Coach Kingsley Privacy Policy

1. Who We Are

Kingsway Education Technologies LLC, trading as Coach Kingsley, operates Coach Kingsley and related educational programs (Founder Track, KYEA Academy, and Partner Access). For family accounts and our own programs, we are the data controller. When an Organization provides Coach Kingsley to its Students, we process student information to provide the service that Organization has contracted for — see section 9.

Privacy contact: info@kingswayyea.org · Organization inquiries: partners@kingswayyea.org

2. Who Uses Coach Kingsley

Coach Kingsley is designed for Students primarily ages 12–18. Family (Founder Track) accounts are set up by a parent/guardian, or by a Student who confirms they are an adult. Organization accounts are created or authorized by the Organization. See section 11 for Students under 13.

3. Information We Collect

Depending on the program and how it is used, we collect:

• Student account information — name, email (or a parent/guardian's email if shared), login credentials, and program enrollment
• Parent/guardian information — name, email, and optional country and phone number provided at signup
• Educator/Facilitator and Organization information — names, work emails, roles, and Organization details
• Learning records — lesson progress, assignment responses, submissions, Business Builder and Launch Kit content
• Feedback and review — Educator/Facilitator feedback, grades or review status, and Pitch Practice rubric and readiness results
• Messages — messages between Students, parents/guardians, Educators/Facilitators, and Kingsway support
• AI coaching conversations with Coach Kingsley, and saved coaching notes used to keep coaching consistent
• Uploaded files a Student chooses to attach to their work
• Pitch Practice recordings (audio or video), transcripts, and delivery measurements
• Technical and security information — device, browser, IP address, and usage timestamps
• Subscription status and billing identifiers (full payment details are handled by Paddle — see section 8)

4. How We Use Information (Purpose Limitation)

We use Student information only as reasonably necessary to:

• provide the educational program the Student is enrolled in
• personalize coaching using the Student's authorized work and progress
• save progress and show it to the Student and the adults authorized to see it
• let authorized Educators/Facilitators review work and give feedback
• send service messages and notifications about the Student's account
• provide support
• keep the service secure and diagnose technical problems
• meet legal and contractual obligations
• improve the quality of Coach Kingsley using limited, internal review — never to build advertising profiles

5. No Sale and No Targeted Advertising

Kingsway does not sell student personal information. We do not use student personal information for behavioral or targeted advertising, we do not build advertising profiles from students' educational activity, and we do not track Students across unrelated websites for advertising.

Our public marketing pages record simple page and button events (for example, that a demo was started) to understand how visitors find Coach Kingsley. These events do not include a Student's answers or work.

6. AI Processing and Model Training

To respond to a Student, Coach Kingsley sends the relevant parts of the request — such as the Student's question, relevant lesson context, and relevant authorized work — to third-party AI model providers through our AI service provider. Pitch Practice recordings are also sent for transcription and feedback.

Kingsway does not use student personal information or student educational work to train general-purpose AI models. AI providers process this information to return a response under their business terms; depending on the provider, limited information may be retained for a short time for abuse prevention or security. We choose providers and settings intended to keep this processing limited, and we will update this policy if our providers change materially.

7. Uploaded Files

Students can attach files to their work. When relevant to a Student's request, Coach Kingsley can read the text of certain file types — Word documents (DOCX), text-based PDFs, and plain text, Markdown, CSV, and RTF files — to give coaching. It does not read text from images or scanned PDFs, and it does not transcribe audio or video files attached to assignments; for those, it only knows that the file exists. Coach Kingsley only accesses a Student's own authorized files, and only to respond to that Student's request.

8. Payments 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 and subscription identifiers, and related billing information.

9. Organization-Provided Accounts

When a school, youth organization, or other Organization provides Coach Kingsley, we process Student information to provide the educational service in that Organization's agreement, and only for its authorized program.

Organization administrators and Educators/Facilitators can see Student information only according to their role and the classes or programs assigned to them. Organization access does not make all Student communications visible to everyone in that Organization, and one Organization cannot see another Organization's Students.

Some Organizations have their own legal obligations for student records (for example, under FERPA in the United States). Whether those apply depends on the Organization and its agreement with us. Coach Kingsley is designed to support Organizations in meeting their student privacy obligations; specific commitments are set out in the Organization's agreement.

10. Who Can See Student Work

• The Student
• For family accounts: the parent/guardian connected to the account
• For KYEA Academy: Kingsway instructors assigned to the Student
• For Partner Access: the Organization's Educators/Facilitators and administrators within their assigned scope
• Authorized Kingsway staff, for support, safety, and operating the service — when staff preview a Student's view, a privacy mode can hide the Student's identity

11. Students Under 13

Coach Kingsley is designed for Students ages 12–18, so some Students may be under 13. A Student under 13 may use Coach Kingsley only when a parent/guardian creates or authorizes the account, or when an Organization authorizes access for its program. Students under 13 should not sign up on their own.

Parents/guardians of a Student under 13 may contact us to review the information we hold about their child, ask us to correct it, ask us to delete it, or withdraw authorization.

12. Teen Privacy

For Students ages 13–18, we apply the same purpose limits in section 4 and the same no-sale and no-targeted-advertising commitments in section 5.

13. Sharing Information

We share personal information only with these categories of recipients:

• Merchant of Record — Paddle.com, for sales, subscription management, payments, tax compliance, invoicing, and refunds
• Service providers — hosting, database and file storage, email delivery, AI model providers (see section 6), and support tooling, acting on our instructions
• The adults and Organizations authorized to see a Student's work (see section 10)
• Connected AI apps a user chooses to authorize (see section 20)
• Professional advisers — legal, accounting, and audit advisers where necessary
• Authorities — where required by law or to protect someone's safety

14. Pitch Practice Recordings

Pitch Practice voice and video recordings are kept for up to 12 months from the date of the attempt. Viewing or downloading a recording does not extend that date.

Students can download their own recording while it is available and can delete an attempt at any time. When an attempt is deleted or reaches 12 months, we remove the recording together with its transcript, delivery measurements, Coach Kingsley feedback, rubric and readiness results for that attempt, linked Judge Q&A, and any comparisons that relied on it.

An expired attempt stops being available immediately, even before cleanup has finished. Cleanup runs automatically after expiry; if a file cannot be removed on the first try, we keep trying rather than treating it as deleted. Expired data may remain briefly in restricted technical systems while secure deletion completes.

Playback and download links are private and expire within minutes.

15. How Long We Keep Other Information

When information is no longer needed, it is deleted or anonymized.

• Pitch Practice — up to 12 months, as described above
• Account and program records — while the account or program is active, and afterward only as long as needed for support, legal, or contractual reasons
• Organization-provided records — according to the Organization's agreement
• Payment records — as required by Paddle and by tax and accounting law
• