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Effective date: August 2, 2026
Bengos (the "Service") is operated by Bengos LLC. This policy describes what personal information we collect, how we use it, and the choices you have. This policy is part of, and incorporated into, our Terms of Service. By using the Service, you consent to the collection and use of information as described in this policy.
We collect information you provide and information generated through your use of the Service, including:
Account and profile information, such as your email address, legal name, an optional preferred name and profile photo, and the exam, jurisdiction, dates, study program, and goals you enter.
Practice data, such as typing performance (including speed, accuracy, errors and corrections, and session and cumulative practice time), confidence ratings, tags, notes, annotations, bookmarks, supplemental passages you write, and your responses to surveys and feedback prompts.
Records related to the injury waiver you sign during onboarding, including the name you type, the date and time, and your IP address.
Billing information, if you make a purchase, such as what you purchased, your access status and end date, billing and payment history, and the limited payment-method details our payment processor reports to us, such as the card brand, the last four digits of the card, and its expiration date.
Technical data, such as cookies necessary for login and security, browser localStorage for interface preferences, server logs including IP address, and the analytics information described in Section 4.
We may collect other information you choose to provide or that we generate in operating the Service.
We use your information to operate the Service: authenticate you, schedule your practice queue, compute your progress statistics, send transactional email (such as verification and password reset), enforce trial and paid access, prevent abuse and unauthorized copying of our content, and comply with law.
We also use practice data and information about how you use the Service to develop and improve the Service, to build new products and features, and to develop, measure, and improve our own marketing and promotional strategies, campaigns, and communications. This includes using your practice data, including the supplemental passages, tags, notes, and annotations you create and the survey and feedback responses you provide, to build, train, evaluate, and refine machine learning models, statistical models, and algorithms, whether for the features that select, order, and schedule passages, measure progress, and generate practice recommendations, or for other current or future features. Models we develop, and any de-identified or aggregated outputs of this work, are our property, and we may retain and use them even after your account is deleted.
The Service may remind you to take rest breaks and may discourage or limit practice beyond healthy daily amounts.
We may send you email about new features or changes to the Service. You can opt out of these messages at any time; we will still send email needed to run your account.
We do not use your personal information for third-party advertising.
We use Google Analytics to understand how visitors use the Service, such as which pages are visited and how visitors arrive. Google Analytics sets cookies and collects device and usage information, including a pseudonymous identifier and general location derived from IP address. Google processes this information as a third party and may use it to provide, maintain, and improve its own services under its own privacy policy. We do not use Google Analytics advertising features. This means Google may collect information about your online activity when you use the Service, and may associate it with activity on other websites and apps that use Google's services. You can block Google Analytics with Google's browser opt-out add-on at tools.google.com/dlpage/gaoptout.
The Service also uses cookies that are necessary for it to function (login sessions and security) and browser localStorage to remember interface preferences. These are not used to track you across other sites.
Some browsers send "Do Not Track" or Global Privacy Control signals. Because we do not sell personal information or share it for cross-context behavioral advertising, the Service treats all visitors the same and does not respond differently to these signals.
We use processors to run the Service, such as a cloud hosting platform, an image hosting service for profile photos, an email delivery service for transactional email, error monitoring and log management services, a payment processor for billing, and Google Analytics as described above. Each receives the data needed to perform its function. Payment card data is collected and processed by our payment processor under its own privacy policy. We do not receive or store your full card number or security code.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising as those terms are defined in California law. We share personal information only: with the service providers described above; with our affiliates; at your direction or with your consent; in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case personal information may be transferred as part of that transaction; when required by law or legal process; and to protect the rights, safety, or property of Bengos, our users, or others. If our practices change, we will update this policy and provide any opt-out that applicable law requires.
We may de-identify or aggregate information so that it can no longer reasonably be linked to you, including the typing performance, review history, and usage data used to build the models described in Section 3. We may use, retain, license, sell, and otherwise share de-identified or aggregated data with third parties for any lawful purpose, including to build, benchmark, train, and improve machine learning and other models, whether ours or a third party's, and to develop, market, and promote our products and services. We take reasonable measures to keep this data de-identified, we do not attempt to re-identify it, and, where we make such data available to others, we require them by contract not to re-identify it. We treat de-identified and aggregated data as outside the personal information protected by California and other privacy laws.
We retain account and practice data while your account has active access, whether by trial or by purchase, and for a reasonable period after your access ends. We may send notice to your account email address before deletion. We keep data longer only where we need to: records we must retain for legal, tax, or accounting purposes, such as waiver and billing records; backups; and de-identified or aggregated data, which we may retain without time limit.
We use reasonable technical and organizational measures intended to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
The Service is operated from the United States and is directed to and intended for users in the United States. We do not target the Service to, or market it in, any other country. If you access the Service from outside the United States, you do so on your own initiative and are responsible for compliance with local law. We are based in the United States, and your information may be processed and stored in the United States and in other locations where we or our service providers operate. By using the Service, you consent to the transfer and processing of your information in those locations, where privacy laws may differ from those of your country. Where the law of your jurisdiction gives you rights in your personal information, you may exercise them as described in Section 11.
You may access and correct your profile information in the Service. You may request a copy, correction, or deletion of your personal information by emailing legal@bengos.io. We will verify that a request comes from the account holder, or from an authorized agent acting with the account holder's permission, before we act on it, and we respond as applicable law requires. If you are a California resident, Section 12 describes your rights under the CCPA and how to exercise them. Residents of other states that have privacy laws may have similar rights and may contact us at the same address.
This section gives additional detail for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"). It supplements the rest of this policy.
The categories of personal information we collect, the sources, the purposes for which we use it, and the parties with whom we share it are described in Sections 2, 3, 5, and 6. We do not collect biometric information, precise geolocation, government identifiers, or protected-classification characteristics.
Sensitive personal information. The only sensitive personal information we collect is your account log-in credentials, and we use and disclose it only to authenticate you and secure the Service. Because we do not use or disclose sensitive personal information for any purpose other than providing and securing the Service, the right to limit the use of sensitive personal information does not apply, and we do not offer a separate "limit" option.
Sale and sharing. We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined by the CCPA, and we have not done so.
Your California rights. Subject to verification and to legal exceptions, you have the right to: know the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients, and to receive a copy in a portable format where technically feasible; delete personal information we collected from you; correct inaccurate personal information; opt out of the sale or sharing of personal information, which does not apply because we do not sell or share; and not receive discriminatory treatment for exercising these rights.
How to exercise your rights. Email legal@bengos.io. Because we operate only online and interact with you only through the Service and by email, we accept requests at that address. We respond within the time the CCPA requires, generally within 45 days, and we may extend that period as the CCPA allows.
Verification. To protect your information, we verify your identity before acting on a request, generally by confirming control of the email address associated with your account and any other information reasonably needed. We use information you provide for a request only to verify and respond to it.
Authorized agents. You may use an authorized agent to submit a request. We may require the agent to provide proof that you authorized them to act for you, and we may ask you to verify your identity directly with us.
Shine the Light. We do not disclose personal information to third parties for those third parties' own direct marketing purposes.
The Service is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal information from children.
We may update this policy from time to time. Material changes will be posted on this page with a new effective date.
Privacy questions or requests: legal@bengos.io.
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