The fine print,
in plain English.

Effective 10 October 2026Last updated 10 October 2026Version 1.6

Summary, in plain language

This is not a substitute for the full agreement below, and the full text controls. But you deserve to know what you are agreeing to before reading the whole thing.

• bcs helps you prepare university applications. It does not apply for you and it does not get you in. Nobody can guarantee admission, and we do not.
• Capy makes mistakes. Everything he produces is a draft or a suggestion. You must check it before you use it.
• Your work is yours. You own your essays and everything you create. We do not train AI models on them.
• You are responsible for following your target institutions' rules on AI. They differ, they change, and breaking them can void an application. Section 6 explains this properly, and it is the most important section in this document.
• If you are under 18, a parent or guardian must agree to these terms with you.
• bcs is free, with immediate access. When you create a bcs account for yourself, or join through an individual invitation, you can use bcs right away. There is no trial period, you do not need a payment method, and nothing is charged automatically. Section 12.4 explains it.
• If you bought bcs Pro before bcs became free, it runs to its end: only the monthly plan renews, except a recurring cycle. The monthly plan renews every month and you can cancel it any time. The upfront cycle (Ciclo à vista) is one payment for 5 months of access and does not renew. In Brazil, where offered, you can also pay one month or the upfront cycle by Pix: a single payment that never renews. The cycle in 5 installments (Ciclo em 5x) is a commitment to 5 monthly payments: it does not renew and cannot be cancelled once the refund window has passed. A recurring cycle is a cycle that checkout sold you as a subscription renewing every 5 months, whenever you bought it: it renews until you cancel, and you can cancel it any time. We may end a bcs Pro plan early, with a refund of what you have not used. Section 12.1 sets out each plan.
• We offer a 14-day full refund of your first purchase, on any plan, which is more generous than the law requires in every country we serve.
• We email you about bcs. Creating an account means you will receive marketing email from us about bcs: new features, announcements and events we take part in. It is never pressure to buy anything. You can unsubscribe at any time, and unsubscribing does not affect your account. Section 4 explains this.
• We do not use forced arbitration and we do not make you waive class actions. You keep your right to go to court.
• Where you live changes your legal rights. Brazilian, Colombian and Indian consumer law gives you protections that we cannot and do not try to waive.

Table of contents

1. Agreement to these terms
2. Definitions
3. Eligibility, age and parental consent
4. Your account
5. What bcs provides
6. Academic integrity and institutional AI rules
7. No guarantee of outcomes, and what our published figures mean
8. AI-generated output
9. Your content, and the licence you give us
10. Our intellectual property
11. Acceptable use
12. Plans, pricing, billing and renewal
13. Cancellation, refunds and your right of withdrawal
14. School, district and institutional licences
15. Third-party services and integrations
16. Suspension, termination and data export
17. Disclaimers
18. Limitation of liability
19. Indemnification
20. Dispute resolution, by country
21. Governing law and venue
22. Intellectual property complaints
23. Changes to these terms
24. General provisions
25. How to contact us

1. Agreement to these terms

These Terms of Service form a binding contract between you and:

bcs – BRIGHT CITIZEN SCHOLARS, INC. A Delaware corporation, Delaware File Number 10377748, incorporated 23 October 2025 EIN 61-2302529 Principal address: 6 Mass Row 2992, Hanover, NH 03755, USA Registered office: 131 Continental Dr, Suite 305, Newark, Delaware 19713, County of New Castle, USA Registered agent: Legalinc Corporate Services Inc.

This is your counterparty wherever you are in the world, including in Brazil.

bcs also operates a Brazilian entity, BCS INC. INOVA SIMPLES (I.S.), CNPJ nº 68.475.111/0001-98, Rua Aimorés nº 162, Bairro Rio Vermelho, Salvador, Bahia, CEP 41940-080, Brasil, which carries out operations in Brazil and serves as our local point of contact. In these Terms, "bcs", "we", "us" and "our" mean the Delaware entity together with its affiliates.

Contracting through a US entity does not reduce your rights. If you are a consumer in Brazil, Colombia, India, the EEA or the UK, the mandatory consumer protection and data protection law of your country applies to this contract in full, and sections 18.5 and 20 give effect to that.

They govern your use of bcscholars.com and its subdomains, the bcs applications, Capy, every bcs module, and any service we provide (together, the "Service").

You accept these Terms by creating an account, joining the waitlist, subscribing to a paid plan, accessing the Service under an institutional licence, or otherwise using the Service. If you do not accept them, do not use the Service.

Our [Privacy Policy](https://bcscholars.com/en/privacy/) is incorporated into these Terms by reference. Where you access bcs under an institutional licence, the institution's agreement with us and its Data Processing Addendum also apply, and they prevail over these Terms in the event of a conflict as to that institution's data.

