Privacy Policy

1.1 Information You Provide

When you create an account, subscribe, or interact with our Platform, you may provide the following information:

• Account Information: Name, email address, and password when you register for an account.
• Payment Information: Billing details and payment method information processed through our payment processor, Stripe. Vrenberg does not directly store your full credit card number, bank account number, or other sensitive payment credentials.
• Communication Data: Information you provide when contacting our support team, submitting feedback, or responding to surveys.
• AI Tutor Interactions: Messages, prompts, and queries you submit to the AI tutor feature, as well as the responses generated.

1.2 Information Collected Automatically

When you access or use the Platform, we automatically collect:

• Performance Data: Question responses, answer accuracy, time spent per question, session duration, topic-level mastery metrics, mock exam scores, readiness assessment results, and study pattern data.
• Device and Technical Data: IP address, browser type and version, operating system, device type, screen resolution, language preference, referring URLs, and access timestamps.
• Usage Data: Pages viewed, features accessed, navigation paths, click patterns, session frequency, and interaction patterns with Platform tools.
• Cookie and Tracking Data: Information collected through cookies, pixels, and similar technologies as described in our Cookie Policy.

1.3 Information from Third Parties

We may receive information about you from third-party services you use to authenticate with the Platform (such as Google or Apple sign-in), payment processors, and analytics providers. This information is used in accordance with this Privacy Policy.

We use the information we collect for the following purposes:

2.1 Platform Operations

• Providing, maintaining, and improving the Platform and its features.
• Processing your subscription payments and managing your account.
• Powering adaptive learning, readiness assessments, performance recovery, and analytics features based on your practice data.
• Generating AI tutor responses tailored to your questions and demonstrated knowledge level.
• Sending transactional communications (account verification, billing confirmations, security alerts).

2.2 Research, Analytics, and Improvement

• Analyzing aggregated and anonymized usage patterns to improve Platform effectiveness.
• Conducting research on educational outcomes, study methodologies, and exam preparation patterns.
• Developing, testing, and refining new features, algorithms, and content.
• Generating aggregated benchmarks, statistical reports, and industry research.

2.3 Communication

• Sending product updates, feature announcements, and educational content (with opt-out available).
• Responding to your support requests and inquiries.
• Notifying you of changes to these policies or our Terms of Service.

2.4 Security and Compliance

• Detecting, preventing, and investigating fraud, abuse, and unauthorized access.
• Enforcing our Terms of Service and protecting the rights and safety of our users.
• Complying with applicable laws, regulations, and legal processes.

Where applicable (including under the EU General Data Protection Regulation, UK GDPR, and similar frameworks), we process your personal data on the following legal bases:

• Contract Performance: Processing necessary to fulfill our contractual obligations to you, including providing access to the Platform and its features.
• Legitimate Interests: Processing necessary for our legitimate interests, including improving the Platform, conducting analytics and research, preventing fraud, and ensuring security, where those interests are not overridden by your rights.
• Consent: Processing based on your consent, such as marketing communications and certain cookie usage. You may withdraw consent at any time.
• Legal Obligation: Processing necessary to comply with applicable laws, regulations, court orders, or legal processes.

We do not sell your personal data. We share your information only in the following circumstances:

• Service Providers: We share data with trusted third-party service providers who process it on our behalf, including payment processors (Stripe), cloud hosting providers (Supabase, Vercel), AI service providers (OpenAI for AI tutor functionality), analytics tools, and email delivery services. These providers are contractually bound to use your data only for the purposes we specify.
• Legal Requirements: We may disclose your information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of the transaction. We will notify you of any such transfer and any choices you may have regarding your data.
• Aggregated and Anonymized Data: We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, benchmarking, marketing, or other commercial purposes without restriction.

We retain your personal data for as long as your account is active or as needed to provide you with the Services. After account closure, we retain personal data for a reasonable period to comply with legal obligations, resolve disputes, enforce our agreements, and support legitimate business operations.

