Privacy Policy
Last updated: April 8, 2025
The Benji Group, Inc. (referred to as “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your privacy online. The purpose of this document (the “Privacy Policy”) is to explain to you how we use information that we have collected from and about you. If, after reviewing the Privacy Policy, you have questions, please contact us at https://withbenji.com/contact/. This Privacy Policy applies to the services (the “Services”) provided through the Company website located at https://withbenji.com (the “Website”). It does not apply to the practices of other companies that Company does not own or control, nor does it apply to information of any kind provided to the Company by advertisers or other business partners. Other websites are governed by their own policies.
If this Privacy Policy is not acceptable to you, you should discontinue using the Services.
1) What information do we collect from or about you?
In this Policy, we refer to two types of user information: Personally Identifiable Information (sometimes referred to as “PII”) and non-Personally Identifiable Information.
Personally Identifiable Information refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Personally Identifiable Information include a name, physical address, email address, telephone number, date of birth, or credit card number.
The Company collects only the PII that you voluntarily provide to us or our partners, such as when you register to use the Services, set up a profile, create content, sign up for a special offer, enter a sweepstakes or promotion, or complete a survey.
You might also be asked for, or choose to provide, additional information about yourself that does not, itself, specifically identify you. This is non-Personally Identifiable Information. However, some information of this kind, such as your age, gender, geographic location, and shopping preferences may be required (or merely requested) when you register for the Services and may be associated with your PII.
Company may also automatically collect other types of non-Personally Identifiable Information as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is anonymous, and is not associated with your PII, although it may be associated with other pieces of anonymous information about you.
Please see Exhibit 1 for the categories of information we collect.
2) What do we use your information for?
Your Personally Identifiable Information may be used in one of the following ways:
To contact you regarding your account. These communications may include notices regarding changes to our policies, service updates, account management procedures, and customer service transactional messages;
To email you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners; and
To bill your credit card or other specified form of payment, in accordance with the Terms of Use.
Non-Personally Identifiable Information may be used in one of the following ways:
To enable us to generate aggregate data about site traffic, site interaction, user characteristics, preferences, and purchases, in each case as long as such data is sufficiently extracted, modified, or transformed so that it cannot be reverse-engineered or otherwise identified at the individual user-level from inspecting, analyzing, or further processing data;
To customize your experience (your information helps us to better respond to your individual needs);
To show you advertisements most relevant to your demographic characteristics;
To make improvements to the Website and Services; and
To inform potential partners and advertisers about the size and characteristics of our audience.
3) Do we sell or trade any information to other parties?
The Company does not sell or trade your Personally Identifiable Information to outside parties.
4) How secure is your personal information?
The security of our user data is very important to us. We store your information securely using industry-standard encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
5) How long do we retain your information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time in case you decide to re-activate your account. We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion. Further, some information may be retained if it is contained in deleted emails or electronic documents that are archived in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents.
If you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those with whom it was shared.
6) Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. The Company does not currently use cookies, but we have relationships with third-party vendors and partners who assist us with aspects of the Website and the Services, including serving advertisements, understanding Website usage, providing functionalities such as email distribution and content contribution, delivering customer surveys, and the like. These vendors typically use cookies and similar tracking technologies, such as web beacons (also known as clear GIFs, web bugs, or tracking pixels), which are similar in function to cookies, allowing a website to determine when users have reached particular Web pages or performed certain actions.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server of the website that issued the cookie to you.
Depending on your web browser, you may have the ability to accept or decline cookies. Most web browsers default to accept cookies but enable you to configure settings to decline them. For further information about disabling cookies, you can visit allaboutcookies.org. If you choose to decline cookies, you may not be able to sign in or use other features of the Services that depend on cookies.
Company maintains internal logs of usage of the Services. Logs include information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. Company uses logs mainly for internal systems administration and diagnostic purposes and to detect improper use of the site. Logs may also be used to generate aggregate, non-Personally Identifiable Information for advertisers or other third parties. The Company may collect such usage logs even if you do not have the Website open.
Company does not use cookies, similar technologies, or its internal logs to associate your Personally Identifiable Information with data about your use of the site.
If you register for any part of the Services, we may offer you the option to save certain information, such as your username and password, via Local Device Storage (LDS). You can disable LDS on your device or browser; however, doing so may render a portion of the Services to not function properly.
7) How can you access, update, or delete your Personally Identifiable Information?
If you wish to have all information about you that either you or a merchant or points programmer provided have provided to Benji deleted, please contact us at privacy@withbenji.com and we will make reasonable efforts to honor your request in compliance with applicable laws. Anonymous information relating to your past usage of the Services may remain in our archived records.
New types of marketing communications may be added from time to time. You can opt out of receiving future marketing communications by emailing privacy@withbenji.com or by following instructions contained in messages you receive.
Please remember that the merchants and points program providers may provide your data in association with transactions, and therefore, your information may be transmitted after an initial deletion if you participate in a transaction using The Benji group marketplace.
8) What if we make changes to our Privacy Policy?
Because enhancements to the Services we provide may affect the information that we collect and the manner in which we use it, this Privacy Policy may change from time to time. All changes will be incorporated into the written policy and posted here. The date of the most recent revision to the Privacy Policy is indicated at the bottom of this page.
The Company will provide you with the opportunity to accept or reject significant changes to the Privacy Policy during your next sign-on to the Services. If you do not agree to the modifications, your access to the Services may be discontinued
9) How do we comply with state consumer data privacy laws?
Many states in the United States have implemented their own consumer data privacy laws, and we strive to comply with all data privacy laws that apply to our business. State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information that would, for example, require us to do some or all of the following:
Allow you to opt out of personal data processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects;
Allow you to opt-out from the processing and use of Sensitive Data;
Confirm whether we process your personal information;
Correct inaccuracies in your personal information;
Delete certain personal information;
Exercise any of the rights above for your child if the child is below the age of 13 (even if your child’s use of the services violates our Terms of Use or Privacy Policy);
Honor requests made under applicable laws that are made by valid authorized agents on your behalf;
Honor opt-out signals made via application, program, or other process by third parties on your behalf;
Make certain disclosures about our use of your personal information;
Provide your personal information in a common file format;
Provide an itemized list of all third parties with which we have shared your data; and
Provide you with information about the data gathered and the uses of the data if we offer any incentive or loyalty programs to you that require the disclosure of additional data that is not required to offer the services.
The scope of these rights varies by state of residence. To exercise any of these rights, please contact us using the information below or use the official state online request form and send us a copy. We will review your request and either comply or notify you that your request was denied and explain why it was denied. Additionally, to the extent allowed by applicable law, we may contact you to validate your identity and that you made the request; failure to respond to these communications may result in a denial of your request.
If you wish to appeal our decision, you must submit your appeal within 30 days from the date your request was denied.
We will not deny you services, charge you different prices or rates, provide you with a different level of services, or otherwise discriminate against you solely because you exercised your privacy rights.
10) What if you have questions that are not answered here?
If there are any questions regarding this Privacy Policy, you may contact us using the information below:
The Benji Group, Inc.
Attention: Privacy
1178 Broadway, 3rd Floor #1320
New York, NY 1001
Exhibit 1: Data Categories
A. Identifiers.
Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Collected: YES
B. Personal information.
Example: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES
C. Sensitive Information.
Example: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: NO
D. Commercial information.
Example: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES
E. Biometric information.
Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO
F. Internet or other similar network activity.
Example: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected: YES
G. Geolocation data.
Example: Physical location or movements.
Collected: NO
H. Sensory data.
Example: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO
I. Professional or employment-related information.
Example: Current or past job history or performance evaluations.
Collected: NO
J. Non-public education information.
Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO
K. Inferences drawn from other personal information.
Example: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: NO
THE BENJI GROUP, INC. PRIVACY POLICY ADDENDUM
FOR EEA RESIDENTS USING THE SERVICES
PURSUANT TO GDPR
This Addendum applies to you if you are a resident of the European Economic Area (EEA), which is the European Union plus Norway, Iceland and Lichtenstein, and you use our Services. This Addendum prevails over the standard terms of our Privacy Policy at https://withbenji.com/privacy. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Privacy Policy.
In this Policy, we refer to two types of user information: Identified Personal Data and Non-Identified Personal Data.
Identified Personal Data (IPD) refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Identified Personal Data include a name, physical address, e-mail address, telephone number, date of birth, or a credit card number.
The Company collects only the IPD that you voluntarily provide to us (such as when you register to use the Services, set up a profile, or create content) or that a partner shares with us on your behalf with your permission.
Non-Identified Personal Data (NIPD) refers to additional information about yourself that does not, itself, specifically identify you, that you might also be asked for, or choose to provide. However, some information of this kind, such as your geographic location and learning preferences may be required (or merely requested) when you register for the Services and may be associated with your IPD.
The Company may also automatically collect other types of NIPD as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is not associated with your IPD, although it may be associated with other pieces of non-identified information about you.
Both IPD and NIPD are personal data in the meaning of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC General Data Protection Regulation (GDPR).
Who controls your personal data?
We, the Company as defined in the Privacy Policy, control your personal data. You can contact us via contact details provided at our website in the Section “Contact”. Our representative for the purpose of the GDPR is Jon, whom you can contact by going to withbenji.com/contact.
Purposes and basis for processing
Providing your Identified Personal Data is required to allow us to provide you with the Services. Your Identified Personal Data may be used in one of the following ways:
To contact you regarding your account in performance of our contract or to provide pre-contractual information. These communications may include notices regarding changes to our policies, Service updates, account management procedures and customer Service transactional messages.
To bill your appropriate points accounts with various third-party companies as necessary for you to use the Services.
To e-mail you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners – pursuing our legitimate interest in marketing our Services.
Your Non-Identified Personal Data may be used in one of the following ways pursuing our legitimate interest in marketing and optimization of our Services:
To enable us to generate aggregate data about site traffic and site interaction.
To customize your experience (your information helps us to better respond to your individual needs).
To show you opportunities most relevant to your demographic characteristics.
To make improvements to the Website and Services
To inform potential partners and advertisers about the size and characteristics of our audience
The Company maintains internal logs of usage of the Services. Logs include NIPD information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. The Company uses logs mainly for its legitimate interests such as internal systems administration and diagnostic purposes, and to detect improper use of the site.
Logs may also be used by the Company pursuing its legitimate interest to generate aggregate, non-Personally Identified Data. The Company may collect such usage logs even if you do not have the Website open.
Data recipients
We describe the categories of potential recipients of your personal data in our main Privacy Policy in the section titled “How secure is your personal information?” we describe the potential recipients of your personal data.
Due to use of third-party plug-ins, pages or third-party services and integrations (e.g. for authorization or localization purpose) we may disclose information about your browser, activity, localization to other entities in order to fulfill your requests, or to provide services that you have requested.
As for our IT infrastructure and other relevant information about recipients of your personal please refer to the following section.
How secure is your personal information?
The security of our user data is very important to us. We store your information securely in a globally leading cloud services infrastructure provider, using industry-compliant encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
How long do we retain your personal information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Primary retention. Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time up to 180 days post closing in case you decide to re-activate your account.
We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion.
Further, some information may be retained if it is contained in deleted emails or electronic documents which are archived by our company in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents. We intend to keep such archives for Five Years from the end of a calendar year they have been created
Please, be advised that if you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those users or Merchants with whom you shared it, as since you shared that information with them it has become theirs as well.
In case your information is needed for a specific legal proceeding, we may keep such information as long as the proceeding in question is ongoing.
