BeneVets, Inc. - Copyright and DMCA Policy

§ 1. Plain-English Overview

In plain English: BeneVets respects copyright. If something you own appears on our Service without your permission, you can tell us using the process below and we will remove or disable access to it promptly. If your material was removed and you believe that was a mistake, you can send a counter-notice and we will explain what happens next. We follow the federal Digital Millennium Copyright Act (DMCA) procedure. This policy also explains who owns the educational summaries on the Service, how we handle artificial-intelligence-generated text, when we display partner content, and how we protect veterans' names and likenesses.

This Copyright and DMCA Policy ("Policy") is incorporated by reference into the BeneVets, Inc. Terms of Service ("Terms") and applies to all visitors, users, Helpers, and anyone who submits material to the BeneVets, Inc. ("BeneVets") web platform, web application, and ancillary surfaces (the "Service").

§ 2. Defined Terms

The following defined terms apply throughout this Policy. Terms used but not defined here have the meaning given in the Terms.

• "BeneVets Content" means content that BeneVets, Inc. authors, edits, compiles, or generates and publishes on the Service, including plain-language benefit summaries, explanations of regulatory authority, navigation guides, illustrations, and the BeneVets brand assets.
• "Designated Agent" means the natural person designated by BeneVets, Inc. under 17 U.S.C. § 512(c)(2) to receive notifications of claimed infringement and registered with the United States Copyright Office DMCA Designated Agent Directory under 37 C.F.R. § 201.38.
• "Notifier" means a person who submits a notice of claimed infringement under § 5 of this Policy.
• "Primary Regulatory Source" means an authority that is not subject to copyright protection under 17 U.S.C. § 105, including the United States Code, the Code of Federal Regulations, the Federal Register, decisions of the U.S. Court of Appeals for Veterans Claims and the U.S. Court of Appeals for the Federal Circuit, VA Adjudication Procedures Manual M21-1 provisions, VA forms, and other U.S. Government works.
• "Subscriber" means a person who has registered an account on the Service.
• "User-Supplied Content" means content that a Subscriber, a Helper, or another person submits to or through the Service, as further described in § 4.4.

§ 3. BeneVets's Own Content - Licensing

In plain English: Most of the educational content we write is offered under a Creative Commons license so that other veterans-serving organizations can reuse it. Government source material we cite is in the public domain. Our logo and brand are not covered by that license.

3.1 BeneVets Content License

Except where a different license is stated on the content itself, BeneVets Content is licensed to the public under the [LICENSE PLACEHOLDER - recommended: Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International (CC BY-NC-ND 4.0); confirm with Board].

If the recommended license is adopted, reusers may copy and redistribute BeneVets Content in any medium or format for noncommercial purposes, provided they give appropriate credit, provide a link to the license, indicate if changes were made, and do not distribute modified material. The full license text will be available at /license and the human-readable summary at https://creativecommons.org/licenses/by-nc-nd/4.0/.

3.2 Primary Regulatory Sources Excluded

Primary Regulatory Sources are not subject to copyright protection. 17 U.S.C. § 105. BeneVets does not claim copyright in any Primary Regulatory Source and cites the source on every benefit summary that derives from one.

3.3 BeneVets Brand Assets Excluded

The BeneVets name, the BeneVets logo, the BeneVets word mark, color palette in trade-dress combination, and other brand assets identified at /brand are not licensed under § 3.1. They remain the trademarks and trade dress of BeneVets, Inc. See § 14 (Trademark Complaints) and § 17 (Service-Mark Notice).

3.4 Photographs of Identifiable Individuals Excluded

Photographs, video, audio, or other depictions of identifiable individuals on the Service are not licensed under § 3.1 and may not be reused without separate written consent from BeneVets and from the depicted individual. See § 16 (Veteran Names and Likenesses).

§ 4. Content Categories on the Service

In plain English: This section explains who owns what on the Service. There are four categories: BeneVets content, content our large language model helps draft from public sources, partner content, and your own content.