Language. These Terms are published in English, and the English text governs. Where the mandatory consumer law of your country of residence requires that contract terms be provided in another language, that requirement applies regardless of this clause and is not waived by your acceptance of these Terms.

2. Definitions

3. Eligibility, age and parental consent

3.1 Minimum age

You must be at least 16 years old to use the Service.

3.2 Users under 18

If you are under 18, you may use the Service only with the involvement and agreement of a parent or legal guardian.

• A parent or legal guardian must read these Terms, agree to them on your behalf, and provide verifiable consent to the processing of your personal data as described in the Privacy Policy.
• Where you access the Service through an Institution, the Institution is responsible for obtaining the consents its own law requires, and confirms to us that it has done so.
• A parent or guardian who agrees to these Terms on behalf of a minor accepts responsibility for the minor's use of the Service, including payment obligations, and for supervising that use.
• India: the Digital Personal Data Protection Act, 2023 treats everyone under 18 as a child, and verifiable parental consent is mandatory.
• Brazil: consent is obtained under LGPD Art. 14 § 1 and in the best interest of the child or adolescent.
• Colombia: the legal representative authorizes, after the minor's own opinion has been heard, per Decreto 1377 Art. 12.
• United States: we do not create accounts for users under 16, so COPPA does not apply to our processing.

3.3 Capacity and legality

You represent that you have the legal capacity to enter this agreement, or that a parent or guardian has done so on your behalf, and that you are not barred from using the Service under the law of your country or under applicable sanctions and export control laws.

3.4 One account

You may hold one personal account. You may not create an account using a false identity, on behalf of someone else without authority, or after we have terminated a previous account of yours for cause.

4. Your account

• Provide accurate, current and complete registration information, and keep it up to date.
• Keep your credentials confidential. Do not share your account.
• Enable multi-factor authentication where offered.
• You are responsible for activity under your account, except activity resulting from our own failure to secure the Service.
• Tell us immediately at contact@bcscholars.com if you suspect unauthorized access.

You may sign in with Google or with your school's single sign-on. Your relationship with that provider is governed by their terms, and you are responsible for what your account there shares with us.

Emails from us. When you create an individual account, you agree to receive marketing email from bcs about the Service: new features, announcements, events we take part in, and content that helps with your applications. These emails do not pressure you to buy anything. This applies to students under 18 as well. There is no separate box to tick for this. You can unsubscribe at any time from the link in any marketing email, or by writing to contact@bcscholars.com. Unsubscribing does not affect your account or the service messages the Service depends on. Section 19 of the Privacy Policy explains how we handle this.

5. What bcs provides

bcs is a college counseling platform. Depending on your plan and licence, the Service includes:

• Dashboard. Deadlines, priority alerts, progress tracking, daily nudges.
• Roadmap. A sequenced plan for your application cycle.
• Essay Lab. Brainstorming, structure, drafting support, revision and feedback on personal statements and supplemental essays.
• EC & Honors. Activity and honors logging, hours analysis, major-alignment scoring, gap analysis and description refinement.
• Mapping. A database of programs, competitions and scholarships matched to your profile.
• School List. College list building with reach, target and safety classification.
• Student Profile. A structured applicant profile built from your inputs.
• Universities Hub. Institutional research and comparison.
• Recommendation Hub (bcs Ultra). Recommender briefing, letter tracking and deadline monitoring.
• WhatsApp check-ins (opt-in). Workflow reminders delivered over WhatsApp.
• Capy, present across every module.

What bcs is not. bcs is not a licensed educational agency, an admissions consultancy engaged by any Target Institution, a financial advisor, an immigration advisor, or a legal advisor. bcs is not affiliated with, endorsed by, or acting on behalf of the Common Application, the Coalition Application, UCAS, any university or college, any testing organization, or any scholarship provider. We are not involved in any admissions or aid decision.

Changes to the Service. We may add, modify, suspend or discontinue features. Where a change materially reduces the core functionality of a paid plan, we will give you at least 30 days' notice and, if you do not accept it, a pro-rata refund of the unused portion of your subscription or cycle, with no further installments due.

Availability. We aim for high availability but do not guarantee uninterrupted access. We may perform maintenance, and we will give advance notice of planned downtime where practical.

6. Academic integrity and institutional AI rules

Read this section carefully. It is the one most likely to affect your application.

6.1 The rules are not ours to set

Every Target Institution sets its own policy on the use of AI in applications. Those policies vary widely, they are inconsistent between institutions, and they change from cycle to cycle. Some permit AI for brainstorming and feedback but not for drafting. Some prohibit AI in the personal statement specifically. Some require disclosure. Some prohibit it entirely. Application platforms including the Common Application impose their own rules and require you to affirm that the work you submit is your own.