Your Rights
You have the right to:
request access and copies of your personal data, unless it would adversely affect the rights and freedoms of others
request to have your information rectified if it is inaccurate or incomplete;
request we erase your personal data in certain circumstances;
request restriction of processing of your personal data in certain circumstances;
request to receive your data you have provided us based on your consent or a contract, in a structured, commonly used and machine -readable format or request us to transmit those data to another controller;
to object to processing of your personal data If we are relying on a legitimate interest in case you are in a particular situation or if we are processing your information for direct marketing purposes;
Right to withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place. If you exercise this right, we may keep minimum information about you (for example on a so called “Robinsons list”) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
To exercise your rights please contact us at privacy@withbenji.com. However, please note that we may not be able to provide some or all of the Services without some necessary data collected from you.
Right to lodge a complaint with the data protection authority. If you have a concern about processing your personal data infringes the GDPR, you may lodge a complaint with the data protection authority in the member state of European Union of your habitual residence, place of work or place of the alleged data infringement.
Children’s Personal Data
We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Services, please contact us and we will endeavor to delete that information from our databases.
If you are under the age of 16, you need to provide us with a consent of the holder of parental responsibility over yourself, to allow us to process your personal data.
Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. We use “cookies” to collect information and improve our Services. We may use “persistent cookies” to save your user ID and password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server of the website that issued the cookie to you.
We use necessary and functionality cookies (required to perform our Services) and analytics and targeting cookies, when we have your consent to collect and use them.
Categories of cookies.
Necessary cookies. Strictly necessary cookies are strictly necessary to provide you with the Services. The information collected through these cookies is used only for the purpose of providing you with the Services and is never shared with third parties.
You cannot refuse those cookies. You may block or delete them by changing your browser settings, but you may not be able to use Services features, and in some cases the The Benji Group website simply will not perform.
Preferences cookies. Functional cookies allow us to remember the choices you make and provide enhanced, more personal features. Examples include your username, language, region, customizations, and prior purchase history. The information collected through these cookies is used for this purpose only and is never shared with third parties.
Performance & Statistic. We work with third parties who use cookies to collect data that helps us understand how people are using our site. We use this information to identify improvements we can make to the user experience.
Marketing & Targeting. We work with third parties who use cookies to collect information about the pages, links, and other sites that you visit. These cookies are used to deliver advertisements that are more relevant to you and your interests across the internet. This information collected by these cookies will be used to track visits and actions on our site, as well as to deliver reporting and analytics to us and our partners. You can opt out of targeted advertising associated with our Website by clicking opt out of (useful links below), which will block targeted ads on the web browser or device you are on.
The following cookies are used:
Facebook (https://www.facebook.com/policies/cookies/)
Google Maps (https://policies.google.com/technologies/types?hl=en)
Google Analytics (https://policies.google.com/technologies/partner-sites?hl=en)
Twitter (https://help.twitter.com/en/rules-and-policies/twitter-cookies)
Pinterest (https://policy.pinterest.com/en/privacy-policy)
How can I control cookies?
All browser technologies enable you to manage the cookies in the cookie folder of your web browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our website or you can set your preferences with regard to the use of cookies before you begin browsing our website. Please note, as stated above, that deleting or rejecting cookies may adversely affect your user experience of our website.
You can find further information at:
Where can I find more information about cookies?
If you want to learn more about cookies or how to control, disable, or delete them, please visit www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google https://adssettings.google.com/u/0/authenticated?hl=en.
You can also learn more about targeting and retargeting for advertising, and about how to turn this feature off, by visiting www.networkadvertising.org, or in the case of those residing in the EU or UK, by visiting http://www.youronlinechoices.com.
Tracking technologies
Cookies are not the only way to recognize or track visitors to a website. Web beacons (sometimes called “tracking pixels” or “clear gifs”) are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our or taken an action in relation with Services.
How to refuse tracing technologies? In many instances, these technologies are reliant on cookies to function properly. As a result, declining cookies will impair their functioning. Where to look for more information?
You may find more information on the way we process your information at https://withbenji.com/privacy.
Privacy Policy
Last updated: April 8, 2025
The Benji Group, Inc. (referred to as “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your privacy online. The purpose of this document (the “Privacy Policy”) is to explain to you how we use information that we have collected from and about you. If, after reviewing the Privacy Policy, you have questions, please contact us at https://withbenji.com/contact/. This Privacy Policy applies to the services (the “Services”) provided through the Company website located at https://withbenji.com (the “Website”). It does not apply to the practices of other companies that Company does not own or control, nor does it apply to information of any kind provided to the Company by advertisers or other business partners. Other websites are governed by their own policies.
If this Privacy Policy is not acceptable to you, you should discontinue using the Services.
1) What information do we collect from or about you?
In this Policy, we refer to two types of user information: Personally Identifiable Information (sometimes referred to as “PII”) and non-Personally Identifiable Information.
Personally Identifiable Information refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Personally Identifiable Information include a name, physical address, email address, telephone number, date of birth, or credit card number.
The Company collects only the PII that you voluntarily provide to us or our partners, such as when you register to use the Services, set up a profile, create content, sign up for a special offer, enter a sweepstakes or promotion, or complete a survey.
You might also be asked for, or choose to provide, additional information about yourself that does not, itself, specifically identify you. This is non-Personally Identifiable Information. However, some information of this kind, such as your age, gender, geographic location, and shopping preferences may be required (or merely requested) when you register for the Services and may be associated with your PII.
Company may also automatically collect other types of non-Personally Identifiable Information as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is anonymous, and is not associated with your PII, although it may be associated with other pieces of anonymous information about you.
Please see Exhibit 1 for the categories of information we collect.
2) What do we use your information for?
Your Personally Identifiable Information may be used in one of the following ways:
To contact you regarding your account. These communications may include notices regarding changes to our policies, service updates, account management procedures, and customer service transactional messages;
To email you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners; and
To bill your credit card or other specified form of payment, in accordance with the Terms of Use.
Non-Personally Identifiable Information may be used in one of the following ways:
To enable us to generate aggregate data about site traffic, site interaction, user characteristics, preferences, and purchases, in each case as long as such data is sufficiently extracted, modified, or transformed so that it cannot be reverse-engineered or otherwise identified at the individual user-level from inspecting, analyzing, or further processing data;
To customize your experience (your information helps us to better respond to your individual needs);
To show you advertisements most relevant to your demographic characteristics;
To make improvements to the Website and Services; and
To inform potential partners and advertisers about the size and characteristics of our audience.
