Privacy Policy

Our primary goals in collecting personally identifiable information are to provide you with the product and services made available through the Service, to communicate with you, and to manage your registered user account, if you have one.

Information we collect: We may collect the following categories of personal information about you through the App, including but not limited to:

- Registration information: To use certain features of the Services, you will need to register an account. When you make an account, you will be asked for basic registration information, such as an email address and password.
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- Identification information: You may also be asked to provide identification information to confirm your identity, including your first and last name, username, address, and phone number.

- Third party credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for websites, apps, products or services provided by third-party service providers (“Third-Party Services”).

- Information from Third-Party Services: In order to display information to you through the Service, we may collect, on your behalf, your account and other personal information from Third-Party Services that you register under your account via the Service. If you choose to access Robinhood’s or Charles Schwab’s services through our Service, we may store a representation of your account information including but not limited to account holdings and transaction histories from your Robinhood or Charles Schwab accounts.
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- Technical and navigational information: We collect information about your interaction with our App such as computer browser type, pages visited, average time spent on our App, IP address, unique identifier of the device, operating system version, and app version. Location information: If you choose to use a location-enabled Service, we may collect location information from your device and will notify you of this collection. You may control or disable the sharing of location information via your device setting and/or the App.
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- Other information: We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.

Use of Contact Information: If you contact us by email through the App or the Site, we may keep a record of your contact information and correspondence, and may use your email address, phone number, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to our Service. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications.

Like many online platforms, we utilize "cookies" to enhance user experience and refine our Service. A cookie is a diminutive data file saved on your computer's storage. Importantly, these cookies don't harvest personal identification data. At Benson, we employ both session and persistent cookies. Session cookies power specific features of our App or Site and are automatically deleted once you exit. On the other hand, persistent cookies remain on your browser and might be accessed during future visits. These cookies help us:
- Grasp user interactions with our Service.
- Monitor overall user activity and web traffic pathways.
- Offer personalized advertisements aligning with your interests.
- Continuously optimize our Service.
Should you wish to manage these cookies, most browsers provide options to reject them or prompt you before any acceptance. Consult your browser's help section for specific guidance.

Service Providers:
We collaborate with trusted third parties for specific functions and services, such as hosting and maintenance. Your personally identifiable information is shared with these entities only to the extent necessary for these functions, and they are contractually bound to safeguard your data. Furthermore, we may access Third-Party Services you've chosen, retrieving the requested data for you. In the context of mobile usage, we may collect the Device ID, a unique identifier assigned by phone manufacturers or operating systems. This ID is essential for functions like security verification, monitoring unusual activity, and storing application preferences.

Security Measures with Device IDs:
We use Device IDs for enhancing security. For instance:
- Ensuring limited access based on specific devices.
- Monitoring unusual access patterns, like one account accessed from various devices.

Legal Compliance:
Benson adheres to lawful requirements and cooperates with legal authorities. We may disclose your data to these entities if we believe it's vital for:
- Addressing legal claims or processes.
- Safeguarding Benson's rights or those of third parties.
- Ensuring public safety.
- Halting illegal or unethical activities.

Business Transfers:
During mergers, acquisitions, or other major business transitions, Benson might transfer or share assets, including your personal information.

Protection of Personal Information:
‍Unless specified in this Privacy Policy, we will not sell, publish, or share your personal data for third-party marketing without your consent. While processing transactions or upon your requests, we may share certain information with third parties. These third parties, when acting on our behalf, are obligated to maintain privacy standards and can't use the information beyond the specified purposes.

Disclosure of Personal Information:
We may disclose your personal information:
- Responding to legal processes or inquiries.
- Addressing violations, illegal activities, threats, or potential fraud.
- Handling claims about content violations.
- Addressing emergencies affecting user safety.
- Other legal mandates or requirements.

Your personal information might also be shared with other entities based on your consent or directives.

We partner with third parties to present you with various products and services on our App, Site, and through the Service. These offers from third parties might complement your use of our platform. The suggestions are often tailored based on the data you provide, your interactions on the Site, or other collected information. If you opt for these third-party services or share data with them, please note that their privacy policies and terms of service will govern their use of your data. We advise you to familiarize yourself with these third-party policies before making decisions regarding their services. Benson does not take responsibility for the privacy practices of these third parties. Additionally, some content available through our Service might be sourced from third parties. These entities might set cookies on your device or seek information from you directly through their content modules. We encourage you to review the terms and privacy policies of such content providers to understand their data practices.