You are solely responsible for knowing and following the rules of every institution, platform, scholarship and competition you apply to. bcs does not know those rules for you, cannot keep track of every institution's current position, and does not warrant that any particular use of the Service is permitted by any particular institution.

6.2 What bcs does, stated honestly

We will not pretend otherwise: Capy drafts and edits. He can produce essay drafts, rewrite activity descriptions, suggest angles and structure, and revise your text. That is a real capability and it is why the product saves time.

That capability creates a real obligation on you.

6.3 Your obligations

By using the Service you agree that:

• The work you submit must be your own. Output is raw material. You must read it, judge it, rewrite it in your own voice, and take ownership of every word before it goes anywhere.
• You will not submit Output verbatim as if it were your own unaided work where the receiving institution prohibits that.
• You will not use the Service to fabricate an activity, an honor, an award, a role, a research project, a publication, a test score, a transcript entry, a financial circumstance, or any other fact about yourself.
• You will not use the Service to impersonate another person, or to prepare an application on behalf of someone else without their knowledge and authority.
• You will not use the Service to draft or forge a letter of recommendation, or any part of one, that will be presented as another person's work. The Recommendation Hub exists to brief and track recommenders, not to write for them.
• You will disclose your use of AI assistance where an institution requires disclosure.
• Where you are a student at an Institution, you will follow that Institution's own academic integrity policy.

6.4 Consequences

Misrepresentation in an application can result in rescinded offers, revoked admission, expulsion, revocation of a degree, or referral to a national admissions authority. bcs bears no responsibility for any consequence arising from your decision to submit AI-assisted content, from your failure to comply with an institution's rules, or from any inaccuracy in what you represent about yourself.

We may suspend or terminate any account we reasonably believe is being used to fabricate credentials, forge documents, or submit work in violation of an institution's stated policy.

7. No guarantee of outcomes, and what our published figures mean

7.1 No guarantee

Using bcs does not guarantee admission to any institution, an offer, a scholarship, financial aid, a visa, a place in any program, or any other outcome. Admissions, aid and enrolment decisions are made entirely by the institutions concerned, on criteria we do not control and are not privy to. We are not involved in any such decision.

7.2 Our published statistics

We publish figures on our website, including time saved across an application cycle and student satisfaction. Those figures are estimates and aggregate survey results derived from typical bcs usage across our student base, presented for general information. They describe past aggregate experience, not a promise to you.

• The time-saving figures are estimates of hours across a full application cycle based on typical bcs student usage, and your own experience will differ depending on your circumstances, your starting point and how you use the Service.
• Satisfaction figures reflect responses from surveyed students at a point in time.
• Nothing in our marketing constitutes a warranty of any specific result for you.

7.3 Financial aid

Financial aid figures Capy produces are estimates, derived from public institutional data and published aid policies. bcs does not collect your family's financial information and cannot calculate your actual eligibility. Real aid depends on institutional methodology, government programs, verification and family circumstances we do not see.

bcs is not a financial advisor and does not provide financial, tax, legal or immigration advice. Confirm every figure with the institution's own financial aid office before relying on it.

8. AI-generated output

• Capy's Output may be inaccurate, incomplete, outdated, biased, or entirely fabricated, including deadlines, requirements, statistics, program details and citations.
• Output is not unique to you. Similar inputs may produce similar Output for other users, and we do not warrant that Output is original or protectable by intellectual property rights.
• You must independently verify any factual claim, deadline, requirement or figure before you rely on it. Institutional websites are the authoritative source, not Capy.
• Output does not constitute professional advice of any kind.
• You are responsible for how you use Output. We provide it as a draft and a suggestion, and the decision to use it is yours.

We use commercially reasonable efforts to make Capy accurate and safe, but we do not warrant accuracy, and section 17 applies.

9. Your content, and the licence you give us

9.1 You own your work

You retain all ownership of Your Content. Your essays, drafts, activity descriptions, transcripts and everything else you create or upload remain yours. bcs claims no ownership interest in Your Content or in your account.

9.2 The licence you grant us

You grant bcs a limited, non-exclusive, worldwide, royalty-free licence to host, store, copy, transmit, display, adapt and process Your Content solely for the purpose of operating and providing the Service to you, including transmitting it to the AI model provider listed in our Privacy Policy so Capy can respond.

This licence is deliberately narrow. To be explicit about its limits:

• It is not perpetual and not irrevocable. It ends when you delete the content or close your account, subject only to backup cycles and legal retention obligations set out in the Privacy Policy.
• It is not sublicensable except to the subprocessors we publish, and only for the purposes stated.
• It does not permit us to train generative AI models on Your Content.
• It does not permit us to use Your Content for marketing, promotion, testimonials, case studies or examples without your separate, specific, written permission.
• It does not permit us to publish Your Content, make it available to other users, or transfer it to any Target Institution unless you specifically direct us to.
• It does not extend to selling, licensing or transferring Your Content to any third party for value. We do not do this. Ever.

