Information Collection  and Information Deletion Processes

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.  If you do not provide your information when requested, you may not be able to use some or all of our Services if that information is necessary to provide you with our Services. 

Information You Provide to Us.

Registration and Profile Information. When you register for an account, we ask you for your email address and birth year.  We do not request your phone number or your birth date. 

Payment Information. We do not currently request any payment information during this beta testing phase. Therefore, until and unless we require a credit card or payment method for your account, no third-party service provider handles payments on our behalf or processes payment card information.

Communications. When you communicate with us, we may receive additional information about you. For example, when you communicate with our Customer Support Team, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may use technologies such as web beacons to track whether you open them to learn how to deliver a better customer experience and improve our Services.

Information We Collect Automatically When You Use Our Services.

When you use the Services, we use a variety of electronic tools, such as cookies, pixel tags, and similar technologies (collectively referred to in this Privacy Policy as “cookies”) to automatically generate information about how you use and interact with the Services as discussed in this section.

What are Cookies? Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer, or small graphic images placed on web pages or in emails. They can be stored either for a single browser session or more permanently. 

We use cookies to collect information about your browsing activities, distinguish you from other users, provide functionality, and analyze use of the Services. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. The types of cookies we and third parties may use to collect information are as follows:

• Strictly necessary cookies. Some cookies are strictly necessary to make the Services available to you. We cannot provide you with the Services without this type of cookies.

• Functional cookies. These are used to recognize you when you return to the Services. This enables us to adapt our content for you, and remember your preferences (for example, your choice of language or region).

• Analytical or Performance cookies. We also use cookies for analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics cookies or use third party analytics providers such as Google Analytics to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. You can opt out of Google Analytics by installing Google’s browser plug-in located here.

You can find more information about your rights and choices, and how to block the use of certain cookies in the section Your Rights and Choices below.

What information do we automatically collect as you use the Services?

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, Internet Service Provider, web browser type, operating system version, phone carrier and manufacturer, application installations, device type and identifiers, and mobile advertising identifiers.

Location Information. We may infer your general location information from other information we collect from and about you (for example, your IP address may indicate your general geographic region).

Usage Information. To help us understand and analyze how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view or interact with, the searches you conduct, your comments, any content you enter or post, commands you type, and the dates and times of your visits.

How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;

• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

• To facilitate the connection of third-party services or applications, such as social networks;

• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;

• To personalize your experience on our Services such as presenting tailored content;

• To facilitate transactions and payments;

• To detect and prevent fraud, and respond to trust and safety issues that may arise;

• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

• For other purposes for which we provide specific notice at the time the information is collected.

De-Identified Information. Please note that we may de-identify the information we collect from and about you so that it can no longer be reasonably linked to you or your device. Once information has been de-identified in this way, we can use and share it for any purpose in our discretion, and this Privacy Policy no longer applies to such information.

Your Privacy Obligations

Bento Flare provides you with the ability to claim task completion microrewards from third parties, which could be used to collect personally identifiable information.    We do not own or operate these third parties.  We are not responsible for the privacy practices of these third parties. 

We encourage you to read their privacy policies before redeeming microrewards or otherwise providing any information to them. If you choose to redeem these microrewards, it is your responsibility to request data deletion from third party microrewards providers if you prefer this level of privacy protection. 

Our Privacy Protection Obligations

In addition to the protocols described above, we also comply with laws and privacy protections including:

• Providing Flare users with appropriate notices of their privacy rights, which incorporate this Privacy Policy by reference.

• Providing any required notices and obtaining any required verifiable parental consent under the Children’s Online Privacy Protection Act (COPPA) or similar laws.  Currently, Bento Flare Beta Testing is limited to adult end users. 

• Complying with legal obligations to allow Bento Flare users to correct their personally identifiable information or to have it erased.  Requests for deletion can be requested here: 855-440-2055 (phone) or support@bentobio.com (email). 

Legal Bases for Processing Information

Various global privacy laws (such as those in the European Economic Area, United Kingdom, and Brazil) require that we have a “legal basis” to process your information.

The legal bases on which we rely to process your information include:

• End User Account creation necessity. We need your information to provide you with the Services, for example to facilitate your registration and respond to your inquiries.

• Compliance with a legal obligation. We have a legal obligation to use your information, for example to comply with tax and accounting obligations.

• Legitimate interests. We have a legitimate interest in using your information for a business purpose that does not override your individual rights and interests. For example, we have a legitimate interest in using your information for product development and internal analytics purposes, to improve the accuracy of our machine learning technologies such as code generation, and otherwise to improve the safety, security, and performance of our Services.

How We Share the Information We Collect

We do not share identifiable information with third parties.

**As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe in good faith that doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoenas; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Marketing Communications. 

You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

European Privacy Rights. If you are located in the European Economic Area or the United Kingdom, you have the additional rights described below.

• You may request access to the information we maintain about you, update and correct inaccuracies in your information, restrict or object to the processing of your information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your information to another company (where technically feasible). In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details here:  855-440-2055 (phone) or support@bentobio.com (email).  Before responding to your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Retention.  We take measures to delete your information or maintain it in a de-identified form when it is no longer necessary to be kept in identifiable form for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by applicable law and any statute of limitations. When you request to delete your account, we delete your data within 30 days.

Security.  We use a variety of technical, organizational, and physical safeguards designed to safeguard the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.  We use subprocessors that help us deliver a high-quality service to our customers. Under the GDPR, a subprocessor is any company that a processor engages to process data on its behalf. This may include third party service providers like cloud infrastructure, payments processors, analytics providers, and other software providers.   Bento Flare subprocessors include inter alia Google Cloud Services (USA Location); Amazon Web Services (USA Location); Appsflyer (USA location).  

Children’s Privacy. Our Services are directed to a general adult audience and are not directed to children under the age of 13. By agreeing to our Privacy Policy and Terms of Service, you represent that you are allowed to use our Services according to your country’s applicable age limits. If we learn that a child is under the age of 13 in the United States, or is under the applicable age requirement in another jurisdiction, we will take reasonable steps to obtain parental consent or delete the user’s personal information from our files as soon as is practicable.

Additional Information for California Residents.  If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the categories of “personal information” (as defined in the CCPA) that we collect from and about you, the purposes for which we use each category, and the third parties to which we share each category for a business purpose.  If you are a California resident, you may exercise the following rights with regard to data where we determine the purposes and means of processing:

• The right to request a copy of the personal information that we have collected about you in the prior 12 months.

• The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.

• The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.

• The right to opt out of the sale of your personal information. We do not “sell” personal information as such term is defined in the CCPA.

California residents can submit access and deletion requests by calling or emailing us at Requests for deletion can be requested here: 855-440-2055 (phone) or support@bentobio.com (email).

International Visitors. Our Services are hosted in the United States.  If you use the Services from regions of the world with laws governing data processing, you accept that you are transferring your information to the United States and other hosting locations for storage and processing. By providing information to Bento Flare, you agree to such transfer and processing.

Changes to this Privacy Policy.  We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we process information, we will provide you with notice in the application and via email in accordance with applicable legal requirements.

Contact Information. If you have any questions, comments, or concerns about our processing activities, please email us at support@bentobio.com or write to us at 1818 Library Street, Suite 500, Reston, Virginia 20190.