4.1 BeneVets-Authored Content

Plain-language benefit summaries, explanatory articles, decision-support text, eligibility-threshold tables, glossary entries, and similar editorial work product authored by BeneVets staff or contractors are BeneVets Content under § 3.

4.2 LLM-Generated Content Disclosure

Some BeneVets Content is generated, in whole or in part, by a third-party large language model ("LLM") under contract to BeneVets, working from Primary Regulatory Sources and from prior BeneVets editorial guidance. This Section aligns with, and should be read together with, the Automated Decision-Making and AI Notice (Document 15).

Copyright posture. BeneVets treats the LLM output, after editorial review and integration, as BeneVets's editorial work product. BeneVets does not assert copyright in any Primary Regulatory Source quoted, paraphrased, or summarized in the output, and a link to the underlying source appears on every benefit summary so generated.

Authorship transparency. BeneVets surfaces a visible indicator on benefit content that has been generated or substantially generated by the LLM, consistent with Document 15.

No training on user content. BeneVets does not provide User-Supplied Content to any LLM provider for the purpose of training the provider's models. The Data Processing Agreement with the LLM provider contractually prohibits use of BeneVets's data for training. See § 19.

4.3 Third-Party Partner and Sponsor Content

The Service displays content supplied by third parties in two contexts.

(a) VSO directory entries. Entries in the directory of accredited Veterans Service Organizations and Veterans Service Officers are sourced from the U.S. Department of Veterans Affairs Office of General Counsel accreditation roster, which is a Primary Regulatory Source, and supplemented with information voluntarily supplied by the listed organization. Logos, organizational descriptions, and similar material remain the property of the listed organization and are displayed by license or fair use.

(b) Sponsored placements. Sponsored partner content displayed pursuant to the sponsorship-firewall framework described at /sponsorship-policy remains the property of the sponsor and is displayed by license. Each sponsored card carries the persistent disclosure required by the sponsorship policy.

A copyright claim against partner or sponsor content should be sent to the partner or sponsor in the first instance, and may also be sent to BeneVets under § 5.

4.4 User-Supplied Content (v1 Scope)

At launch, the Service does not host user-generated content in the customary sense. There are no comments, no reviews, no forums, no messaging, and no public-facing user pages. The following User-Supplied Content categories exist at v1:

1. Profile information the Subscriber enters about themselves (name, contact, service history, conditions of interest).
2. Uploaded documents, principally the DD-214, stored in the encrypted ProfileVault envelope.
3. Symptom log entries prepared by the Subscriber in connection with the Compensation and Pension examination preparation tool.
4. Form-field content the Subscriber prepares for pro se transmission to VA via the Lighthouse Benefits Intake API.
5. Helper-shared content, where a Subscriber has authorized a Helper to view some portion of (1) through (4).

These categories are not surfaced publicly and are not redistributed by BeneVets. Copyright issues are therefore narrow at v1.

Forward-compatible language. If and when BeneVets opens user-generated-content features (for example, public partner reviews, community questions and answers, or a peer-support surface), this Policy applies to those surfaces and the DMCA notice-and-takedown procedure in §§ 5 through 11 governs. BeneVets reserves the right to amend this Policy to address new content categories.

§ 5. DMCA Designated Agent

In plain English: Federal law requires us to designate one person to receive copyright complaints. Below is how to reach that person.

Under 17 U.S.C. § 512(c)(2), BeneVets, Inc. has designated the following agent to receive notifications of claimed infringement:

5.1 U.S. Copyright Office Directory Registration

The designation above is not effective for safe-harbor purposes until BeneVets has filed the designation with the U.S. Copyright Office DMCA Designated Agent Directory under 37 C.F.R. § 201.38. Step-by-step:

1. The designated person creates an account at https://dmca.copyright.gov.
2. BeneVets pays the filing fee ($6.00 per designation as of the rule's current schedule).
3. The designation includes the full legal name of BeneVets, Inc., all alternate names under which BeneVets does business, the physical and electronic contact information set out above, and an authorized signature.
4. The designation is renewed every three years under 37 C.F.R. § 201.38(c)(2). BeneVets sets a calendar reminder 60 days before each renewal date.
5. Any change to the designated agent or contact information is updated in the directory within 30 days under 37 C.F.R. § 201.38(c)(3).