9.3 Your warranties about Your Content

You represent that you own Your Content or have the rights necessary to submit it, that it does not infringe anyone's rights, and that you have permission to include information about any third party you mention. Do not upload another person's transcript, essay, recommendation letter or personal data without their permission.

9.4 Feedback

If you send us suggestions or feedback about the product, we may use them without obligation or compensation. This applies to product ideas only, not to Your Content.

9.5 Storage is not a backup service

We take reasonable measures to store Your Content reliably, but the Service is not a backup or archival service. Keep your own copies of anything important. Export is described in section 16.5.

10. Our intellectual property

bcs owns the Service, including its software, models and model configurations, the Capy persona and name, our admissions knowledge base, scoring methodologies, the Mapping database structure and curation, our workflow design, documentation, trademarks, logos and visual identity.

We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Service for your own personal, non-commercial application preparation, or, for Institutional Users, for the educational purposes the Institution's licence permits.

You may not: copy, modify, distribute, sell, licence, rent or lease the Service; reverse engineer, decompile or attempt to derive our models, prompts, system instructions or scoring logic; scrape, crawl or bulk-extract data from the Service; use the Service or its Output to build, train, evaluate or improve a competing product or model; remove proprietary notices; or use our trademarks without written permission.

11. Acceptable use

You will not:

• break any applicable law or regulation;
• fabricate credentials, forge documents, or misrepresent yourself in any application, in violation of section 6;
• upload malware, or interfere with, overload, probe or attack the Service or its infrastructure;
• attempt to circumvent security controls, access another user's account or data, or bypass usage limits;
• use automated tools to access the Service except as we expressly permit;
• attempt to extract our system prompts, model weights, or proprietary instructions, including through prompt injection or jailbreaking;
• resell, sublicense or commercially exploit access to the Service, including operating a consulting practice on a single personal account. bcs is licensed to individual students and to institutions only. There is no independent-counselor or reseller plan.
• upload content that is unlawful, harassing, defamatory, obscene, hateful, or that sexualizes a minor;
• upload another person's sensitive personal data without authority;
• use the Service to harass, deceive or harm anyone; or
• use the Service in a way that could damage the reputation or lawful operation of bcs or an Institution.

We may investigate suspected violations and take proportionate action, including warning, feature restriction, suspension or termination.

12. Plans, pricing, billing and renewal

12.1 Plans

bcs Pro is no longer sold. If you bought it before bcs became free, you hold one of these three plans; this is how each is paid and whether it renews:

Missed installments. If an installment of the Cycle in 5 installments fails, Stripe retries the charge. If it stays unpaid, we suspend access to the paid features until it is paid. The remaining installments of the commitment stay due, and we will contact you about paying them.

Recurring cycle. Where checkout sells the cycle as a subscription renewing every 5 months, rather than as the one-time upfront cycle, what you buy is a recurring cycle, whether you bought it before or after these Terms took effect. A recurring cycle is paid by card, renews every 5 months until you cancel, and keeps the renewal and cancellation terms shown at that checkout. The commitments in section 12.3 apply to it, and you can cancel it any time in Account Settings (section 13.1). What these Terms say about the upfront cycle not renewing does not apply to a recurring cycle.

Ending a bcs Pro plan early. Because bcs is now free, we may stop the renewal of a bcs Pro plan, or end the plan before its term is over. If we stop the renewal, your plan runs to the end of the period you already paid for and you are not charged again. If we end the plan before that, we refund the unused portion of what you paid and no further installments are due. Either way, you keep your access to bcs at no charge.

12.2 Payment

• Card payments are processed by Stripe, Inc. By subscribing you authorize bcs and Stripe to charge your payment method for all amounts due. Stripe's terms are at https://stripe.com/legal and its privacy policy at https://stripe.com/privacy.
• Payment methods. The monthly subscription, a recurring cycle and the Cycle in 5 installments are paid by card. The upfront cycle is paid by card or, in Brazil and where offered, by Pix. In Brazil and where offered, one month can also be paid by Pix. Whichever way you pay, a one-time purchase gives its months of access from payment confirmation (or from the end of the one-time access you already hold) and does not renew. You pay exactly the price shown.
• Pix. Pix payments are processed by Mercado Pago. The Pix code is generated inside bcs and stays valid for the time shown on screen; if it is not paid by then, nothing is charged and you can generate another. Access starts when Mercado Pago confirms the payment. bcs does not ask for your CPF to generate a Pix. Mercado Pago's terms and privacy notice are at https://www.mercadopago.com.br/ajuda/termos-e-politicas_194.
• bcs charges in two currencies. Visitors from Brazil are billed in Brazilian reais (BRL) and everyone else in US dollars (USD). Which one applies follows the country your connection comes from, as located by our hosting provider from your IP address. The price shown to you at checkout is the price you pay for that billing period.
• Currency and conversion. Where your card is denominated in a different currency from the one you are billed in, your card issuer sets the exchange rate and may add a foreign transaction fee. That fee is charged by your bank, not by bcs, and we have no visibility into it or control over it.
• Taxes. The price shown at checkout includes all applicable taxes. Depending on where you are, that may include Brazilian ISS, Indian GST, Colombian IVA, US state sales tax or local equivalents. You will not be charged more than the displayed amount by bcs.
• You must keep billing information current. If a payment fails, we may retry, suspend the paid features, or terminate the subscription after notice. For the Cycle in 5 installments, section 12.1 also applies.

