ternwheel, i3 Bank, Unit, and applicable providers might collect information required to verify individuals and businesses and comply with financial-services laws.
Depending on the product, this information might include:
• Legal name
• Business name
• Business address
• Residential address
• Date of birth
• Tax identification information
• Government identification information
• Beneficial ownership information
• Business formation information
• Identity-verification information
• Compliance and sanctions-screening information
• Fraud and risk information
Certain information might be collected directly by a banking or identity-verification provider rather than stored by Ternwheel.
CONNECTED FINANCIAL ACCOUNTS
When you connect an external financial account, Ternwheel and its financial-data providers might receive information such as:
• Financial institution
• Account type
• Account identifier
• Account balance
• Transaction history
• Transaction description
• Merchant information
• Account ownership information
The information received depends on the connection you authorize and the provider involved.
USER CONTENT AND COMMUNICATIONS
We process information you submit through Ternwheel, including:
• Messages
• Comments
• Uploaded files
• Images
• Receipts
• Travel documents
• Settlement documents
• Financial documents
• Support requests
• Feedback
• Communications with Ternwheel
DEVICE AND USAGE INFORMATION
When you use the Services, we might automatically collect:
• IP address
• Browser type
• Device type
• Operating system
• Device identifiers
• Application version
• Pages and features viewed
• Clicks and interactions
• Session information
• Referring pages
• Approximate location derived from IP address
• Crash information
• Performance information
• Log data
• Date and time of access
MOBILE INFORMATION
Our mobile applications might process device information and permissions needed for features you choose to use.
Depending on your settings and the features involved, these permissions might include:
• Notifications
• Camera or photo access
• Files
• Device information
You control many mobile permissions through your device settings.
COOKIES AND SIMILAR TECHNOLOGIES
Ternwheel and its service providers use cookies, software development kits, pixels, local storage, and similar technologies.
These technologies help us:
• Keep users signed in.
• Maintain security.
• Remember preferences.
• Understand product usage.
• Diagnose technical problems.
• Measure site and product performance.
• Understand marketing effectiveness.
Where required by law, we obtain consent before using non-essential technologies.
ANALYTICS
We use analytics and monitoring services to understand how people interact with Ternwheel, diagnose errors, improve performance, and develop features.
These providers might receive device, browser, network, and usage information.
ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING
Certain Ternwheel features use artificial intelligence, machine learning, automated extraction, or similar technologies.
These features might process information you submit to:
• Extract structured information from documents or images.
• Assist with data entry.
• Categorize information.
• Generate summaries.
• Suggest classifications.
• Improve workflows.
We evaluate applicable privacy obligations when deploying automated processing.
Where required by applicable law, we provide notices, choices, or rights relating to qualifying automated decisionmaking technology.
Ternwheel does not represent AI-assisted output as guaranteed to be accurate.
HOW WE USE PERSONAL INFORMATION
We use personal information to:
• Provide the Services.
• Create and administer accounts.
• Authenticate users.
• Manage permissions.
• Process subscriptions.
• Provide tour-management functionality.
• Provide financial-management functionality.
• Facilitate banking-related functionality.
• Connect financial accounts.
• Process and display transactions.
• Reconcile expenses and budgets.
• Provide guest-list functionality.
• Send notifications.
• Provide customer support.
• Maintain and improve the Services.
• Develop new features.
• Conduct analytics.
• Diagnose technical problems.
• Protect users and Ternwheel.
• Detect fraud and abuse.
• Maintain security.
• Comply with financial-services requirements.
• Verify identities and businesses where applicable.
• Meet legal and regulatory obligations.
• Enforce our agreements.
• Resolve disputes.
• Communicate service updates.
• Send marketing communications where permitted.
HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information as needed to operate the Services.
Recipients might include:
• Cloud-hosting providers
• Database and infrastructure providers
• Analytics providers
• Error-monitoring providers
• Communications providers
• Customer-support providers
• Payment processors
• Financial-data providers
• Banking providers
• Financial institutions
• Card networks
• Identity-verification providers
• Fraud-prevention providers
• Compliance providers
• Professional advisers
• Contractors working on our behalf
We require service providers to handle personal information according to applicable contractual and legal requirements.
BANKING PARTNERS
Information associated with banking Services might be disclosed to i3 Bank, Unit, Visa, financial institutions, payment networks, compliance providers, fraud-prevention providers, and other parties necessary to provide financial Services.