§ 6. Notice of Claimed Infringement - Required Content

In plain English: If you want us to take something down because it infringes your copyright, send the Designated Agent a written notice with the six items listed below. If any item is missing, we may not be able to act on it.

A notice of claimed infringement under 17 U.S.C. § 512(c)(3)(A) must be a written communication provided to the Designated Agent that includes substantially the following six elements:

(1) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

(2) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.

(3) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit BeneVets to locate the material - provide the precise URL or URLs on the Service at which the material appears.

(4) Information reasonably sufficient to permit BeneVets to contact the Notifier, such as an address, telephone number, and, if available, an electronic mail address at which the Notifier may be contacted.

(5) A statement that the Notifier has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law. The statement must include this language under penalty of perjury where indicated in element (6):

"I have a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law."

(6) A statement that the information in the notification is accurate, and under penalty of perjury, that the Notifier is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. The statement must use this language:

"I swear, under penalty of perjury, that the information in this notification is accurate, and that I am the owner, or am authorized to act on behalf of the owner, of an exclusive right that is allegedly infringed."

A template form is available at /dmca/notice-template. Use of the template is not required, but it ensures all six elements are present.

6.1 Substantial Compliance

Under 17 U.S.C. § 512(c)(3)(B), a notification that fails to comply substantially with elements (2), (3), and (4) above will not be considered in determining whether BeneVets has actual or red-flag knowledge of infringement. BeneVets will, however, make reasonable attempts to contact the Notifier or take other reasonable steps to assist in receipt of compliant notification when only minor defects are present, as required by 17 U.S.C. § 512(c)(3)(B)(ii).

6.2 Good-Faith Fair-Use Consideration

Consistent with Lenz v. Universal Music Corp., 815 F.3d 1145 (9th Cir. 2015), BeneVets requests that Notifiers consider whether the allegedly infringing use is a fair use under 17 U.S.C. § 107 before submitting a notice. A notice that misrepresents the use, including by failing to consider fair use in good faith, may expose the Notifier to liability under 17 U.S.C. § 512(f). See § 13.

§ 7. BeneVets's Response to a Valid Notice

In plain English: When we get a complete notice, we will promptly remove or block access to the material and let the person who posted it know.

Upon receipt of a notice that substantially complies with 17 U.S.C. § 512(c)(3), BeneVets will:

(a) Acknowledge receipt of the notice to the Notifier within a reasonable time, ordinarily within five business days.

(b) Expeditiously remove or disable access to the material identified in the notice in accordance with 17 U.S.C. § 512(c)(1)(C).

(c) Take reasonable steps to notify the Subscriber, Helper, or other person responsible for the material that the material has been removed or disabled in accordance with 17 U.S.C. § 512(g)(2)(A). The notice to the affected person will include a copy of the notice received (with the Notifier's personal contact information redacted as appropriate), and a description of the counter-notice procedure available under § 8.

(d) Log the event in BeneVets's repeat-infringer documentation under § 11.

§ 8. Counter-Notice - Required Content

In plain English: If your material was taken down and you believe that was a mistake or that you have the right to use it, you can send a counter-notice with the items below. We will pass it to the Notifier, and unless the Notifier files a lawsuit within ten to fourteen business days, we will restore the material.

A counter-notice under 17 U.S.C. § 512(g)(3) must be a written communication provided to the Designated Agent that includes substantially the following elements:

(1) A physical or electronic signature of the Subscriber, Helper, or other person whose material was removed or disabled (the "Counter-Notifier").

(2) Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled.

(3) A statement under penalty of perjury that the Counter-Notifier has a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material. The statement must use this language:

"I swear, under penalty of perjury, that I have a good faith belief that the material was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled."