12.3 Automatic renewal

Only the monthly plan and a recurring cycle renew automatically. The monthly plan renews every month at the then-current price until you cancel. A recurring cycle renews every 5 months until you cancel (section 12.1).

Renewal does not apply to the upfront cycle, by card or Pix (charged once, for 5 months), to a month paid by Pix (charged once, for 1 month), or to the Cycle in 5 installments (5 charges, ending after the fifth). None of them is ever charged again on its own; when it ends, you choose whether to buy another plan. The commitments below apply to the monthly plan and to a recurring cycle.

We commit to the following, which meets or exceeds the strictest applicable auto-renewal law:

• Before you subscribe, we present the renewal terms, the amount, the frequency and the cancellation method clearly and near the purchase button.
• We send a renewal reminder by email at least 7 days before each renewal, stating the amount and the date.
• We notify you at least 30 days before any price increase takes effect, and you may cancel before it applies.
• Cancellation is available online, self-serve, in your account settings, in the same number of steps it took to subscribe. No phone call, no email required, no retention gauntlet.

12.4 Free access

bcs is free. When you create a bcs account for yourself, or join through an individual invitation, you have immediate access. There is no trial period, and your access does not end after a set number of days. Accounts under an Institution's licence are covered by section 14 instead.

• No payment method is required. We do not ask for a card or any other payment method to create an account or use bcs.
• Nothing is charged automatically. Using bcs never turns into a paid subscription on its own.
• Capy has a monthly allowance. Free access includes an allowance of AI use for each account, renewed every calendar month. If you reach it, Capy pauses until the next month. Nothing is charged, and the rest of bcs keeps working.
• Paid plans are optional. If we offer paid plans or features in the future, you are charged only if you choose one, under the price and terms shown before you buy, and sections 12.1 to 12.3 then apply.

Free access is not a purchase. The refund policy in section 13.2 applies to plans you buy and pay for, including bcs Pro bought before bcs became free.

13. Cancellation, refunds and your right of withdrawal

13.1 Cancelling

Monthly plan: cancel any time in Account Settings, self-serve, in the same number of steps it took to subscribe. You may also email contact@bcscholars.com. Cancellation stops future renewals. You keep access until the end of the period you already paid for.

Upfront cycle: there is nothing to cancel. It is charged once and does not renew, and access ends when the 5 months end.

Month paid by Pix: there is nothing to cancel. It is charged once and does not renew, and access ends when the month ends.

Recurring cycle: cancel any time in Account Settings, as for the monthly plan. Cancellation stops future renewals, and you keep access until the end of the 5 months you already paid for.

Cycle in 5 installments: this plan is a commitment to 5 installments and cannot be cancelled, in Account Settings or otherwise, except under the refund policy in section 13.2 or a statutory right in section 13.3. Outside those, all 5 installments are due. After the 5th paid installment the plan ends on its own, with nothing to cancel.

13.2 The bcs refund policy

We offer a full refund of your first purchase if you ask for it within 14 calendar days of purchase. This applies to all three bcs Pro plans, however you paid. It is a single global standard, it is more generous than the statutory minimum in every country we serve, and you do not have to give a reason. Ask at contact@bcscholars.com.

• Monthly plan: the first monthly payment is refunded in full and the subscription ends.
• Upfront cycle: the payment is refunded in full, to your card or, for a Pix payment, by Pix to the paying account.
• Month paid by Pix: the payment is refunded in full, by Pix to the paying account.
• Recurring cycle: the first cycle payment is refunded in full and the subscription ends.
• Cycle in 5 installments: everything you have paid is refunded in full, the commitment ends, and no further installments are due.

Access ends when the refund is issued. After 14 days, amounts already paid are non-refundable and the remaining installments of a Cycle in 5 installments stay due, except where a statutory right below gives you more, or where the law of your country requires a refund.