3) Do we sell or trade any information to other parties?
The Company does not sell or trade your Personally Identifiable Information to outside parties.
4) How secure is your personal information?
The security of our user data is very important to us. We store your information securely using industry-standard encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
5) How long do we retain your information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time in case you decide to re-activate your account. We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion. Further, some information may be retained if it is contained in deleted emails or electronic documents that are archived in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents.
If you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those with whom it was shared.
6) Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. The Company does not currently use cookies, but we have relationships with third-party vendors and partners who assist us with aspects of the Website and the Services, including serving advertisements, understanding Website usage, providing functionalities such as email distribution and content contribution, delivering customer surveys, and the like. These vendors typically use cookies and similar tracking technologies, such as web beacons (also known as clear GIFs, web bugs, or tracking pixels), which are similar in function to cookies, allowing a website to determine when users have reached particular Web pages or performed certain actions.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server of the website that issued the cookie to you.
Depending on your web browser, you may have the ability to accept or decline cookies. Most web browsers default to accept cookies but enable you to configure settings to decline them. For further information about disabling cookies, you can visit allaboutcookies.org. If you choose to decline cookies, you may not be able to sign in or use other features of the Services that depend on cookies.
Company maintains internal logs of usage of the Services. Logs include information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. Company uses logs mainly for internal systems administration and diagnostic purposes and to detect improper use of the site. Logs may also be used to generate aggregate, non-Personally Identifiable Information for advertisers or other third parties. The Company may collect such usage logs even if you do not have the Website open.
Company does not use cookies, similar technologies, or its internal logs to associate your Personally Identifiable Information with data about your use of the site.
If you register for any part of the Services, we may offer you the option to save certain information, such as your username and password, via Local Device Storage (LDS). You can disable LDS on your device or browser; however, doing so may render a portion of the Services to not function properly.
7) How can you access, update, or delete your Personally Identifiable Information?
If you wish to have all information about you that either you or a merchant or points programmer provided have provided to Benji deleted, please contact us at privacy@withbenji.com and we will make reasonable efforts to honor your request in compliance with applicable laws. Anonymous information relating to your past usage of the Services may remain in our archived records.
New types of marketing communications may be added from time to time. You can opt out of receiving future marketing communications by emailing privacy@withbenji.com or by following instructions contained in messages you receive.
Please remember that the merchants and points program providers may provide your data in association with transactions, and therefore, your information may be transmitted after an initial deletion if you participate in a transaction using The Benji group marketplace.
8) What if we make changes to our Privacy Policy?
Because enhancements to the Services we provide may affect the information that we collect and the manner in which we use it, this Privacy Policy may change from time to time. All changes will be incorporated into the written policy and posted here. The date of the most recent revision to the Privacy Policy is indicated at the bottom of this page.
The Company will provide you with the opportunity to accept or reject significant changes to the Privacy Policy during your next sign-on to the Services. If you do not agree to the modifications, your access to the Services may be discontinued
9) How do we comply with state consumer data privacy laws?
Many states in the United States have implemented their own consumer data privacy laws, and we strive to comply with all data privacy laws that apply to our business. State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information that would, for example, require us to do some or all of the following:
Allow you to opt out of personal data processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects;
Allow you to opt-out from the processing and use of Sensitive Data;
Confirm whether we process your personal information;
Correct inaccuracies in your personal information;
Delete certain personal information;
Exercise any of the rights above for your child if the child is below the age of 13 (even if your child’s use of the services violates our Terms of Use or Privacy Policy);
Honor requests made under applicable laws that are made by valid authorized agents on your behalf;
Honor opt-out signals made via application, program, or other process by third parties on your behalf;
Make certain disclosures about our use of your personal information;
Provide your personal information in a common file format;
Provide an itemized list of all third parties with which we have shared your data; and
Provide you with information about the data gathered and the uses of the data if we offer any incentive or loyalty programs to you that require the disclosure of additional data that is not required to offer the services.
The scope of these rights varies by state of residence. To exercise any of these rights, please contact us using the information below or use the official state online request form and send us a copy. We will review your request and either comply or notify you that your request was denied and explain why it was denied. Additionally, to the extent allowed by applicable law, we may contact you to validate your identity and that you made the request; failure to respond to these communications may result in a denial of your request.
If you wish to appeal our decision, you must submit your appeal within 30 days from the date your request was denied.
We will not deny you services, charge you different prices or rates, provide you with a different level of services, or otherwise discriminate against you solely because you exercised your privacy rights.
10) What if you have questions that are not answered here?
If there are any questions regarding this Privacy Policy, you may contact us using the information below:
The Benji Group, Inc.
Attention: Privacy
1178 Broadway, 3rd Floor #1320
New York, NY 1001
Exhibit 1: Data Categories
A. Identifiers.
Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Collected: YES
B. Personal information.
Example: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES
C. Sensitive Information.
Example: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: NO
D. Commercial information.
Example: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES
E. Biometric information.
Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO
F. Internet or other similar network activity.
Example: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected: YES
G. Geolocation data.
Example: Physical location or movements.
Collected: NO
H. Sensory data.
Example: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO
I. Professional or employment-related information.
Example: Current or past job history or performance evaluations.
Collected: NO
J. Non-public education information.
Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO
K. Inferences drawn from other personal information.
Example: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: NO
THE BENJI GROUP, INC. PRIVACY POLICY ADDENDUM
FOR EEA RESIDENTS USING THE SERVICES
PURSUANT TO GDPR
This Addendum applies to you if you are a resident of the European Economic Area (EEA), which is the European Union plus Norway, Iceland and Lichtenstein, and you use our Services. This Addendum prevails over the standard terms of our Privacy Policy at https://withbenji.com/privacy. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Privacy Policy.
In this Policy, we refer to two types of user information: Identified Personal Data and Non-Identified Personal Data.