(4) The Counter-Notifier's name, address, and telephone number, and a statement that the Counter-Notifier consents to the jurisdiction of Federal District Court for the judicial district in which the address is located, or, if the Counter-Notifier's address is outside of the United States, for any judicial district in which BeneVets may be found, which is the United States District Court for the Central District of California, Riverside Division, and that the Counter-Notifier will accept service of process from the Notifier under § 512(c)(1)(C) or an agent of such Notifier.

The required jurisdictional consent language is:

"I consent to the jurisdiction of the United States District Court for the [judicial district in which my address is located, or, if my address is outside of the United States, the United States District Court for the Central District of California, Riverside Division], and I will accept service of process from the person who provided notification under 17 U.S.C. § 512(c)(1)(C) or that person's agent."

A template form is available at /dmca/counter-notice-template.

§ 9. BeneVets's Response to a Valid Counter-Notice

In plain English: After we get a complete counter-notice, we forward it to the original Notifier and wait ten to fourteen business days. If the original Notifier does not file a lawsuit and tell us about it, we put the material back up.

Upon receipt of a counter-notice that substantially complies with 17 U.S.C. § 512(g)(3), BeneVets will:

(a) Promptly provide the Notifier with a copy of the counter-notice under 17 U.S.C. § 512(g)(2)(B).

(b) Inform the Notifier that BeneVets will replace the removed material or cease disabling access to it not less than 10 nor more than 14 business days after receipt of the counter-notice, unless the Designated Agent first receives notice from the Notifier that the Notifier has filed an action seeking a court order to restrain the Counter-Notifier from engaging in infringing activity relating to the material on BeneVets's system or network under 17 U.S.C. § 512(g)(2)(C).

(c) If no such notice of court action is received, replace the removed material or cease disabling access to it on the 10th to 14th business day after receipt of the counter-notice.

(d) Log the event in BeneVets's repeat-infringer documentation under § 11.

§ 10. Submission Method

Notices and counter-notices may be submitted to the Designated Agent by either:

• Email to dmca@benevets.org, with a clear subject line, for example, "DMCA Takedown Notice" or "DMCA Counter-Notice"; or
• Postal mail to the mailing address in § 5.

Email is preferred for promptness of response and for confirmation of receipt.

§ 11. Repeat-Infringer Policy

In plain English: Federal law requires us to terminate accounts of users who repeatedly infringe copyright. We do that. We also document each step.

Under 17 U.S.C. § 512(i)(1)(A), BeneVets has adopted and reasonably implements, and informs Subscribers and Helpers of, a policy that provides for the termination in appropriate circumstances of Subscribers and Helpers who are repeat infringers.

11.1 Documentation

For each notice that results in removal or disabling under § 7, and for each counter-notice received under § 9, BeneVets's Designated Agent records, in a system of record retained for not less than four years:

1. Date and time of notice receipt.
2. The Notifier's identity and contact information.
3. The Subscriber, Helper, or other party associated with the affected material.
4. The material affected (URL or identifier).
5. Action taken and date of action.
6. Resolution (counter-notice received, restored, abandoned, lawsuit filed).

11.2 Strike Schedule

For Subscribers and Helpers:

• Strike 1. First valid notice resulting in removal or disabling: written warning to the affected person, with copy of the notice (redacted as appropriate) and reference to this Policy.
• Strike 2. Second valid notice within a rolling 24-month window: temporary suspension of the affected account for 30 days, plus written warning that a third strike will result in termination.
• Strike 3. Third valid notice within a rolling 24-month window: termination of the affected account. Reinstatement may be considered only on a showing that the prior strikes were resolved in the Subscriber's or Helper's favor (for example, by successful counter-notice and no court action) or in other appropriate circumstances.

11.3 Counter-Notice Effect

A strike is recorded when material is removed or disabled in response to a notice. If the affected person submits a valid counter-notice and the material is restored under § 9, the strike is administratively vacated. Repeat lodging of facially deficient notices against the same Subscriber may also be considered in evaluating "appropriate circumstances" under 17 U.S.C. § 512(i).

11.4 Identifier Used

For purposes of this policy, "the affected account" means the Subscriber's account on the Service, identified by the email address used for registration or by the BeneVets-assigned account identifier. A person who has had an account terminated under this policy may not re-register without prior written approval from BeneVets.

