DRAFT FOR LAWYER REVIEW

This document is a DRAFT only. It is not legal advice. Do not publish until reviewed and approved by an Australian lawyer. Placeholders appear in [SQUARE_BRACKETS].

Privacy Policy — Tesni

Effective date: Draft as at 15 September 2026 (not yet in force — pending lawyer approval)
Operator: Tubby Code Pty Ltd (trading as Tesni)
ABN: 32 653 747 329 · ACN: 653 747 329
Contact: henry@laterletter.cool

This policy explains how we collect, use, store, and share personal information when you use Tesni (the app at https://app.tubbycode.com.au and our marketing site).

We follow the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) where they apply. This policy is written in plain Australian English.

By creating an account or using Tesni, you acknowledge that you have read this policy and consent to us handling your personal information as it describes (including the overseas disclosure in section 7). Where the law requires specific consent for a particular collection or use, we will ask for it at that point.

We may update this policy by posting the revised version on this page with a new effective date (see section 14). Continued use after that date means you accept the updated policy.

1. Who we are

Tesni is a family budgeting product operated by Tubby Code Pty Ltd (trading as Tesni).

We are not a bank. We do not hold deposits. We do not provide financial advice.

Tesni is for adults only. A household can include up to two adult members. Tesni is not a children’s product.

2. What we collect

Depending on how you use Tesni, we may collect:

We do not intentionally collect information about children.

3. How we collect it

• Directly from you — when you create an account, set preferences, upload files, or use chat.
• Through bank connection — when you connect a bank via Basiq Consent. Basiq is an Australian open-banking intermediary. Tesni is not claiming to be a Consumer Data Right (CDR) accredited data recipient.
• Automatically — session and similar technical data needed to operate the service.
• Derived by us — categories and related insights from transactions and uploads (including with AI assistance — see overseas disclosure below).

4. Why we collect it (purposes)

We use personal information to:

• Provide and operate Tesni (accounts, households, budgeting views).
• Connect and sync bank data you consent to share via Basiq.
• Categorise transactions and show balances and history.
• Process uploads you choose to add.
• Provide AI categorisation and chat features.
• Secure the service, prevent abuse, and fix faults.
• Communicate with you about the service (e.g. privacy or security notices).
• Investigate and respond to misuse, security incidents, and complaints.
• Meet legal obligations.

We do not sell your personal information.

Marketing. We do not currently send marketing or promotional messages. If we ever do, we will comply with the Spam Act 2003 (Cth) — we will only send them with your consent, they will identify us as the sender, and each will include a working unsubscribe.

5. Bank connections (important)

When you connect a bank:

• Consent is handled through Basiq.
• Tesni receives connection metadata, account masks/institution, posted transactions, and balances as enabled by that consent and our product design.

If you remove a bank connection, Tesni:

• Deletes the Basiq connection and related links.
• Clears balances if no remaining links apply.
• Keeps bank account rows and imported transactions already stored in Tesni.

Removing a connection is not the same as deleting all historical bank data from Tesni. See also Deletion and your choices below.

6. Who we share with

We share personal information only as needed to run Tesni, including with:

We require service providers to handle information appropriately under our arrangements with them, subject to their own terms and applicable law.

7. Overseas disclosure

Some processing may occur outside Australia.

In particular, AI categorisation and chat are provided via xAI (Grok). Treat this as an overseas disclosure of relevant chat content and data needed for those features, unless your lawyer advises a different characterisation.

AWS app/DB hosting and Cognito for Tesni are configured in Australia (Sydney / AU) where stated above. Basiq operates as an Australian intermediary for open banking as described in their materials.

By using AI features, you acknowledge that related information may be processed overseas. Ask us at henry@laterletter.cool if you need more detail before using those features.

8. Storage and security

We store Tesni app and database data primarily in AWS ap-southeast-2 (Sydney).

We take reasonable steps to protect personal information. No method of storage or transmission is completely secure. Do not treat Tesni as a vault for secrets you cannot afford to lose.

9. Retention

We keep information for as long as needed to provide Tesni, meet legal obligations, resolve disputes, and enforce agreements.

Bank account rows and imported transactions may remain after you disconnect a bank (see section 5).

Exact retention periods: [LAWYER TO CONFIRM / RETENTION_SCHEDULE].

10. Deletion and your choices

What the product currently supports:

• Remove a bank connection (see section 5 — historical data may remain).
• Leave a family / household (as implemented in-product).
• Delete an upload.
• Delete a chat thread.

Full account erasure may be incomplete in the product today. If you want us to delete personal information beyond what the app supports, email henry@laterletter.cool and we will respond in line with applicable law and our operational ability.

You may also request access or correction of your personal information via henry@laterletter.cool.

11. Marketing site, cookies, and third-party links

See our separate Cookies and tracking notice for essential auth/session data, localStorage, and Google Fonts on the marketing site. We do not currently run a full analytics cookie consent wall because we do not currently operate non-essential analytics tracking as described there.

Tesni and our marketing site may link to third-party websites or services (for example, your bank, Basiq, or the OAIC). Those sites have their own privacy practices, which we do not control and are not responsible for. Read their privacy policies before providing them with personal information.

12. Not financial advice

Categories, budgets, balances, uploads, and AI chat are tools to help you organise information. They are not financial, tax, or credit advice. See also our Terms of Use.

13. Complaints

Contact henry@laterletter.cool first. We will try to resolve your complaint promptly.

If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC): https://www.oaic.gov.au/

14. Changes

We may update this policy from time to time. We will post the updated version on this page with a new effective date; the posted version is the current version. Continued use of Tesni after that date means you accept the updated policy. Material changes may also be notified in-app or by email where appropriate.

15. Contact

Privacy (access, correction, deletion, complaints): henry@laterletter.cool
Report misuse, a security concern, or a suspected data breach: henry@laterletter.cool
Operator: Tubby Code Pty Ltd (trading as Tesni)
ABN: 32 653 747 329 · ACN: 653 747 329
Address: 19-21 South Steyne, Manly NSW 2095
Website: https://tubbycode.com.au