Identified Personal Data (IPD) refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Identified Personal Data include a name, physical address, e-mail address, telephone number, date of birth, or a credit card number.
The Company collects only the IPD that you voluntarily provide to us (such as when you register to use the Services, set up a profile, or create content) or that a partner shares with us on your behalf with your permission.
Non-Identified Personal Data (NIPD) refers to additional information about yourself that does not, itself, specifically identify you, that you might also be asked for, or choose to provide. However, some information of this kind, such as your geographic location and learning preferences may be required (or merely requested) when you register for the Services and may be associated with your IPD.
The Company may also automatically collect other types of NIPD as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is not associated with your IPD, although it may be associated with other pieces of non-identified information about you.
Both IPD and NIPD are personal data in the meaning of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC General Data Protection Regulation (GDPR).
Who controls your personal data?
We, the Company as defined in the Privacy Policy, control your personal data. You can contact us via contact details provided at our website in the Section “Contact”. Our representative for the purpose of the GDPR is Jon, whom you can contact by going to withbenji.com/contact.
Purposes and basis for processing
Providing your Identified Personal Data is required to allow us to provide you with the Services. Your Identified Personal Data may be used in one of the following ways:
To contact you regarding your account in performance of our contract or to provide pre-contractual information. These communications may include notices regarding changes to our policies, Service updates, account management procedures and customer Service transactional messages.
To bill your appropriate points accounts with various third-party companies as necessary for you to use the Services.
To e-mail you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners – pursuing our legitimate interest in marketing our Services.
Your Non-Identified Personal Data may be used in one of the following ways pursuing our legitimate interest in marketing and optimization of our Services:
To enable us to generate aggregate data about site traffic and site interaction.
To customize your experience (your information helps us to better respond to your individual needs).
To show you opportunities most relevant to your demographic characteristics.
To make improvements to the Website and Services
To inform potential partners and advertisers about the size and characteristics of our audience
The Company maintains internal logs of usage of the Services. Logs include NIPD information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. The Company uses logs mainly for its legitimate interests such as internal systems administration and diagnostic purposes, and to detect improper use of the site.
Logs may also be used by the Company pursuing its legitimate interest to generate aggregate, non-Personally Identified Data. The Company may collect such usage logs even if you do not have the Website open.
Data recipients
We describe the categories of potential recipients of your personal data in our main Privacy Policy in the section titled “How secure is your personal information?” we describe the potential recipients of your personal data.
Due to use of third-party plug-ins, pages or third-party services and integrations (e.g. for authorization or localization purpose) we may disclose information about your browser, activity, localization to other entities in order to fulfill your requests, or to provide services that you have requested.
As for our IT infrastructure and other relevant information about recipients of your personal please refer to the following section.
How secure is your personal information?
The security of our user data is very important to us. We store your information securely in a globally leading cloud services infrastructure provider, using industry-compliant encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
How long do we retain your personal information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Primary retention. Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time up to 180 days post closing in case you decide to re-activate your account.
We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion.
Further, some information may be retained if it is contained in deleted emails or electronic documents which are archived by our company in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents. We intend to keep such archives for Five Years from the end of a calendar year they have been created
Please, be advised that if you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those users or Merchants with whom you shared it, as since you shared that information with them it has become theirs as well.
In case your information is needed for a specific legal proceeding, we may keep such information as long as the proceeding in question is ongoing.
Your Rights
You have the right to:
request access and copies of your personal data, unless it would adversely affect the rights and freedoms of others
request to have your information rectified if it is inaccurate or incomplete;
request we erase your personal data in certain circumstances;
request restriction of processing of your personal data in certain circumstances;
request to receive your data you have provided us based on your consent or a contract, in a structured, commonly used and machine -readable format or request us to transmit those data to another controller;
to object to processing of your personal data If we are relying on a legitimate interest in case you are in a particular situation or if we are processing your information for direct marketing purposes;
Right to withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place. If you exercise this right, we may keep minimum information about you (for example on a so called “Robinsons list”) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
To exercise your rights please contact us at privacy@withbenji.com. However, please note that we may not be able to provide some or all of the Services without some necessary data collected from you.
Right to lodge a complaint with the data protection authority. If you have a concern about processing your personal data infringes the GDPR, you may lodge a complaint with the data protection authority in the member state of European Union of your habitual residence, place of work or place of the alleged data infringement.
Children’s Personal Data
We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Services, please contact us and we will endeavor to delete that information from our databases.
If you are under the age of 16, you need to provide us with a consent of the holder of parental responsibility over yourself, to allow us to process your personal data.
Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. We use “cookies” to collect information and improve our Services. We may use “persistent cookies” to save your user ID and password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server of the website that issued the cookie to you.
We use necessary and functionality cookies (required to perform our Services) and analytics and targeting cookies, when we have your consent to collect and use them.
Categories of cookies.
Necessary cookies. Strictly necessary cookies are strictly necessary to provide you with the Services. The information collected through these cookies is used only for the purpose of providing you with the Services and is never shared with third parties.
You cannot refuse those cookies. You may block or delete them by changing your browser settings, but you may not be able to use Services features, and in some cases the The Benji Group website simply will not perform.
Preferences cookies. Functional cookies allow us to remember the choices you make and provide enhanced, more personal features. Examples include your username, language, region, customizations, and prior purchase history. The information collected through these cookies is used for this purpose only and is never shared with third parties.
Performance & Statistic. We work with third parties who use cookies to collect data that helps us understand how people are using our site. We use this information to identify improvements we can make to the user experience.
Marketing & Targeting. We work with third parties who use cookies to collect information about the pages, links, and other sites that you visit. These cookies are used to deliver advertisements that are more relevant to you and your interests across the internet. This information collected by these cookies will be used to track visits and actions on our site, as well as to deliver reporting and analytics to us and our partners. You can opt out of targeted advertising associated with our Website by clicking opt out of (useful links below), which will block targeted ads on the web browser or device you are on.