13.3 Statutory rights that sit on top of our policy

Nothing in this section reduces the rights below, and the commitment of the Cycle in 5 installments does not limit them. If you withdraw under one of them, whatever you paid is refunded as that law provides and, for the Cycle in 5 installments, the commitment ends and no further installments are due.

• Brazil. Article 49 of the Código de Defesa do Consumidor gives you the right to withdraw from a contract entered into outside a commercial establishment, including online, within 7 days of contracting or of receiving the service, with a full refund of amounts paid, monetarily adjusted.
• Colombia. Article 47 of Ley 1480 de 2011 gives you the right of retracto within 5 business days of contracting for distance sales, with reimbursement within 30 calendar days.
• India. Under the Consumer Protection (E-Commerce) Rules, 2020 we publish this refund policy, name a Grievance Officer, acknowledge complaints within 48 hours and resolve them within one month.
• European Economic Area and United Kingdom. A 14-day right of withdrawal applies to distance contracts. Where you ask us to begin the Service immediately and acknowledge that you will lose the withdrawal right on full performance, that acknowledgement applies.
• United States. State auto-renewal laws, including the California Automatic Renewal Law, apply, and the commitments in section 12.3 are designed to satisfy them.

13.4 Institutional licences

Refunds under an institutional licence are governed by the agreement with that institution, not this section.

14. School, district and institutional licences

14.1 The Institution's responsibilities

An Institution that licenses bcs represents and warrants that it:

• has the authority to enrol its students in the Service;
• has provided the notices and obtained the consents its own law requires from students and, where applicable, their parents or guardians, including under FERPA, state student privacy laws, LGPD Art. 14, DPDP Section 9 and Decreto 1377 Art. 12;
• will provide only the student data necessary for the Service;
• will not use administrator access to obtain individual student essays or Capy conversations except where the student has explicitly shared them, or where a documented safeguarding or legal obligation requires it and the Institution has authority to do so;
• will comply with its own policies on AI use in applications and communicate them to its students.

14.2 Our responsibilities

• We act as processor, operator or service provider on the Institution's documented instructions.
• Administrators see aggregate, cohort-level data. Individual essays and Capy conversations are not exposed to administrators or counselors by default.
• We do not market to students or parents on the basis of institutional data.
• On termination, we return or delete institutional data as agreed with the Institution, and we give students advance notice so they can export their own work.

14.3 Students under an institutional licence

If your Institution's licence ends, your access ends. We will give you at least 30 days' notice and an export window so you can take your essays, activity lists and profile with you, and, where offered, convert to a personal bcs account.

15. Third-party services and integrations

The Service relies on third parties, including cloud infrastructure, an AI model provider, payment processing and WhatsApp. The current list is in our Privacy Policy. It may link to or integrate with third-party sites and platforms including university portals and application platforms.

• We are not responsible for third-party services, their availability, their content or their policies.
• Your use of them is governed by their terms.
• Where you connect a third-party account, you authorize the data exchange that connection requires, and you may disconnect it at any time in settings.
• WhatsApp check-ins are opt-in and travel through WhatsApp, operated by Meta Platforms, under Meta's terms. Standard carrier rates may apply. Reply STOP to end them.

16. Suspension, termination and data export

16.1 By you

You can cancel a monthly plan or a recurring cycle yourself in Account Settings, as described in section 13.1, which also explains why the upfront cycle, a month paid by Pix and the Cycle in 5 installments have nothing to cancel. To close your account entirely and have your data deleted, email contact@bcscholars.com. Section 13 governs refunds.

16.2 Withdrawal of guardian consent

Where a parent or guardian withdraws the consent they gave for a user under 18, we stop processing that user's data and close the account. The export window in section 16.4 applies, and we will tell the student before the account closes.

16.3 By us, for cause

We may suspend or terminate your access, with notice where practicable, if you materially breach these Terms, if we reasonably believe you are using the Service to fabricate credentials or forge documents, if you fail to pay, if you create a security or legal risk, or if we are legally required to.

Where the breach is curable and the risk is not urgent, we will describe the problem and give you a reasonable opportunity to fix it before terminating.

16.4 By us, without cause

We may discontinue the Service or terminate your account without cause on 30 days' notice, and we will refund the unused portion of any prepaid subscription or cycle and release you from any remaining installments.

16.5 Your data on termination

We will not hold your work hostage.

• You may export Your Content as a PDF. A structured, machine-readable copy is available on request at contact@bcscholars.com, subject line PRIVACY. See section 17.1 of the Privacy Policy.
• On termination for any reason, including termination for cause, we give you a 30-day window to export before deletion, unless a law or a valid legal order requires otherwise.
• After that window, we delete Your Content per the retention schedule in the Privacy Policy.

16.6 Survival

Sections 6, 7, 8, 9.3, 9.4, 10, 17, 18, 19, 20, 21 and 24 survive termination, together with any provision that by its nature should survive.