These entities might process information under their own legal obligations and privacy notices.
OTHER USERS AND ORGANIZATIONS
Ternwheel is a collaborative platform.
Information you submit might be visible to users who have permission to access the same artist, tour, show, company, or organization.
Account administrators determine many organizational permissions.
Review permissions before entering sensitive financial, travel, or personal information.
LEGAL AND SAFETY DISCLOSURES
We might disclose personal information when reasonably necessary to:
• Comply with law.
• Respond to lawful legal process.
• Respond to government or regulatory requests.
• Enforce agreements.
• Protect Ternwheel’s rights.
• Protect users or other individuals.
• Detect or prevent fraud.
• Investigate security incidents.
• Address illegal activity.
CORPORATE TRANSACTIONS
Personal information might be transferred as part of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction.
SALE AND SHARING OF PERSONAL INFORMATION
Ternwheel does not sell personal information for money.
Some privacy laws define “sale,” “sharing,” or “targeted advertising” broadly enough to cover certain advertising or analytics disclosures even when no money changes hands.
Where Ternwheel engages in activity legally defined as selling or sharing personal information or using personal information for targeted advertising, we provide the rights and opt-out mechanisms required by applicable law.
We honor qualifying opt-out preference signals, including Global Privacy Control, where required by applicable law.
SENSITIVE PERSONAL INFORMATION
Depending on your use of the Services, Ternwheel or its providers might process information considered sensitive personal information under applicable law, including financial account information, authentication information, government identification information, or precise information supplied for financial-services compliance.
We use sensitive personal information for permitted business purposes, including providing requested Services, maintaining security, preventing fraud, processing transactions, and meeting legal obligations.
Where applicable law grants a right to limit certain uses of sensitive personal information, we provide that right when our processing falls within the scope of the law.
DATA RETENTION
We retain personal information for periods reasonably necessary for the purposes described in this Privacy Policy.
Retention periods depend on:
• The type of information.
• The Services involved.
• The duration of the customer relationship.
• Legal obligations.
• Banking and financial-services requirements.
• Tax and accounting obligations.
• Security requirements.
• Fraud-prevention needs.
• Contractual obligations.
• Dispute-resolution needs.
We do not retain personal information longer than reasonably necessary for disclosed purposes unless a longer period is required or permitted by law.
Deletion of a Ternwheel account does not require deletion of information we must retain for legal, security, fraud-prevention, financial, accounting, or regulatory purposes.
DATA SECURITY
We maintain administrative, technical, and organizational safeguards designed to protect personal information.
Security measures might include:
• Access controls
• Authentication controls
• Encryption where appropriate
• Network and infrastructure protections
• Monitoring
• Logging
• Security testing
• Role-based permissions
• Incident-response procedures
• Vendor-security controls
No internet-based service provides absolute security.
PRIVACY AND SECURITY GOVERNANCE
We periodically evaluate privacy and security risks associated with our Services.
Where applicable law requires risk assessments, cybersecurity audits, or similar compliance measures, Ternwheel undertakes those processes according to applicable requirements and implementation deadlines.
CHILDREN
Ternwheel is intended for business and professional use and is not directed to children under 13.
We do not knowingly collect personal information directly from children under 13 without legally required authorization.
If you believe a child has provided personal information to Ternwheel improperly, contact privacy@ternwheel.com.
YOUR PRIVACY RIGHTS
Depending on where you live, you might have rights concerning your personal information.
These rights might include the right to:
• Know whether we process your personal information.
• Access personal information.
• Obtain information about categories of personal information collected.
• Obtain information about sources of personal information.
• Obtain information about purposes for processing.
• Obtain information about categories of recipients.
• Correct inaccurate personal information.
• Delete personal information.
• Obtain a portable copy of certain information.
• Opt out of qualifying sales of personal information.
• Opt out of qualifying sharing or targeted advertising.
• Limit certain uses of sensitive personal information.
• Opt out of qualifying automated decisionmaking or profiling.
• Appeal certain privacy-request decisions.
• Receive equal service without unlawful discrimination for exercising privacy rights.
Rights differ by jurisdiction.
CALIFORNIA PRIVACY RIGHTS
California residents receive rights under the California Consumer Privacy Act, as amended.
Subject to applicable exceptions, California residents have rights to:
• Know the personal information Ternwheel collects.
• Access personal information.
• Request deletion.
• Request correction.
• Know categories of sources.