The following cookies are used:
Facebook (https://www.facebook.com/policies/cookies/)
Google Maps (https://policies.google.com/technologies/types?hl=en)
Google Analytics (https://policies.google.com/technologies/partner-sites?hl=en)
Twitter (https://help.twitter.com/en/rules-and-policies/twitter-cookies)
Pinterest (https://policy.pinterest.com/en/privacy-policy)
How can I control cookies?
All browser technologies enable you to manage the cookies in the cookie folder of your web browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our website or you can set your preferences with regard to the use of cookies before you begin browsing our website. Please note, as stated above, that deleting or rejecting cookies may adversely affect your user experience of our website.
You can find further information at:
Where can I find more information about cookies?
If you want to learn more about cookies or how to control, disable, or delete them, please visit www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google https://adssettings.google.com/u/0/authenticated?hl=en.
You can also learn more about targeting and retargeting for advertising, and about how to turn this feature off, by visiting www.networkadvertising.org, or in the case of those residing in the EU or UK, by visiting http://www.youronlinechoices.com.
Tracking technologies
Cookies are not the only way to recognize or track visitors to a website. Web beacons (sometimes called “tracking pixels” or “clear gifs”) are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our or taken an action in relation with Services.
How to refuse tracing technologies? In many instances, these technologies are reliant on cookies to function properly. As a result, declining cookies will impair their functioning. Where to look for more information?
You may find more information on the way we process your information at https://withbenji.com/privacy.
Privacy Policy
Last updated: April 8, 2025
The Benji Group, Inc. (referred to as “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your privacy online. The purpose of this document (the “Privacy Policy”) is to explain to you how we use information that we have collected from and about you. If, after reviewing the Privacy Policy, you have questions, please contact us at https://withbenji.com/contact/. This Privacy Policy applies to the services (the “Services”) provided through the Company website located at https://withbenji.com (the “Website”). It does not apply to the practices of other companies that Company does not own or control, nor does it apply to information of any kind provided to the Company by advertisers or other business partners. Other websites are governed by their own policies.
If this Privacy Policy is not acceptable to you, you should discontinue using the Services.
1) What information do we collect from or about you?
In this Policy, we refer to two types of user information: Personally Identifiable Information (sometimes referred to as “PII”) and non-Personally Identifiable Information.
Personally Identifiable Information refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Personally Identifiable Information include a name, physical address, email address, telephone number, date of birth, or credit card number.
The Company collects only the PII that you voluntarily provide to us or our partners, such as when you register to use the Services, set up a profile, create content, sign up for a special offer, enter a sweepstakes or promotion, or complete a survey.
You might also be asked for, or choose to provide, additional information about yourself that does not, itself, specifically identify you. This is non-Personally Identifiable Information. However, some information of this kind, such as your age, gender, geographic location, and shopping preferences may be required (or merely requested) when you register for the Services and may be associated with your PII.
Company may also automatically collect other types of non-Personally Identifiable Information as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is anonymous, and is not associated with your PII, although it may be associated with other pieces of anonymous information about you.
Please see Exhibit 1 for the categories of information we collect.
2) What do we use your information for?
Your Personally Identifiable Information may be used in one of the following ways:
To contact you regarding your account. These communications may include notices regarding changes to our policies, service updates, account management procedures, and customer service transactional messages;
To email you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners; and
To bill your credit card or other specified form of payment, in accordance with the Terms of Use.
Non-Personally Identifiable Information may be used in one of the following ways:
To enable us to generate aggregate data about site traffic, site interaction, user characteristics, preferences, and purchases, in each case as long as such data is sufficiently extracted, modified, or transformed so that it cannot be reverse-engineered or otherwise identified at the individual user-level from inspecting, analyzing, or further processing data;
To customize your experience (your information helps us to better respond to your individual needs);
To show you advertisements most relevant to your demographic characteristics;
To make improvements to the Website and Services; and
To inform potential partners and advertisers about the size and characteristics of our audience.
3) Do we sell or trade any information to other parties?
The Company does not sell or trade your Personally Identifiable Information to outside parties.
4) How secure is your personal information?
The security of our user data is very important to us. We store your information securely using industry-standard encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
5) How long do we retain your information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time in case you decide to re-activate your account. We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion. Further, some information may be retained if it is contained in deleted emails or electronic documents that are archived in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents.
If you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those with whom it was shared.
6) Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. The Company does not currently use cookies, but we have relationships with third-party vendors and partners who assist us with aspects of the Website and the Services, including serving advertisements, understanding Website usage, providing functionalities such as email distribution and content contribution, delivering customer surveys, and the like. These vendors typically use cookies and similar tracking technologies, such as web beacons (also known as clear GIFs, web bugs, or tracking pixels), which are similar in function to cookies, allowing a website to determine when users have reached particular Web pages or performed certain actions.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server of the website that issued the cookie to you.
Depending on your web browser, you may have the ability to accept or decline cookies. Most web browsers default to accept cookies but enable you to configure settings to decline them. For further information about disabling cookies, you can visit allaboutcookies.org. If you choose to decline cookies, you may not be able to sign in or use other features of the Services that depend on cookies.
Company maintains internal logs of usage of the Services. Logs include information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. Company uses logs mainly for internal systems administration and diagnostic purposes and to detect improper use of the site. Logs may also be used to generate aggregate, non-Personally Identifiable Information for advertisers or other third parties. The Company may collect such usage logs even if you do not have the Website open.
Company does not use cookies, similar technologies, or its internal logs to associate your Personally Identifiable Information with data about your use of the site.
If you register for any part of the Services, we may offer you the option to save certain information, such as your username and password, via Local Device Storage (LDS). You can disable LDS on your device or browser; however, doing so may render a portion of the Services to not function properly.
7) How can you access, update, or delete your Personally Identifiable Information?
If you wish to have all information about you that either you or a merchant or points programmer provided have provided to Benji deleted, please contact us at privacy@withbenji.com and we will make reasonable efforts to honor your request in compliance with applicable laws. Anonymous information relating to your past usage of the Services may remain in our archived records.