Benson prioritizes the protection of your personally identifiable information. We utilize a combination of administrative, physical, and electronic safeguards to defend against unauthorized access. However, while we strive for the highest level of security, we cannot guarantee absolute protection against all potential unauthorized access attempts. In the event of any breach affecting the security, confidentiality, or integrity of your unencrypted electronically stored personal data, we commit to providing legally-mandated notifications. We will notify you either via email or through a prominent notice on our App or Site.

Our App and Site are designed for individuals aged 18 and above. We do not intentionally gather personal information from children under the age of 18. Should we discover that a child under 18 has provided us with their personal information, we will promptly remove such data from our records.

You possess the right to request access to, rectify, or erase any Personal Information that Benson holds about you. While we strive to provide these services without charge, in certain cases, a nominal fee might be applied to cover our administrative costs in furnishing you with the specific Personal Information we retain about you. If you wish to exercise these rights and access your Personal Information, please reach out to us using the contact details provided below.

When using our Service, you must comply with all applicable laws and regulations governing personal finance products and services. Key relevant regulations include: GLBA - Gramm-Leach-Bliley Act FCRA - Fair Credit Reporting Act EFTA - Electronic Fund Transfer Act TILA - Truth in Lending Act ECOA - Equal Credit Opportunity Act FDCPA - Fair Debt Collection Practices Act TCPA - Telephone Consumer Protection Act As a provider of personal financial services to consumers, we are committed to full compliance with these laws and principles of ethical conduct. You are responsible for providing accurate registration information and keeping your account secure per our Terms of Service. Do not misrepresent your identity or engage in fraud or unauthorized activities. Contact us immediately if you suspect any improper use of your account. We will investigate and take appropriate actions to enforce our policies, terms, and applicable regulations. Our Service is designed to comply with relevant US regulations. Contact us if you have any compliance-related questions or concerns about our Service.

You are responsible for taking appropriate steps to secure credentials and End User Data when using our Service. This includes: Keeping API authentication credentials confidential. Report any credential breaches, unauthorized access, or suspicious activity immediately. Following industry best practices for End User Data security. Implement access controls, encryption, network security, input validation, and other appropriate controls. Complying with relevant data protection and privacy regulations applicable to your location and users. Conduct risk assessments and audits to identify potential vulnerabilities. Monitoring systems and data access to detect breaches or intrusions. Notify us and affected users without undue delay in case of an actual breach. Restricting End User Data access only to authorized personnel, and only for intended purposes. Maintaining physical security of devices and credentials. Follow secure backup, storage, and destruction practices. We regularly review and enhance our technical, administrative, and physical safeguards to help protect the security of user data. However, no method of transmission or data storage can be guaranteed to be 100% secure. Users are responsible for securing their own systems and credentials for use of our Service.

Securely store all End User Data in compliance with applicable laws.

You may deactivate your account at any time by following the instructions provided. We may also deactivate accounts that: Have not been paid for 3 consecutive months Have an expired or terminated agreement with us Need to be closed as reasonably necessary per applicable laws Upon deactivation, we will revoke your access to all associated end user data. Post-deactivation, we may retain your information as long as necessary per our Privacy Policy or to comply with legal obligations. The retention period will align with the purposes for collecting your data outlined in our privacy practices. We will limit data retention to the minimum period required by applicable laws. Information associated with deactivated accounts will remain protected per our security standards during retention. Please contact us if you have any questions about account deactivation or data retention practices. We will address your inquiries in a timely manner.

You may not use the Service to: Sell, rent, or otherwise disclose End User Data without authorization Engage in unlawful, malicious, or unethical activities Collect data without permission Breach privacy laws, regulations, or contractual agreements Infringe intellectual property rights Misuse the Service for purposes other than intended Conduct unauthorized security testing on our systems Overload or spam our Service Redistribute the Service without permission Reverse engineer the Service Breach agreements with Benson or end users Violate any applicable laws or regulations The prohibited activities are provided as examples and not as an exhaustive list. We reserve the right to terminate accounts or suspend access for any misuse of the Service against our policies, applicable laws, or fair use standards.

We reserve the right to suspend or terminate your access to the Service if we detect misuse, illegal activity, or violations of our policies or applicable laws. Reasons for suspension or termination may include but are not limited to: Breach of this Privacy Policy or Terms of Service Illegal, fraudulent, or malicious activity Compromise of account security or data integrity Harm caused to other users or third parties While we aim to provide advance notice of suspensions or terminations, we may need to take immediate action without notice in some cases. We are not liable for any damages arising from account suspensions or terminations per this policy. Suspended or terminated accounts will continue to be governed by our Privacy Policy. Please contact us if you believe an account action was taken in error so we may review the situation. We will respond promptly to all good faith inquiries.

Should any provision of this Policy be deemed invalid, the other provisions remain in effect.