17. Disclaimers

Read section 18.5 first if you are a consumer in Brazil, Colombia, India, the EEA or the UK. Some of what follows does not apply to you.

Except as expressly stated in these Terms and to the fullest extent permitted by applicable law, the Service is provided "as is" and "as available", and bcs disclaims all warranties, express, implied or statutory, including implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and any warranty arising from course of dealing or usage of trade.

Without limiting that, we do not warrant that: the Service will meet your requirements; access will be uninterrupted, timely, secure or error-free; Output will be accurate, complete, current or reliable; defects will be corrected; or that using the Service is permitted by any Target Institution.

18. Limitation of liability

18.1 Excluded damages

To the fullest extent permitted by applicable law, bcs will not be liable for indirect, incidental, special, consequential, exemplary or punitive damages, or for loss of profits, revenue, data, goodwill or opportunity, arising out of or relating to the Service, on any theory of liability.

18.2 What this specifically covers

Subject to sections 18.4 and 18.5, we are not liable for: any admissions, scholarship, financial aid, visa or enrolment decision; the consequences of submitting AI-assisted content to any institution; reliance on inaccurate Output; missed deadlines; or service interruptions.

18.3 Cap

To the fullest extent permitted by applicable law, our total aggregate liability arising out of or relating to these Terms or the Service will not exceed the greater of (a) the amounts you paid bcs in the twelve (12) months preceding the event giving rise to the claim, or (b) USD 100.

18.4 What is never limited

Nothing in these Terms limits or excludes liability for: death or personal injury caused by our negligence; fraud or fraudulent misrepresentation; wilful misconduct or gross negligence; or any liability that cannot lawfully be limited.

18.5 Consumers, by country

Brazil. Article 51 of the Código de Defesa do Consumidor renders void any contractual clause that makes it impossible, exonerates or reduces the supplier's liability for defects of any kind, or that waives or disposes of the consumer's rights. Articles 12, 14, 18 and 20 establish strict supplier liability for product and service defects. If you are a consumer in Brazil, sections 17, 18.1, 18.2 and 18.3 do not apply to you to the extent the CDC prohibits them, and your rights under the CDC apply in full.

Colombia. Ley 1480 de 2011 establishes non-waivable consumer rights, including the guarantee of quality and suitability, and Art. 42 renders abusive clauses ineffective. If you are a consumer in Colombia, the limitations above apply only to the extent Colombian law permits.

India. The Consumer Protection Act, 2019 provides non-excludable rights and remedies against deficiency in service and unfair contract terms. Nothing here limits those rights.

EEA and UK. Consumer protection law limits the exclusion of liability. Nothing here affects your non-excludable statutory rights.

United States. Some states do not allow certain exclusions or limitations, so some of the above may not apply to you.

19. Indemnification

This section does not apply to consumers in Brazil, Colombia, India, the EEA or the UK, or anywhere else where consumer law prohibits it.

For all other users, you agree to indemnify and hold harmless bcs and its officers, directors, employees and agents from third-party claims, damages, losses and reasonable legal costs arising out of: your breach of these Terms; Your Content; your violation of any Target Institution's academic integrity or AI policy; your violation of any third party's rights; or your violation of applicable law.

This does not require you to indemnify us for our own fraud, gross negligence or wilful misconduct. We will notify you promptly of any claim, and we may assume its defence at our own cost, in which case you will cooperate reasonably.

20. Dispute resolution, by country

bcs does not use mandatory arbitration anywhere, and does not ask any user to waive a class action. A mandatory arbitration clause imposed on a consumer in an adhesion contract is void under Article 51 of the Brazilian Consumer Code and is problematic under Colombian and Indian consumer law, and we have chosen not to impose one on anyone else either. Your rights depend on where you live.

20.1 First step, everywhere: talk to us

Before starting any formal proceeding, contact us at contact@bcscholars.com with your name, account email, a description of the problem and what you want. We will respond within 15 days and try in good faith to resolve it within 45 days. This step is a condition precedent to formal proceedings for users outside Brazil, Colombia and India, and is offered as a good-faith option for users in those countries.

20.2 Brazil

If you are a consumer in Brazil, you may bring any claim in the courts of your own domicile, as Article 101, I of the Código de Defesa do Consumidor permits. There is no mandatory arbitration and no class action waiver. You retain your right to participate in collective consumer actions.

You may also use https://www.consumidor.gov.br or your local PROCON at no cost, and you may complain to the ANPD on data protection matters.

20.3 Colombia

If you are a consumer in Colombia, you may bring a claim before the ordinary courts or before the Superintendencia de Industria y Comercio in its jurisdictional capacity, in the venue Colombian law provides. There is no mandatory arbitration and no class action waiver. You retain your rights to acciones de grupo and acciones populares. You may also file a reclamación directa with us first, which we will answer within the statutory period.