New types of marketing communications may be added from time to time. You can opt out of receiving future marketing communications by emailing privacy@withbenji.com or by following instructions contained in messages you receive.
Please remember that the merchants and points program providers may provide your data in association with transactions, and therefore, your information may be transmitted after an initial deletion if you participate in a transaction using The Benji group marketplace.
8) What if we make changes to our Privacy Policy?
Because enhancements to the Services we provide may affect the information that we collect and the manner in which we use it, this Privacy Policy may change from time to time. All changes will be incorporated into the written policy and posted here. The date of the most recent revision to the Privacy Policy is indicated at the bottom of this page.
The Company will provide you with the opportunity to accept or reject significant changes to the Privacy Policy during your next sign-on to the Services. If you do not agree to the modifications, your access to the Services may be discontinued
9) How do we comply with state consumer data privacy laws?
Many states in the United States have implemented their own consumer data privacy laws, and we strive to comply with all data privacy laws that apply to our business. State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information that would, for example, require us to do some or all of the following:
Allow you to opt out of personal data processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects;
Allow you to opt-out from the processing and use of Sensitive Data;
Confirm whether we process your personal information;
Correct inaccuracies in your personal information;
Delete certain personal information;
Exercise any of the rights above for your child if the child is below the age of 13 (even if your child’s use of the services violates our Terms of Use or Privacy Policy);
Honor requests made under applicable laws that are made by valid authorized agents on your behalf;
Honor opt-out signals made via application, program, or other process by third parties on your behalf;
Make certain disclosures about our use of your personal information;
Provide your personal information in a common file format;
Provide an itemized list of all third parties with which we have shared your data; and
Provide you with information about the data gathered and the uses of the data if we offer any incentive or loyalty programs to you that require the disclosure of additional data that is not required to offer the services.
The scope of these rights varies by state of residence. To exercise any of these rights, please contact us using the information below or use the official state online request form and send us a copy. We will review your request and either comply or notify you that your request was denied and explain why it was denied. Additionally, to the extent allowed by applicable law, we may contact you to validate your identity and that you made the request; failure to respond to these communications may result in a denial of your request.
If you wish to appeal our decision, you must submit your appeal within 30 days from the date your request was denied.
We will not deny you services, charge you different prices or rates, provide you with a different level of services, or otherwise discriminate against you solely because you exercised your privacy rights.
10) What if you have questions that are not answered here?
If there are any questions regarding this Privacy Policy, you may contact us using the information below:
The Benji Group, Inc.
Attention: Privacy
1178 Broadway, 3rd Floor #1320
New York, NY 1001
Exhibit 1: Data Categories
A. Identifiers.
Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Collected: YES
B. Personal information.
Example: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES
C. Sensitive Information.
Example: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: NO
D. Commercial information.
Example: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES
E. Biometric information.
Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO
F. Internet or other similar network activity.
Example: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected: YES
G. Geolocation data.
Example: Physical location or movements.
Collected: NO
H. Sensory data.
Example: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO
I. Professional or employment-related information.
Example: Current or past job history or performance evaluations.
Collected: NO
J. Non-public education information.
Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO
K. Inferences drawn from other personal information.
Example: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: NO
THE BENJI GROUP, INC. PRIVACY POLICY ADDENDUM
FOR EEA RESIDENTS USING THE SERVICES
PURSUANT TO GDPR
This Addendum applies to you if you are a resident of the European Economic Area (EEA), which is the European Union plus Norway, Iceland and Lichtenstein, and you use our Services. This Addendum prevails over the standard terms of our Privacy Policy at https://withbenji.com/privacy. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Privacy Policy.
In this Policy, we refer to two types of user information: Identified Personal Data and Non-Identified Personal Data.
Identified Personal Data (IPD) refers to any information that can be used to uniquely identify, contact, or locate you. Examples of Identified Personal Data include a name, physical address, e-mail address, telephone number, date of birth, or a credit card number.
The Company collects only the IPD that you voluntarily provide to us (such as when you register to use the Services, set up a profile, or create content) or that a partner shares with us on your behalf with your permission.
Non-Identified Personal Data (NIPD) refers to additional information about yourself that does not, itself, specifically identify you, that you might also be asked for, or choose to provide. However, some information of this kind, such as your geographic location and learning preferences may be required (or merely requested) when you register for the Services and may be associated with your IPD.
The Company may also automatically collect other types of NIPD as you use the Services, including technical information (such as your internet protocol (“IP”) address, mobile device ID, or browser type) and usage information (such as location data, preferred language, the parts of the Services you have visited, which links you have clicked and other information about how you interact with the Services). This information is not associated with your IPD, although it may be associated with other pieces of non-identified information about you.
Both IPD and NIPD are personal data in the meaning of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC General Data Protection Regulation (GDPR).
Who controls your personal data?
We, the Company as defined in the Privacy Policy, control your personal data. You can contact us via contact details provided at our website in the Section “Contact”. Our representative for the purpose of the GDPR is Jon, whom you can contact by going to withbenji.com/contact.
Purposes and basis for processing
Providing your Identified Personal Data is required to allow us to provide you with the Services. Your Identified Personal Data may be used in one of the following ways:
To contact you regarding your account in performance of our contract or to provide pre-contractual information. These communications may include notices regarding changes to our policies, Service updates, account management procedures and customer Service transactional messages.
To bill your appropriate points accounts with various third-party companies as necessary for you to use the Services.
To e-mail you newsletters or tips about how to use the Services, inform you of product updates, or notify you about our own special offers or those of our third-party partners – pursuing our legitimate interest in marketing our Services.
Your Non-Identified Personal Data may be used in one of the following ways pursuing our legitimate interest in marketing and optimization of our Services:
To enable us to generate aggregate data about site traffic and site interaction.
To customize your experience (your information helps us to better respond to your individual needs).
To show you opportunities most relevant to your demographic characteristics.
