Privacy Policy

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. We do not create voiceprints, and we do not use your voice or other personal characteristics to identify you. Where the optional voice features described in Section 4.4 are offered and you choose to use them, your speech is transcribed to text by your browser's built-in speech recognition (see Section 4.4); we receive only the resulting text, never the audio, and your voice is not used for biometric identification;
• 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 and Simulation Features

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 written essay or performance-task submissions with any AI provider other than Anthropic.

Interactive simulations. The Platform also includes interactive skill simulations, including the "Sustained" courtroom-objection simulator and its Open Court mode. Participation in these features is optional, and they use AI processors in the ways described below.

In Open Court, you may compose and submit a free-form legal argument in response to a courtroom prompt. When you do, the Platform sends the text of your argument, together with the relevant authored scenario context and grading guidance, to Anthropic, which returns an evaluation and a scripted judicial ruling. This evaluation is a teaching aid and, like AI-drafted essay feedback, is not a substitute for instructor review.

At the end of a simulation, the Platform may offer a spoken debrief that reviews your performance. To prepare it, the Platform sends Anthropic a structured record of the session built from the authored scenario content and coded summaries of the choices you made—for example, whether you objected and on what ground. For this purpose the Platform does not send Anthropic your name, your account identifier, or any free-form text. Anthropic returns the text of the debrief.

To voice these features, the Platform sends the resulting text—the debrief, and the judicial ruling in Open Court—to ElevenLabs, Inc., which synthesizes an audio version in an instructor's voice and returns the audio to your browser. ElevenLabs receives only the generated text to be spoken and the selected voice; it does not receive your identity, and it never receives any free-form text you compose yourself. Voicing is provided on a best-effort basis, and these features remain fully usable in text alone if synthesis is unavailable.

Voice input (optional). Where a simulation offers a spoken-response mode, you may choose to speak your response aloud instead of typing it. This feature relies on your web browser's built-in speech-recognition capability, which the Platform turns on only with your permission and only while you are actively using a voice feature. Depending on the browser you use, your browser may transcribe your speech on your device or may transmit the audio to your browser provider's own speech-recognition service (for example, Google for Chrome or Apple for Safari) in order to produce the transcript; that processing is performed by your browser and is governed by your browser provider's privacy terms, not ours. CEC does not receive, store, or have access to the audio of your voice—we receive only the resulting text, which is then handled exactly like text you type (for example, an argument you dictate in Open Court is sent to Anthropic just as a typed argument would be, as described above). Your voice is not used to create a voiceprint or any other biometric identifier. Voice input is never required—typing is always available—and you may use the simulator fully without enabling it.

Each AI provider processes the data we send under its API terms. We have affirmatively opted out of model training with Anthropic and with ElevenLabs, so neither uses our inputs or outputs to train its models. Each provider retains inputs and outputs only as needed to provide its service and to maintain abuse and safety detection.

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.

4.8 Research and Scholarship (Optional, Consent-Based)

With your consent, we may use your practice activity data, in anonymized or pseudonymous form, for research and scholarship. This includes analyzing the performance and characteristics of practice questions, studying how candidates learn and prepare for licensing examinations, evaluating assessment design, and publishing findings in forms such as scholarly articles, white papers, books, and professional presentations.

Research use is entirely optional and operates only on an opt-in basis. We will not use your data for the research purposes described in this section unless you have affirmatively consented. You may decline, and you may withdraw a previously given consent at any time, as described below. Your decision to consent, decline, or withdraw has no effect on your access to or use of the Platform, your practice tools, your feedback, your live teaching engagements, or any other aspect of your relationship with CEC.

For purposes of this section, "anonymized" data is data from which identifying information has been removed in a manner intended to be irreversible, so that it can no longer reasonably be linked back to you. "Pseudonymous" data is data in which your name and other direct identifiers have been replaced with a key; the key is held separately and is not included in any research dataset, so the research dataset itself does not identify you.

Research datasets exclude direct identifiers and also exclude sensitive data. In particular, disability accommodation status described in Sections 3.3 and 6.2 is never included in any research dataset and is never provided to any AI service provider for any purpose. The protections in Section 6.2 remain in full force and are not modified by this section.

Where research analysis involves Anthropic, the AI analysis provider identified in Section 5.1, that provider operates only on anonymized or pseudonymous data that excludes the identifiers and sensitive data described above.

Withdrawing consent takes effect going forward from the time of withdrawal. Because anonymized and aggregated results cannot be traced back to you, results that have already been incorporated into completed analyses or into published or presented work cannot be recalled. You may record or change your research decision at any time using the controls in your Platform profile, or by contacting us at chris@czerwonkalegal.com.

4.9 Invitation-Only Feature Previews

From time to time, certain account holders—generally those who use the Platform heavily and have a consistent history of providing feedback on their experience—may be invited to participate in invitation-only previews of features that are not yet ready for general release. In that event, an invitation modal setting out the terms and conditions of participation, and the privacy implications thereof, will be surfaced within the Platform. You will be prompted to Agree or Disagree with the terms of the preview. The privacy-facing implications described in any such modal are incorporated by reference into this Privacy Policy. Participation in any preview is entirely voluntary, and declining has no effect on your access to or use of the generally available Platform.

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;
• ElevenLabs, Inc., which provides AI voice synthesis for the spoken simulation features described in Section 4.4 (the simulation debrief and the spoken rulings in Open Court);
• Square, Inc., which processes scholarship fund donations as described in Section 3.5;
• Backblaze, Inc., which provides encrypted, off-site backup storage for disaster recovery as described in Sections 6.1 and 7.2;
• 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. For disaster recovery, we also maintain encrypted, off-site backups with an independent storage provider (Backblaze); these backups are encrypted by us before they leave our infrastructure, so the backup storage provider cannot read their contents.

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 described in Section 4.4. No AI processor—including Anthropic and ElevenLabs—receives, infers, or acts 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. Our off-site backups are maintained on a rolling cycle, and some backups are stored in an immutable form for a defined retention window; for that reason, residual copies of deleted information may persist in backups for up to 90 days after removal from active systems before they expire or are overwritten, and such backups are used only for disaster recovery, never to restore a deleted account. 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 from active systems within 60 days of account deletion; residual copies in off-site backups are purged on the rolling backup cycle described in Section 7.2.
• 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, Anthropic, ElevenLabs, and Backblaze, 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: