ETL Group LLC

Privacy Policy

Effective October 29, 2026

1. Who we are and what this covers

ETL Group LLC ("ETL Group", "we") operates internal software tools used by the company and its affiliated transportation businesses. This policy explains what data those internal tools collect when they connect to financial accounts through Plaid, and how we use and protect it. The tools are for internal use only and are not offered to the public.

2. Data we collect

When an authorized company representative connects one of ETL Group's own bank or card accounts through Plaid, we receive, from Plaid, account details (account name, type and the last four digits of the account number), balances and transaction history for the accounts selected. We do not receive or store bank login credentials; those are entered directly with Plaid and the bank.

3. Consent

An account is connected only when the company's authorized representative logs in to the bank through Plaid and selects the accounts to share. That action is the consent to collect and process the data described above. Access can be withdrawn at any time by disconnecting the account.

4. How we use the data

Only for internal financial analysis and bookkeeping: cash position, spending review, reconciliation with our accounting records and spotting unusual activity. We do not use the data for advertising, we do not sell it, and we do not share it with third parties except service providers that process it on our behalf (Plaid) or where the law requires.

5. Security

Data is transmitted over TLS 1.2 or higher, and access tokens and financial data are stored encrypted with access limited to the company's owner and the internal service that needs it. Systems holding this data require multi-factor authentication. See our Information Security Policy.

6. Retention and deletion

We keep only ETL Group's own data and only for as long as it is needed for analysis and the company's record-keeping obligations. Disconnecting an account revokes Plaid access and deletes the stored access token; data that is no longer needed is deleted. This policy is reviewed periodically and in line with applicable data privacy laws.

7. Plaid

We use Plaid Inc. to connect to financial accounts. Plaid's handling of data is described in the Plaid End User Privacy Policy.

8. Contact

Questions or requests about this policy: amon@etlgroupllc.com. We may update this policy; the effective date above shows the latest version.