§ 12. Standards of Identification - Privacy of the Notifier

BeneVets may share a redacted copy of a notice with the affected Subscriber or Helper. By default, BeneVets does not redact the Notifier's name (which is necessary to give the affected person a meaningful opportunity to counter-notice), but BeneVets will redact the Notifier's residential street address and personal telephone number where the Notifier requests redaction and where alternative contact (such as an email address or an attorney's address) is available.

§ 13. Material Misrepresentation - 17 U.S.C. § 512(f)

In plain English: If you knowingly lie in a takedown notice or a counter-notice, federal law lets the other side recover damages and attorneys' fees from you. We may report misrepresentations.

Any person who knowingly materially misrepresents that material or activity is infringing, or that material or activity was removed or disabled by mistake or misidentification, may be liable for any damages, including costs and attorneys' fees, incurred by the alleged infringer, the copyright owner, the copyright owner's authorized licensee, or by BeneVets as a service provider under 17 U.S.C. § 512(f).

BeneVets considers good-faith analysis of fair use under 17 U.S.C. § 107 to be a prerequisite to forming the "good faith belief" required by § 512(c)(3)(A)(v), consistent with the Ninth Circuit's holding in Lenz v. Universal Music Corp., 815 F.3d 1145 (9th Cir. 2015). BeneVets reserves the right to seek recovery from a Notifier under § 512(f) where the Notifier has materially misrepresented infringement, including by failing to undertake a good-faith fair-use analysis.

§ 14. Trademark Complaints

In plain English: Trademark complaints (including complaints about brand names, logos, or service marks) are handled separately, not through DMCA. Send those to legal@benevets.org.

DMCA notice and takedown procedures apply only to copyright. Trademark complaints are governed by separate law (principally the Lanham Act, 15 U.S.C. § 1051 et seq., and California's unfair competition statute, Cal. Bus. & Prof. Code § 17200 et seq.) and follow a separate intake process.

14.1 How to Submit a Trademark Complaint

Send to legal@benevets.org with the subject line "Trademark Complaint," including:

1. The asserted mark and its registration number (if any) or basis for unregistered rights.
2. The goods or services with which the mark is used.
3. The location on the Service of the allegedly infringing use.
4. The basis for confusion or other actionable use.
5. The complainant's contact information.

14.2 BeneVets's Posture on U.S. Department of Veterans Affairs Branding

BeneVets does not use the Department of Veterans Affairs ("VA") seal, the Department of Veterans Affairs name as a brand element, the "VA" two-letter mark in a trademark sense, or any other VA brand element on the Service in any manner that suggests sponsorship by, endorsement by, or affiliation with the U.S. Department of Veterans Affairs without the prior written authorization of the U.S. Department of Veterans Affairs. BeneVets cites VA as a source and links to VA.gov resources, which is a nominative, non-source-indicating use.

This commitment is consistent with 38 U.S.C. § 902 (use of "Department of Veterans Affairs" and related insignia is restricted) and with 38 U.S.C. § 6307 (false claims of affiliation with VA in connection with services to veterans is independently actionable).

14.3 Holding-Out Prohibition Cross-Reference

BeneVets also does not represent itself as accredited under 38 C.F.R. § 14.629, does not act on a Subscriber's behalf with respect to VA, and does not use language implying VA representation. See Terms of Service and Pro Se Filing Attestation.

§ 15. Right of Publicity - California Civil Code §§ 3344 and 3344.1

In plain English: California law protects every person's right to control commercial use of their name, voice, signature, photograph, and likeness - including after death. BeneVets does not use any individual's name or likeness to advertise or sell without written consent.

15.1 Living Persons

Under California Civil Code § 3344, BeneVets does not knowingly use any individual's name, voice, signature, photograph, or likeness, in any manner, on or in products, merchandise, or goods, or for purposes of advertising or selling, or soliciting purchases of, products, merchandise, goods, or services, without that individual's prior written consent. Statutory damages may be available to an aggrieved individual under Cal. Civ. Code § 3344(a).

