1. Introduction
This Privacy Policy describes how Czerwonka Educational Consulting, LLC ("CEC," "we," "us," or "our") collects, uses, stores, and protects information about users of the Bar Exam Command Center, accessible at barexamapp.czerwonkalegal.com, together with its companion applications including the Law School Resource Center at lawschoolhub.czerwonkalegal.com and other educational tools we operate (collectively, the "Platform").
CEC is a Delaware limited liability company with a registered address in Delaware. The Platform is operated by Christopher Czerwonka, J.D., a licensed attorney admitted in the State of New York. We provide the Platform at no charge to clients of our practice as a complimentary tool alongside paid live teaching engagements.
The Platform is offered as a beta product. It is in active development, and features, content, and operational practices evolve over time. This Privacy Policy describes our current practices and will be updated as the Platform matures.
This policy formalizes practices that have been individually disclosed to each client at intake through verbal briefings, with contemporaneous notes captured on file. The publication of this consolidated policy supplements, but does not supersede or modify, those individual disclosures.
2. Who This Policy Applies To
This Privacy Policy applies to all users of the Platform, including:
- Active bar examination preparation students engaged with our practice;
- Pre-law readiness program participants;
- Alumni who have completed bar preparation and continue using the Platform's alumni-tier features;
- Visitors to the Platform's marketing and informational pages.
Different sections of this policy describe practices applicable to different categories of users. Where a practice applies only to a specific user category, the relevant section identifies the category.
3. Information We Collect
3.1 Account Information
When you create an account on the Platform, we collect your name and email address. If you sign in using Google, we receive your name, email address, and profile image from Google as part of the authentication process. We do not receive your Google password or access to other Google services.
3.2 Practice Activity Data
As you use the Platform, we collect data about your practice activity, including:
- Your responses to multiple-choice questions, including the question presented, the answer selected, the time taken, and whether the answer was correct;
- Your written submissions to essay (MEE) and performance task (MPT) practice prompts;
- Your responses to MPRE practice questions;
- Computed metrics derived from your practice activity, including ability estimates calculated through Item Response Theory, subtopic mastery indicators, and predicted score ranges;
- Session metadata, including which questions you have seen, your progress through the question bank, and timing information;
- Self-reported data you provide, including your target bar examination jurisdiction, target examination date, and any information you submit through feedback forms or wellness check-in prompts.
Note on examination content. Our Terms of Service prohibit you from submitting actual bar examination content (including MBE questions, MEE prompts, MPT materials, and MPRE questions) to the Platform, including content recalled from memory after sitting for an examination. If we have reason to believe content you have submitted may include actual examination material, we may remove that content from your account and from our systems. We treat any such removal as part of our ordinary content-handling practices and do not separately retain copies of removed content.
3.3 Accommodations Data
If you require disability accommodations for the bar examination, you may configure accommodation flags in your Platform profile. These flags include extended time settings (1.5x, 2x) and pause functionality for timed practice sessions. We treat accommodations data as sensitive and apply the protections described in Section 6 below.
3.4 Alumni Tier Data
If you continue using the Platform after passing the bar examination and join the alumni tier, we may additionally collect:
- Bar examination outcome data (jurisdiction, date, pass/fail status), provided voluntarily by you;
- Testimonials about your experience with the Platform, provided voluntarily and subject to administrative approval before any public display;
- Referral activity, including the number of referrals you have generated through your unique referral link.
3.5 Donation Data
If you contribute to our scholarship fund, we use Square as our payment processor. We do not receive or store your full payment card details. Square may share with us your name, email address, and contribution amount for accounting and acknowledgment purposes. Square's own privacy practices are governed by Square's privacy policy.
3.6 Technical Data
When you access the Platform, our systems and our service providers automatically collect technical information including your IP address, browser type, device type, operating system, and the dates and times of your visits. This information is used to operate the Platform, secure it against abuse, and improve performance.
3.7 Information We Do Not Collect
We do not collect, and the Platform does not require, the following categories of information:
- Government-issued identification numbers (Social Security number, driver's license number, passport number);
- Financial account information beyond what is processed by Square for scholarship donations;
- Biometric data;
- Location data beyond the approximate location inferred from your IP address;
- Health information, except to the limited extent that disability accommodation flags described in Section 3.3 may indicate the existence of an accommodation need.
4. How We Use Your Information
We use the information described above for the following purposes:
4.1 Providing the Platform
Operating the Platform, including authenticating your account, serving practice questions calibrated to your ability level, recording your responses, computing your progress metrics, and presenting your practice history.