20.4 India

If you are a consumer in India, you may raise a grievance with our Grievance Officer, who acknowledges within 48 hours and resolves within one month. You retain full access to the District, State and National Consumer Disputes Redressal Commissions under the Consumer Protection Act, 2019, and to mediation under that Act. There is no mandatory arbitration and no class action waiver for Indian consumers.

20.5 United States

If you are in the United States, and the informal step in section 20.1 does not resolve the dispute, you and bcs may bring the claim in court.

• There is no mandatory arbitration. bcs does not require you to arbitrate, and does not ask you to give up a jury trial.
• There is no class action waiver. You retain any right you have to participate in a class or representative action.
• Either party may bring a qualifying claim in small claims court.
• Either party may seek injunctive relief in court for intellectual property misuse.

20.6 Everywhere else

For users outside Brazil, Colombia, India and the United States, disputes are resolved by the courts identified in section 21, after the informal step in section 20.1. Mandatory consumer law in your country of residence always gives you the right to a local forum where it says so, and that right prevails.

21. Governing law and venue

Your counterparty is bcs – BRIGHT CITIZEN SCHOLARS, INC. everywhere. Governing law and venue depend on where you are.

The UN Convention on Contracts for the International Sale of Goods does not apply. There is no arbitration clause in this agreement. Mandatory consumer protection law in your country of habitual residence always applies regardless of this table.

22. Intellectual property complaints

If you believe content on the Service infringes your rights, send a notice to our designated agent with: your contact details; identification of the work; the location of the material on the Service; a statement of good-faith belief that the use is unauthorized; a statement, under penalty of perjury, that the notice is accurate and you are authorized to act; and your signature.

Designated agent: Caio Vitor Urbano Neves caio@bcscholars.com bcs – BRIGHT CITIZEN SCHOLARS, INC., 6 Mass Row 2992, Hanover, NH 03755, USA

We respond to valid notices under the Digital Millennium Copyright Act and equivalent laws, and we terminate the accounts of repeat infringers.

23. Changes to these terms

We may update these Terms. When we do:

• We update the effective date and version number.
• For material changes, we give at least 30 days' advance notice by email and by in-product notice before they take effect.
• If you do not accept a material change, you may cancel before it takes effect and receive a pro-rata refund of the unused portion of any prepaid subscription or cycle. This also applies to the Cycle in 5 installments: no further installments are due.
• Material changes do not apply retroactively to disputes that arose before they took effect.

For consumers in Brazil and Colombia, changes that reduce your rights or increase your obligations require your affirmative agreement, not merely continued use.

24. General provisions

Entire agreement. These Terms, the Privacy Policy, any plan-specific terms, and any signed institutional agreement form the entire agreement between us on this subject.

Order of precedence. Any signed institutional agreement, then plan-specific terms, then these Terms, then the Privacy Policy.

Severability. If any provision is held unenforceable, it is modified to the minimum extent necessary to make it enforceable, or severed, and the rest remains in effect.

No waiver. Our failure to enforce a provision is not a waiver of it.

Assignment. You may not assign these Terms without our written consent. We may assign them to an affiliate or in connection with a merger, acquisition or sale of assets, on notice to you. If the assignment materially affects your rights, you may terminate and receive a pro-rata refund.

Force majeure. Neither party is liable for delay or failure caused by events beyond its reasonable control.

Notices. We may notify you by email to your account address or by in-product notice. You notify us at contact@bcscholars.com and at the postal address for your region in section 25.

Electronic communications. You consent to receive communications from us electronically, and agree they satisfy any legal requirement that a communication be in writing.

Relationship. Nothing here creates a partnership, joint venture, agency or employment relationship.

No third-party beneficiaries, except that Institutions are intended beneficiaries of section 14 as it applies to their students.

Export and sanctions. You represent that you are not located in an embargoed country and are not on any restricted-party list, and you will not use the Service in violation of export control or sanctions law.

25. How to contact us

Brazil BCS INC. INOVA SIMPLES (I.S.) CNPJ 68.475.111/0001-98 Rua Aimorés, nº 162, Bairro Rio Vermelho Salvador, Bahia, CEP 41940-080, Brasil

United States and rest of world bcs – BRIGHT CITIZEN SCHOLARS, INC. 6 Mass Row 2992, Hanover, NH 03755, USA

Service of process (Delaware) 131 Continental Dr, Suite 305, Newark, Delaware 19713, County of New Castle, USA c/o Legalinc Corporate Services Inc., registered agent

Use the subject line shown so your message is routed correctly and the right deadline starts running.

© 2026 bcs – BRIGHT CITIZEN SCHOLARS, INC. and BCS INC. INOVA SIMPLES (I.S.) All rights reserved.