15.2 Deceased Personalities

Under California Civil Code § 3344.1, BeneVets does not use a deceased personality's name, voice, signature, photograph, or likeness, in any manner, on or in products, merchandise, or goods, or for purposes of advertising or selling, or soliciting purchases of, products, merchandise, goods, or services, without prior consent from the person or persons entitled to grant consent. The post-mortem right under § 3344.1 extends 70 years after death.

15.3 Right of Publicity Complaints

A person who believes their right of publicity has been violated by content on the Service should contact legal@benevets.org. BeneVets will review the claim and respond. Where appropriate, BeneVets will remove or disable the content.

§ 16. Veteran Names and Likenesses - Heightened Standard

In plain English: Out of respect for veterans, we apply a higher bar than the law requires. If a veteran's name, photo, story, or other identifying information appears on the Service, we have separate, documented written consent on file.

BeneVets treats every appearance of a veteran's name, voice, signature, photograph, likeness, service record, or personal story on any BeneVets surface (including testimonials, recognition pages, case studies, donor materials, press releases, the Annual Impact Report, and social-media accounts) as requiring separate, contemporaneous, written consent from the veteran (or, for deceased veterans, from the person or persons entitled to grant consent under Cal. Civ. Code § 3344.1).

The consent record is documented and retained per the Data Retention Schedule (Document 14), and includes:

1. The veteran's identity and contact information.
2. The specific content covered (text, photograph, video, audio, or other).
3. The specific surfaces on which the content may appear.
4. The duration of consent and any limits.
5. The veteran's right to withdraw consent prospectively at any time.
6. Date and signature.

A veteran who wishes to withdraw consent for any content currently appearing on the Service may write to legal@benevets.org. BeneVets will promptly remove or disable the content on receipt.

§ 17. Service-Mark Notice

The following marks are claimed by BeneVets, Inc. as common-law trademarks or service marks. Federal registration status is noted where applicable.

BeneVets reserves all rights in the foregoing. Nothing on the Service grants any license to use any BeneVets mark. See § 14 for the trademark complaint process for complaints by third parties against BeneVets's use of marks.

§ 18. International Considerations

In plain English: Our Service is meant for U.S. residents. If a copyright owner outside the U.S. asks us to take something down, we will follow the same procedure if the claim works under U.S. law or under an international treaty the U.S. has signed.

The Service is intended for users physically located in the United States, including the 50 states, the District of Columbia, U.S. territories, and APO/FPO/DPO addresses. BeneVets does not affirmatively offer the Service in the European Economic Area, the United Kingdom, Canada, Mexico, or other foreign jurisdictions.

International rights-holders who believe BeneVets is hosting or displaying their copyrighted work without authorization may submit a notice under § 5. BeneVets will honor a notice that asserts a claim colorable under U.S. copyright law as applied through the Berne Convention for the Protection of Literary and Artistic Works (Paris Act 1971) and the WIPO Copyright Treaty (1996), or under another applicable treaty to which the United States is a party. Where a notice asserts rights recognized in the rights-holder's jurisdiction but not under U.S. law (for example, a moral-rights-based notice not corresponding to 17 U.S.C. § 106A), BeneVets will evaluate the request as a matter of corporate policy but is not bound to act under the DMCA safe harbor.

§ 19. Artificial Intelligence and Copyright

In plain English: We use a large language model to help draft some plain-language summaries from government source material. We do not feed your data to that model for training, and the model provider is contractually prohibited from doing so. We are watching the courts but not taking sides on the broader AI-copyright debate.

19.1 No Use of User Content for Model Training

BeneVets does not provide User-Supplied Content to any LLM provider, search-engine provider, or other artificial-intelligence service provider for the purpose of training, fine-tuning, or evaluating the provider's models. The Data Processing Agreement with BeneVets's LLM provider contractually prohibits use of BeneVets's data for those purposes and requires deletion of any inputs and outputs after a defined retention window. The current LLM provider is identified, and the relevant contract terms summarized, in the Sub-processor List (Document 4) and the Automated Decision-Making and AI Notice (Document 15).