4.2 Personalized Practice
The Platform's adaptive practice engine uses your prior responses and computed ability estimates to select practice questions intended to maximize learning. This personalization is intrinsic to the Platform's pedagogical approach.
4.3 Instructor Visibility
As your instructor, Christopher Czerwonka has access to your practice activity, including your responses, written submissions, and computed metrics. This visibility supports the live teaching engagements that complement your use of the Platform.
4.4 AI-Assisted Feedback Drafting
For written submissions to essay (MEE) and performance task (MPT) practice prompts, we use Anthropic's API as an AI processor to draft initial feedback on your work. The Platform sends the text of your submission, the prompt, and relevant grading guidance to Anthropic, which returns drafted feedback.
AI-drafted feedback may be made visible to you on the Platform soon after submission, before instructor review. Any AI-drafted feedback that has not yet been reviewed by Christopher Czerwonka, J.D., is clearly marked as preliminary and is not the final feedback for your submission. Preliminary feedback is intended to give you something to work with quickly; it is not a substitute for instructor review.
Christopher reads every submission personally. After reviewing the AI-drafted feedback alongside your submission, Christopher will provide his own personal feedback, which may confirm, modify, expand, or replace the preliminary AI-drafted feedback in whole or in part. Christopher's personal feedback is the authoritative feedback for your submission.
Anthropic processes the data we send under its standard API terms. Anthropic does not use API inputs to train its models by default, and we have not opted into any program that would change this. Anthropic retains API inputs and outputs only as needed to provide the service and maintain abuse and safety detection. We have not configured the Platform to share your submissions with any other AI provider.
4.5 Communications
We may use your email address to send you Platform-related communications, including:
- Practice reminders, deadline notifications, and progress summaries;
- Updates about new Platform features or content;
- Notices about changes to this Privacy Policy or our Terms of Service;
- Communications about your live teaching engagement, where applicable.
You may opt out of non-essential communications at any time. Communications related to the security of your account or material changes to our terms are not subject to opt-out.
4.6 Service Improvement
We use aggregated and de-identified practice activity data to evaluate Platform features, identify content gaps, and improve the question bank, the adaptive engine, and the user experience. Aggregated and de-identified data does not personally identify any individual user.
4.7 Legal and Safety Purposes
We may use information as necessary to comply with applicable law, respond to lawful requests from authorities, enforce our Terms of Service, protect the rights and safety of users and others, and investigate potential violations of our policies.
5. How We Share Your Information
We do not sell your personal information. We do not share your personal information with advertisers or marketing partners. We share information only as described in this section.
5.1 Service Providers
We share information with third-party service providers that help us operate the Platform. Our current service providers are:
- Google LLC (Firebase services), which provides authentication, database hosting, application hosting, and related infrastructure;
- Anthropic PBC, which provides the AI processing described in Section 4.4;
- Square, Inc., which processes scholarship fund donations as described in Section 3.5;
- Email service providers used to send communications described in Section 4.5.
Each service provider receives only the information necessary to perform its function and is bound by its own privacy obligations to handle that information appropriately.
5.2 Legal Requirements
We may disclose your information if required to do so by law, by valid legal process, or by a government request that we determine in good faith requires disclosure. Where legally permitted, we will notify you of such requests.
5.3 Business Transfers
If CEC undergoes a merger, acquisition, or sale of assets, your information may be transferred to a successor entity. Any such transfer would be subject to this Privacy Policy or to a successor policy that provides at least equivalent protections, and you would be notified before any change took effect.
5.4 With Your Consent
We may share your information for any other purpose with your explicit consent.
Use of Outstanding Submissions as Exemplars. From time to time, Christopher Czerwonka may identify a particularly excellent written submission (such as an MEE or MPT response) that, in de-identified form, could serve as an instructive exemplar for other students. If Christopher wishes to use your work in this way, he will contact you directly to request your consent. Your consent is entirely voluntary, and you may decline without any adverse consequence to your standing on the Platform, your relationship with Christopher, your access to live teaching engagements, or any other aspect of your engagement with CEC. If you consent, your submission will be de-identified before any use as an exemplar, including removal of your name and any other personally identifying information. You may withdraw your consent at any time by contacting Christopher at chris@czerwonkalegal.com, and the exemplar will be removed from any future use, although CEC cannot recall copies that have already been distributed in any form.