Specific retention periods include:

• Account Data: Retained for the duration of your account plus 30 days after deletion request to allow for account recovery.
• Payment Records: Retained for seven (7) years as required by financial regulations and tax obligations.
• Performance Data: Retained for the duration of your account. Upon account deletion, performance data is anonymized and retained in aggregate form for research and analytics purposes.
• AI Tutor Conversations: Retained for the duration of your account. Conversation data may be retained in anonymized form for AI model improvement after account deletion.
• Server Logs: Retained for 90 days for security and operational purposes.

We implement commercially reasonable technical, administrative, and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols.
• Encryption of sensitive data at rest.
• Access controls and authentication mechanisms for internal systems.
• Regular security assessments and monitoring.
• Secure payment processing through PCI DSS-compliant third-party processors.

Despite these measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your data. You acknowledge and accept the inherent security risks of providing information online and agree not to hold Vrenberg responsible for any breach of security beyond our reasonable control.

Depending on your jurisdiction, you may have certain rights regarding your personal data, including:

• Access: The right to request a copy of the personal data we hold about you.
• Rectification: The right to request correction of inaccurate or incomplete personal data.
• Erasure: The right to request deletion of your personal data, subject to legal retention requirements and legitimate interests.
• Restriction: The right to request restriction of processing of your personal data.
• Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Objection: The right to object to processing of your personal data for certain purposes, including direct marketing.
• Withdrawal of Consent: The right to withdraw previously given consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at legal@vrenberg.com. We will respond to your request within 30 days or such shorter period as required by applicable law. We may ask you to verify your identity before processing your request.

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with a data protection authority, you have the right to lodge a complaint with your local supervisory authority.

Vrenberg operates globally and may transfer, store, and process your personal data in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from the laws of your jurisdiction.

Where we transfer personal data outside the European Economic Area, the United Kingdom, or other jurisdictions with transfer restrictions, we implement appropriate safeguards to ensure your data receives an adequate level of protection, including:

• Standard Contractual Clauses approved by the European Commission.
• Transfers to countries with adequacy decisions.
• Other legally recognized transfer mechanisms.

By using the Platform, you consent to the transfer of your data to the United States and other jurisdictions as described in this section.

The Platform is not directed to individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will promptly delete such data. If you believe a child under 18 has provided us with personal data, please contact us at legal@vrenberg.com.

The Platform integrates with and relies on the following categories of third-party services:

• Payment Processing: Stripe processes all payment transactions. Your payment data is subject to Stripe's privacy policy.
• Cloud Infrastructure: Supabase provides database services, and Vercel provides hosting and edge computing. Your data stored on these platforms is subject to their respective security and privacy practices.
• AI Services: OpenAI provides the language model powering the AI tutor feature. Prompts and queries you submit to the AI tutor are transmitted to OpenAI for processing. OpenAI's data handling practices apply to data processed through their systems.
• Analytics — Google Analytics 4 & Google signals: We use Google Analytics 4 (provided by Google LLC) to measure how visitors discover and interact with the Platform. Google Analytics sets cookies and processes information such as IP address, device and browser identifiers, approximate location, pages viewed, referring source, and events you trigger (for example, sign-up, starting a free trial, downloading the formula sheet, or completing a purchase). We have enabled Google signals, User-ID, and granular location and device data collection. When a visitor is signed in to a Google account and has consented (in their Google account) to ads personalization, Google may associate the visitation information collected here with information from that Google account — including end-user location, search history, YouTube history, and data from sites that partner with Google — to enable cross-device measurement and aggregate audience insights. You can opt out of Google Analytics entirely with the Google Analytics Opt-out Browser Add-on, manage ads-personalization controls in your Google account, or block analytics cookies via the controls described in our Cookie Policy.

User-Data Collection Acknowledgement. By using the Platform you acknowledge that Vrenberg has provided you with the necessary disclosures (in this Policy and our Cookie Policy) and obtained the rights required for the collection and processing of your data described above, including the association of such data with the visitation information that Google Analytics collects from this site and any related applications.

We encourage you to review the privacy policies of these third-party services. Vrenberg is not responsible for the privacy practices of third-party services.

We may update this Privacy Policy from time to time. Material changes will be communicated by posting the revised policy on the Platform with an updated “Last Updated” date, and where required by law, by notifying you via email. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised policy.

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related inquiries within 30 days.