To make improvements to the Website and Services
To inform potential partners and advertisers about the size and characteristics of our audience
The Company maintains internal logs of usage of the Services. Logs include NIPD information such as IP address, browser type and version, computer processing speed, connection speed, clickstream data, and computer operating system. The Company uses logs mainly for its legitimate interests such as internal systems administration and diagnostic purposes, and to detect improper use of the site.
Logs may also be used by the Company pursuing its legitimate interest to generate aggregate, non-Personally Identified Data. The Company may collect such usage logs even if you do not have the Website open.
Data recipients
We describe the categories of potential recipients of your personal data in our main Privacy Policy in the section titled “How secure is your personal information?” we describe the potential recipients of your personal data.
Due to use of third-party plug-ins, pages or third-party services and integrations (e.g. for authorization or localization purpose) we may disclose information about your browser, activity, localization to other entities in order to fulfill your requests, or to provide services that you have requested.
As for our IT infrastructure and other relevant information about recipients of your personal please refer to the following section.
How secure is your personal information?
The security of our user data is very important to us. We store your information securely in a globally leading cloud services infrastructure provider, using industry-compliant encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
How long do we retain your personal information?
The retention period of collected information depends on the type of information and the reasons why we collect it.
Primary retention. Your account information is retained while your account is active, unless you request us to delete the information or close your account in which case some information may still be retained for a reasonable time up to 180 days post closing in case you decide to re-activate your account.
We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services, in which case we would anonymize and encrypt such information until complete deletion.
Further, some information may be retained if it is contained in deleted emails or electronic documents which are archived by our company in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents. We intend to keep such archives for Five Years from the end of a calendar year they have been created
Please, be advised that if you request us to delete your information or close your account, some of the information you shared through the Services may still be accessible by those users or Merchants with whom you shared it, as since you shared that information with them it has become theirs as well.
In case your information is needed for a specific legal proceeding, we may keep such information as long as the proceeding in question is ongoing.
Your Rights
You have the right to:
request access and copies of your personal data, unless it would adversely affect the rights and freedoms of others
request to have your information rectified if it is inaccurate or incomplete;
request we erase your personal data in certain circumstances;
request restriction of processing of your personal data in certain circumstances;
request to receive your data you have provided us based on your consent or a contract, in a structured, commonly used and machine -readable format or request us to transmit those data to another controller;
to object to processing of your personal data If we are relying on a legitimate interest in case you are in a particular situation or if we are processing your information for direct marketing purposes;
Right to withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place. If you exercise this right, we may keep minimum information about you (for example on a so called “Robinsons list”) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
To exercise your rights please contact us at privacy@withbenji.com. However, please note that we may not be able to provide some or all of the Services without some necessary data collected from you.
Right to lodge a complaint with the data protection authority. If you have a concern about processing your personal data infringes the GDPR, you may lodge a complaint with the data protection authority in the member state of European Union of your habitual residence, place of work or place of the alleged data infringement.
Children’s Personal Data
We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Services, please contact us and we will endeavor to delete that information from our databases.
If you are under the age of 16, you need to provide us with a consent of the holder of parental responsibility over yourself, to allow us to process your personal data.
Do we use cookies or other forms of tracking?
Cookies are small files that a website or one of its service providers transfers to your computer’s storage device via your Web browser (if your browser is configured to permit this) that enable its systems to recognize your browser and store certain information. We use “cookies” to collect information and improve our Services. We may use “persistent cookies” to save your user ID and password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service.
Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server of the website that issued the cookie to you.
We use necessary and functionality cookies (required to perform our Services) and analytics and targeting cookies, when we have your consent to collect and use them.
Categories of cookies.
Necessary cookies. Strictly necessary cookies are strictly necessary to provide you with the Services. The information collected through these cookies is used only for the purpose of providing you with the Services and is never shared with third parties.
You cannot refuse those cookies. You may block or delete them by changing your browser settings, but you may not be able to use Services features, and in some cases the The Benji Group website simply will not perform.
Preferences cookies. Functional cookies allow us to remember the choices you make and provide enhanced, more personal features. Examples include your username, language, region, customizations, and prior purchase history. The information collected through these cookies is used for this purpose only and is never shared with third parties.
Performance & Statistic. We work with third parties who use cookies to collect data that helps us understand how people are using our site. We use this information to identify improvements we can make to the user experience.
Marketing & Targeting. We work with third parties who use cookies to collect information about the pages, links, and other sites that you visit. These cookies are used to deliver advertisements that are more relevant to you and your interests across the internet. This information collected by these cookies will be used to track visits and actions on our site, as well as to deliver reporting and analytics to us and our partners. You can opt out of targeted advertising associated with our Website by clicking opt out of (useful links below), which will block targeted ads on the web browser or device you are on.
The following cookies are used:
Facebook (https://www.facebook.com/policies/cookies/)
Google Maps (https://policies.google.com/technologies/types?hl=en)
Google Analytics (https://policies.google.com/technologies/partner-sites?hl=en)
Twitter (https://help.twitter.com/en/rules-and-policies/twitter-cookies)
Pinterest (https://policy.pinterest.com/en/privacy-policy)
How can I control cookies?
All browser technologies enable you to manage the cookies in the cookie folder of your web browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our website or you can set your preferences with regard to the use of cookies before you begin browsing our website. Please note, as stated above, that deleting or rejecting cookies may adversely affect your user experience of our website.
You can find further information at:
Where can I find more information about cookies?
If you want to learn more about cookies or how to control, disable, or delete them, please visit www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google https://adssettings.google.com/u/0/authenticated?hl=en.
You can also learn more about targeting and retargeting for advertising, and about how to turn this feature off, by visiting www.networkadvertising.org, or in the case of those residing in the EU or UK, by visiting http://www.youronlinechoices.com.
Tracking technologies
Cookies are not the only way to recognize or track visitors to a website. Web beacons (sometimes called “tracking pixels” or “clear gifs”) are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our or taken an action in relation with Services.
How to refuse tracing technologies? In many instances, these technologies are reliant on cookies to function properly. As a result, declining cookies will impair their functioning. Where to look for more information?
You may find more information on the way we process your information at https://withbenji.com/privacy.
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