6. Data Security and Sensitive Data Handling
6.1 General Security Practices
We use commercially reasonable administrative, technical, and physical safeguards to protect your information against unauthorized access, alteration, disclosure, and destruction. Our infrastructure runs on Google Cloud and Firebase services, which provide encryption in transit and at rest, access controls, and operational security measures.
No method of transmission over the internet or electronic storage is fully secure. We cannot guarantee absolute security and you should take reasonable steps to protect your account, including using a strong, unique password and signing out of shared devices.
6.2 Accommodations Data
Disability accommodation flags are stored in your Platform profile and are protected as sensitive data. Specifically:
- Accommodation status is implemented as a hard technical gate in our database, not as a soft user-interface preference. Accommodation features are not available unless explicitly configured in the user profile.
- Accommodation status is never delegated to the AI processing pipeline described in Section 4.4. The AI does not receive, infer, or act on accommodation data.
- Accommodation features are never surfaced or hinted at to users who do not have accommodations configured.
- Accommodation data is accessible only to the user and to Christopher Czerwonka in his administrative capacity.
These protections reflect our broader accessibility commitment, including the Platform's audit against the Web Content Accessibility Guidelines (WCAG) 2.2 success criteria, including AAA criteria where technically feasible.
6.3 Account Compromise
If you believe your account has been compromised or accessed without your authorization, contact us immediately at chris@czerwonkalegal.com. We will work with you to secure your account.
6.4 Notification of Data Incidents
In the event of a data incident affecting your personal information, we will notify you in accordance with applicable law. Where notification is not legally required but the incident may be material to you, we will use reasonable judgment to notify affected users.
7. Your Choices and Rights
7.1 Access and Correction
You may access and update your account information by signing in to the Platform and editing your profile. For information that is not editable through the Platform interface, you may request access or correction by contacting us at chris@czerwonkalegal.com.
7.2 Deletion
You may request deletion of your account and associated personal information by contacting us at chris@czerwonkalegal.com. Upon deletion, we will remove your personal information from active systems within a reasonable period and from backups in accordance with our backup retention schedule. Some information may be retained as required by law or for legitimate business purposes (for example, scholarship donation records may be retained for tax and accounting purposes).
Deletion of your account will end your access to the Platform and to any practice progress, written submissions, and other content associated with your account.
7.3 Communications Preferences
You may opt out of non-essential communications by following the opt-out instructions in any such communication, by adjusting communication preferences in your Platform profile where available, or by contacting us at chris@czerwonkalegal.com.
7.4 Jurisdiction-Specific Rights
If you are a resident of a jurisdiction with privacy laws that grant additional rights (for example, the California Consumer Privacy Act, the Virginia Consumer Data Protection Act, or the European Union General Data Protection Regulation), you may have additional rights including the right to know what personal information we have collected, the right to data portability, and the right to non-discrimination for exercising your rights. To exercise these rights, contact us at chris@czerwonkalegal.com.
8. Data Retention
We retain your information for as long as your account is active and for a reasonable period thereafter to provide the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements.
Specific retention practices include:
- Account information: retained for the duration of your account and for up to 24 months after account deletion, except where shorter retention is required by law.
- Practice activity data: retained for the duration of your account. After account deletion, this data is retained in aggregated and de-identified form for service improvement purposes.
- Written submissions (MEE/MPT/essay): retained for the duration of your account and deleted within 60 days of account deletion.
- Communications: retained for up to 36 months for operational and legal purposes.
- Scholarship donation records: retained for at least 7 years for tax and accounting purposes.
9. Children's Privacy
The Platform is intended for users who are at least 18 years old. The bar examination is administered to candidates who have completed law school, and our user base consists almost entirely of adults engaged in or preparing for legal study. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, contact us at chris@czerwonkalegal.com and we will take appropriate action.
10. International Data Transfers
CEC operates in the United States. Our service providers, including Google and Anthropic, may store and process information in the United States and other countries where they maintain operations. If you access the Platform from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States and other countries.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify users by email and by posting the updated policy on the Platform with a revised effective date. For users with active accounts, continued use of the Platform after the effective date of an updated policy constitutes acceptance of the changes.
Material changes that affect how we use your existing data will not take effect for users with existing accounts until those users have had at least 30 days to review the changes and either accept them or close their accounts.
12. Contact Information
Questions about this Privacy Policy or our privacy practices may be directed to:
Christopher Czerwonka, J.D.
Czerwonka Educational Consulting, LLC
chris@czerwonkalegal.com
2093 Philadelphia Pike, Suite #4231
Claymont, DE 19703