Coach Kingsley Privacy Policy

1. Who We Are (Data Controller)

Kingsway Education Technologies LLC, trading as Coach Kingsley, is the data controller responsible for personal information processed through the Coach Kingsley platform and the Coach Kingsley Founder Track program. This Privacy Notice explains what information we collect, why, how we share it, and the rights families have.

Controller: Kingsway Education Technologies LLC · info@kingswayyea.org

2. Who Uses Coach Kingsley

Coach Kingsley Founder Track is designed for students ages 12–18. Parent/guardian enrollment and authorization is required.

3. Information We Collect

We may collect:

• parent/guardian name
• parent/guardian email
• student name
• student email, if separate login is used
• student grade or age range, if provided
• account login credentials
• selected plan and subscription status
• lesson progress
• assignment responses
• Business Builder entries
• Launch Kit content
• Coach Kingsley interaction summaries or logs
• support messages
• technical and usage information such as device, browser, IP address, device identifiers, and usage timestamps

4. Payment Information and Our Merchant of Record

Our order process is conducted by our online reseller Paddle.com. Paddle.com is the Merchant of Record for all our orders, and acts as controller of the payment data it collects for billing, tax compliance, invoicing, and fraud prevention. See Paddle's privacy notice at https://www.paddle.com/legal/privacy.

Coach Kingsley never receives or stores full card numbers. We store only what we need to manage access: payment status, plan, Paddle customer ID, Paddle subscription ID, and related billing metadata.

5. How Information Is Used

Information may be used to:

• create and manage accounts
• provide Founder Track access
• deliver lessons and Coach Kingsley support
• save student progress
• show parent progress views
• manage billing and subscription status
• improve safety, quality, and the learning experience
• provide customer support
• comply with legal obligations

6. Legal Basis for Processing

Where data protection law requires a legal basis, we rely on the following:

• Performance of a contract — creating accounts, providing Founder Track lessons and coaching, saving progress, and managing subscriptions and access.
• Legitimate interests — platform security, fraud prevention, service reliability, product improvement, and responding to support requests.
• Consent — parent/guardian authorization for a student's account (including any child under 13) and optional marketing email; consent can be withdrawn at any time.
• Legal obligation — tax, accounting, recordkeeping, and responding to lawful requests.

7. AI-Assisted Learning Data

Coach Kingsley may use lesson context, assignment responses, and student interactions to provide personalized educational guidance. Coach Kingsley is designed to guide student learning, not complete the student's work for them.

8. Children Under 13

If Coach Kingsley collects personal information from a child under 13, parent or guardian authorization is required. Parents may contact us to request access, correction, or deletion of their child's personal information, subject to legal and operational requirements.

9. Teen Privacy

For students ages 13–18, Coach Kingsley still treats student learning data with care and limits use to educational, operational, safety, support, and platform-improvement purposes.

10. Sharing Information

We do not sell student personal information. We share personal information only with the following categories of recipients:

• Merchant of Record — Paddle.com, for the sale of our products, subscription management, payments, tax compliance, invoicing, and refunds.
• Service providers and subprocessors — hosting and database providers, email delivery, AI model providers used to power Coach Kingsley, analytics, and support tooling.
• Professional advisers — legal, accounting, and audit advisers where necessary.
• Authorities — where required by law or to protect the safety of a student or another person.

11. International Transfers

Our providers, including Paddle, may process information in countries other than your own. Where required, such transfers are protected by appropriate safeguards such as standard contractual clauses or adequacy decisions.

12. Data Security

We apply appropriate technical and organizational measures, including encryption in transit, access controls, and role-based permissions. No system can be guaranteed completely secure.

13. Data Retention

We retain information for as long as needed to provide services, maintain educational records, support families, comply with legal and tax obligations, and resolve disputes. When information is no longer needed, it is deleted or anonymized.

14. Cookies

We use essential cookies and similar local storage to keep families signed in and to keep the platform secure. If we add analytics or marketing cookies, we will request consent where required and provide a way to manage preferences. Browser settings can also be used to block or delete cookies.

15. Your Rights

Depending on where you live, you (or a parent/guardian on a student's behalf) may request:

• access to the personal information we hold
• correction of inaccurate information
• deletion or erasure of information, where appropriate
• restriction of, or objection to, certain processing
• a portable copy of information you provided to us
• withdrawal of consent, including parent authorization
• revocation of product enrollment or access

16. Contact and Complaints

For privacy questions or to exercise any right above, contact Kingsway Education Technologies LLC at info@kingswayyea.org. We aim to respond within one month.

If you are in the UK or EEA, you also have the right to lodge a complaint with your local data protection supervisory authority.

17. Connected AI Apps (Agent Integrations)

If a family authorizes an outside AI assistant to connect to a Coach Kingsley account, that app receives read-only access to that account's own data: basic profile and email, entitled published curriculum, lesson progress, and assignment submissions with instructor feedback. It cannot read other students' data and cannot write anything.

Data a connected app reads is transferred to that provider and is then governed by their privacy policy and retention practices rather than ours; the provider acts as an independent controller for that copy. We log connection and tool activity for security and audit purposes, apply rate limits, and require Coach Kingsley approval of each app.

Authorization can be withdrawn at any time from Profile > Connected AI apps, or by contacting us; instructors can also revoke a connection. Withdrawal stops further access but does not retrieve data already transferred to that provider.