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Privacy Policy

Privacy Policy for Ben, Your Personal Concierge

Last updated: October 16, 2025

1. Introduction

Welcome to Ben, your Personal Concierge (the “App”). This Privacy Policy explains how Benfin.ai Inc. (“we”, “us”, or “our”) collects, uses, discloses, and protects your personal information when you use the App on iOS devices. By downloading, installing, or using the App, you agree to the terms of this Privacy Policy.

2. Information We Collect

Category	Types of Data Collected	Purpose
Conversation Data	Text messages and conversations with the AI assistant, including any personal information you choose to share.	Provide AI assistance, maintain conversation context, and improve responses.
Location Information	Location data only when voluntarily provided by you within conversations (e.g., “find restaurants near me in San Francisco”).	Provide location-based recommendations and assistance when requested.
Basic Technical Data	IP address, device type, app version, crash reports (if any).	Ensure app functionality, security, and technical support.

We only collect the data necessary to provide AI assistance and maintain basic app functionality. We do not access your device contacts, calendar, photos, or other personal files.

3. How We Use Your Information

Provide & Maintain Services – Process AI queries, generate responses, and keep the App operational.
Communications – Respond to support requests and send important service updates.
Personalization – Tailor AI responses based on the conversation context you provide.
Analytics & Improvement – Analyze usage trends (in aggregate) to enhance performance and user experience.
Legal & Safety – Comply with legal obligations, enforce our Terms of Service, and protect against fraud or abuse.

4. Sharing & Disclosure

Recipient	Reason for Sharing	Data Shared
Your Wealth Manager	Provide personalized services.	Full conversation history, usage analytics, and activity reports linked to your license number.
Service Providers (e.g., cloud hosting, AI processing)	Perform core functions on our behalf.	Conversation data and technical information needed for AI processing.
Legal Authorities & Regulators	Comply with legal processes, subpoenas, court orders, and financial-regulatory requirements (SEC, FINRA).	Information required by law; raw conversational data as required by SEC Rule 17a-4 and FINRA Rule 4511.
Business Transfers	Merger, acquisition, or sale of assets.	All user data transferred as part of the transaction.
Aggregated/Anonymized Data	Research, statistical analysis, public reporting.	No personally identifiable information.

Important: Your wealth manager can identify you and access your conversations and usage data through the license-number system. This data sharing enables integrated financial advisory services.

We do not systematically gather or use personally identifiable information.

We do not sell or rent your personal information to third parties for marketing purposes.

5. Data Retention

Data Type	Retention Period
Conversation Data	Retained for a minimum of 6 years to comply with SEC Rule 17a-4 and FINRA Rule 4511 (first 2 years in an easily accessible format).
Regulatory Compliance Records	Raw conversational data retained as required by SEC and FINRA regulations, stored in a non-erasable format with complete audit trails.
Technical & Log Data	Retained for up to 24 months for security, troubleshooting, and functionality purposes.

We delete or anonymize data when it is no longer needed for the purposes described herein, subject to regulatory retention requirements.

6. Your Rights

Right	Description	How to Exercise
Access	Request a copy of the personal data we hold about you.	Contact your wealth manager or email privacy@benfin.ai.
Correction	Request correction of inaccurate or incomplete data.	Contact your wealth manager or email privacy@benfin.ai.
Deletion	Request erasure of your personal data (subject to regulatory retention).	Contact your wealth manager – note that financial regulations may require data retention.
Portability	Receive your data in a commonly used format.	Contact your wealth manager or email privacy@benfin.ai.

For residents of the European Economic Area (EEA) and the United Kingdom, these rights are provided under the General Data Protection Regulation (GDPR). For California residents, we comply with the California Consumer Privacy Act (CCPA).

7. Children’s Privacy

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such data, please contact us at privacy@benfin.ai for removal.

8. Security Measures

Encryption: Data in transit is protected using TLS 1.2 or higher; stored data is encrypted at rest.
Access Controls: Restricted to authorized personnel on a need-to-know basis.
Regular Audits: Periodic security assessments and vulnerability testing.

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure.

9. International Data Transfers

Your information may be transferred to and processed in countries outside your residence, including the United States. We use appropriate safeguards (e.g., Standard Contractual Clauses) to ensure such transfers comply with applicable data-protection laws.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “Last updated” date. Continued use of the App after revisions constitutes acceptance of the updated policy.

11. Contact Us

Benfin.ai Inc.
Address: 1007 North Orange Street, 4th Floor, Wilmington, DE, 19801
Email: privacy@benfin.ai

12. Important Disclaimers

Not Financial or Health Advice: Personal Concierge is an AI-powered assistant tool and does not provide financial advice, investment recommendations, or health/medical advice. Any information provided by the AI should not be considered professional financial or health guidance. Always consult qualified advisors or healthcare providers for specific advice.

Wealth Manager Relationship: Your access to Personal Concierge is provided through your wealth manager’s license. For questions about financial services or advice, please contact your wealth manager directly.

This Privacy Policy is provided for informational purposes and does not constitute legal advice. Please consult a qualified attorney to ensure compliance with all applicable laws and regulations.