Effective Date: May 23, 2026  |  Last Updated: June 3, 2026

Privacy Policy

Young Stewards™ | A product of Scale Consulting Group, LLC

Who We Are

Young Stewards™ is a family financial education application operated by Scale Consulting Group, LLC, a Florida limited liability company, doing business as Young Stewards™ ("Young Stewards," "we," "us," or "our"). Young Stewards is made available through CS Advisors, Inc., an SEC-registered investment adviser subject to the Investment Advisers Act of 1940 and the SEC's Privacy Rule (Regulation S-P).

Your use of Young Stewards does not make you a client of CS Advisors, Inc. If you separately engage CS Advisors for investment advisory services, your information as an advisory client is governed by CS Advisors' separate privacy notice provided at the time of engagement, not by this policy.

What This Policy Covers

This Privacy Policy explains how Young Stewards collects, uses, stores, and protects information you provide when using the Young Stewards mobile application (the "App"). It does not cover third-party services you may access through links in the App.

Information We Collect

Account information: When you create an account, we collect your email address and a hashed password. We do not store your password in plain text.

Family profiles: You may enter your children's first names, ages or birth dates, and optional pronouns. This information is used only to personalize the App experience for your family.

Money Story: You may optionally answer a reflective question about your own relationship with money. This response is stored and used to personalize COACH interactions.

Activity data: We record which activities your family completes and when, including the specific activity content and version delivered to your family. These records serve as a log of educational content delivered and are used to power the spaced repetition Revisit Engine and track your family's progress.

COACH conversations: Messages you send to the COACH feature and the AI-generated responses are stored to enable conversation continuity across sessions and to generate session summaries.

Session summaries: After a COACH conversation, a brief automated summary is generated and stored to provide COACH with context in future sessions.

Derived data (bridge signals): The COACH feature may detect when a parent's questions indicate needs beyond the educational scope of the App (such as questions about estate planning, college savings, or investment strategy). When detected, a signal is logged internally and may be reviewed by a representative of CS Advisors to determine whether to reach out about advisory services. This is disclosed as a potential conflict of interest in our Terms of Use. No external data sharing occurs as a result of this detection.

Push notification tokens: If you enable notifications, we store a device token to deliver scheduled reminders. We do not use notification tokens for advertising.

Technical data: We may collect device type, operating system version, app version, and IP address for security, abuse prevention, and debugging purposes. We do not collect precise geolocation data.

How We Use Your Information

• To provide and personalize the App experience for your family
• To power the COACH AI feature with relevant family context
• To schedule and deliver activity reminders via push notification
• To maintain your activity completion history and streak
• To generate and store session summaries for COACH continuity
• To detect bridge signals as described above
• To respond to support requests sent to privacy@youngstewards.family
• To comply with legal obligations applicable to Young Stewards and CS Advisors, Inc.

Children's Privacy (COPPA)

You must be 18 or older to create an account. We do not knowingly collect personal information directly from children under 13. All child information in the App is entered by the parent account holder. We do not serve targeted advertising to any user, including children. If you believe we have inadvertently collected information from a child under 13 without verifiable parental authorization, contact privacy@youngstewards.family and we will delete it promptly.

Data Sharing

We do not sell your personal information to third parties. We do not share your information with advertisers, marketers, or data brokers — ever. We use the following service providers who process data on our behalf under data processing agreements:

• Supabase, Inc.: database hosting and authentication
• Amazon Web Services, Inc.: AI model inference (AWS Bedrock) for the COACH feature
• Expo / Expo Application Services: mobile app delivery and over-the-air updates

We may disclose information if required by law, court order, or to protect the rights, property, or safety of our users or the public.

Data Retention

We retain your account and family profile data for as long as your account remains active. COACH conversation messages and session summaries are retained for as long as your account is active to support continuity across sessions. Bridge signals are retained indefinitely for internal compliance review purposes unless you delete your account.

If you delete your account using the "Delete Account" option in Settings, all of your data (account information, family profiles, activity history, COACH conversations, session summaries, and bridge signals) is permanently deleted from our systems within 30 days. This deletion is irreversible.

We do not retain data beyond account deletion for any purpose other than legal obligations that require a specific retention period, which we will identify to you if applicable.

Your Rights

Access and correction: You may update your account email and family profile information at any time within the App.

Deletion: You may delete your account and all associated data at any time through Settings > Delete Account.

California residents (CCPA): You have the right to know what personal information we collect, request deletion of your personal information, and opt out of the sale of personal information. We do not sell personal information. To exercise your rights, contact privacy@youngstewards.family.

European residents (GDPR): If you are located in the European Economic Area, you have the right to access, rectify, erase, restrict processing of, and port your personal data. You also have the right to object to processing and to lodge a complaint with a supervisory authority. To exercise these rights, contact privacy@youngstewards.family. By using the App from the EEA, you consent to the transfer of your data to the United States, where our servers are located.

Security

We maintain cybersecurity practices consistent with the requirements applicable to SEC-registered investment advisers under Regulation S-P, including encryption in transit, access controls, and periodic review of our data handling practices. No system is perfectly secure. If you believe your account has been compromised, contact privacy@youngstewards.family immediately.

Changes to This Policy

We will notify you of material changes to this policy by email or through a notice in the App at least 30 days before changes take effect. Continued use of the App after the effective date constitutes acceptance of the updated policy.