19.2 BeneVets's Posture on Pending AI Copyright Litigation

The legal questions surrounding the use of copyrighted works to train large language models are unsettled. See, e.g., Andersen v. Stability AI Ltd., No. 3:23-cv-00201 (N.D. Cal., pending); The New York Times Co. v. Microsoft Corp., No. 1:23-cv-11195 (S.D.N.Y., pending). BeneVets does not take a litigation position on these questions in this Policy and does not concede liability of itself or of any provider by virtue of using a provider whose training data has been challenged. BeneVets selects providers whose contractual terms with BeneVets disclaim training on BeneVets's data and whose underlying training practices are publicly described.

19.3 Notice from AI Rights-Holders

A copyright owner who believes that BeneVets-published LLM-assisted content reproduces protected expression from the owner's work in a manner that would be actionable if the content had been authored without LLM assistance may submit a notice under § 5. The DMCA procedure applies. The fact that content was generated with LLM assistance does not alter BeneVets's notice-and-takedown obligations.

§ 20. License to BeneVets of User-Supplied Content

In plain English: When you submit content to the Service, you give us a narrow, free license to use it just enough to operate the Service for you. The license is limited and ends when you delete the content or your account.

The license set out in this Section is restated from the Terms of Service. In case of any inconsistency, the Terms of Service control.

By submitting User-Supplied Content to the Service, you grant BeneVets a worldwide, non-exclusive, royalty-free, non-sublicensable (except to BeneVets's service providers solely for the purposes set out below), revocable license to host, store, display, transmit, reproduce, and modify the User-Supplied Content solely for the following purposes:

(a) operating the Service for the benefit of you and any Helpers you have authorized; (b) transmitting forms you have prepared pro se to the U.S. Department of Veterans Affairs at your direction; (c) backing up and securing your content; (d) complying with legal obligations; and (e) defending BeneVets against legal claims arising from your content.

The license terminates when you delete the content, when you close your account, or when retention is no longer required under the Data Retention Schedule, whichever is earliest, subject to the limited retention periods described in the Privacy Policy and the Data Retention Schedule (Document 14).

BeneVets does not claim ownership of User-Supplied Content. Subscribers retain all rights in their content not expressly licensed above.

§ 21. Section 230 Reservation

BeneVets, Inc. is an "interactive computer service" within the meaning of 47 U.S.C. § 230(f)(2). BeneVets reserves all protections afforded by 47 U.S.C. § 230, including those of § 230(c)(1) (publisher immunity for third-party content) and § 230(c)(2) (immunity for good-faith content moderation). Nothing in this Policy waives those protections. Reference to the DMCA notice-and-takedown procedure in this Policy is for the purpose of qualifying for the safe harbor under 17 U.S.C. § 512 and is not a representation that BeneVets is a publisher of third-party content for any other purpose.

§ 22. Updates to This Policy

BeneVets may update this Policy from time to time. Material changes will be noticed by:

• updating the "Last updated" date at the top of this Policy;
• posting a notice on the Service for a reasonable period; and
• where required by law or where the change materially affects rights or obligations of Subscribers, by email to registered Subscribers.

Continued use of the Service after the effective date of an updated Policy constitutes acknowledgment of the update, subject to the Terms of Service.

§ 23. Contact Information

§ 24. Cross-References

This Policy is incorporated by reference into and should be read together with:

• Document 01 - Terms of Service
• Document 02 - Privacy Policy
• Document 04 - Sub-processor List (identifies the LLM provider)
• Document 06 - Acceptable Use Policy (prohibitions on infringing uploads)
• Document 07 - Helper / Account-Linking Terms
• Document 14 - Data Retention Schedule (consent records and DMCA log retention)
• Document 15 - Automated Decision-Making and AI Notice (LLM disclosure)

End of Document 12 - DMCA / Copyright Policy. U.S. Copyright Office DMCA Designated Agent Directory registration must be completed before this Policy is operative for safe-harbor purposes.