• Know business or commercial purposes for collection and disclosure.
• Know categories of third parties receiving personal information.
• Opt out of sale or sharing where applicable.
• Limit qualifying uses and disclosures of sensitive personal information.
• Receive information concerning qualifying automated decisionmaking technology where applicable.
• Exercise applicable opt-out rights concerning qualifying automated decisionmaking technology.
• Receive non-discriminatory treatment for exercising CCPA rights.
CALIFORNIA 12-MONTH DISCLOSURE
During the preceding 12 months, depending on how individuals interacted with Ternwheel, we have collected the following categories of personal information described by California law:
• Identifiers.
• Customer-record information.
• Characteristics of protected classifications when voluntarily provided or required by law.
• Commercial information.
• Internet or other electronic-network activity.
• Geolocation information.
• Audio, electronic, visual, or similar information.
• Professional or employment-related information.
• Inferences derived from other information.
• Sensitive personal information.
The specific information within these categories is described throughout this Privacy Policy.
SOURCES OF CALIFORNIA PERSONAL INFORMATION
We collect personal information from:
• You.
• Organizations that provide you access to Ternwheel.
• Other Ternwheel users.
• Your devices and browsers.
• Financial institutions.
• Banking and financial-service providers.
• Financial-data providers.
• Service providers.
• Business partners.
• Publicly available sources where appropriate.
CALIFORNIA BUSINESS PURPOSES
We collect and use personal information for the purposes described in Section 17, including providing Services, maintaining accounts, processing transactions, providing financial functionality, security, fraud prevention, analytics, customer support, product development, communications, and legal compliance.
CALIFORNIA DISCLOSURES
During the preceding 12 months, we might have disclosed categories of personal information described above to service providers, contractors, banking partners, financial institutions, payment networks, analytics providers, infrastructure providers, professional advisers, and other recipients described in this Privacy Policy for business purposes.
We do not sell personal information for money.
Where a disclosure constitutes “sale” or “sharing” under California law, California residents receive the applicable right to opt out.
GLOBAL PRIVACY CONTROL
Where required by applicable law, Ternwheel processes recognized opt-out preference signals such as Global Privacy Control as a request to opt out of applicable sale or sharing for the browser or device transmitting the signal.
OTHER U.S. STATE PRIVACY RIGHTS
Residents of states with comprehensive privacy laws might receive additional rights regarding access, correction, deletion, portability, targeted advertising, sale, profiling, sensitive information, or appeals.
We process verified requests according to the law applicable to the requester.
EXERCISING YOUR RIGHTS
To submit a privacy request, contact:
Your request should identify the right you wish to exercise and provide enough information for us to locate the relevant account or records.
We might need to verify your identity before completing a request.
We will use information submitted for verification only as permitted by applicable law.
AUTHORIZED AGENTS
Where permitted by law, you might designate an authorized agent to submit a privacy request for you.
We might request evidence of the agent’s authority and might separately verify your identity.
APPEALS
Where applicable state law provides a right to appeal our decision concerning a privacy request, you may submit an appeal to privacy@ternwheel.com.
Include “Privacy Appeal” in the subject line and describe the request and decision you wish to appeal.
MARKETING CHOICES
You may unsubscribe from promotional emails through the unsubscribe link in those messages.
Even after opting out of marketing, we might send transactional, account, security, legal, banking, or service-related communications.
COOKIE CHOICES
You control browser cookies through browser settings and any privacy controls provided on our website.
Disabling certain technologies might affect Service functionality.
Where required, Ternwheel provides controls for non-essential cookies and qualifying advertising or sharing technologies.
INTERNATIONAL USERS
Ternwheel is based in the United States.
If you access Ternwheel from another country, your information might be processed in the United States or other jurisdictions where our service providers operate.
Where required by applicable law, we use appropriate safeguards for international transfers of personal information.
THIRD-PARTY LINKS
Ternwheel might contain links to third-party websites or services.
Their privacy practices are governed by their own policies.
CHANGES TO THIS PRIVACY POLICY
We might update this Privacy Policy as our Services, technology, business practices, or legal obligations change.
We will update the “Last Updated” date when changes are made.
Where required by law, we will provide additional notice before material changes take effect.
CONTACT US
Questions or requests concerning this Privacy Policy should be directed to:
Ternwheel, Inc.
600 California Street, Floor 11
San Francisco, CA 94108
United States
Phone: 415-741-0255
Email: privacy@ternwheel.com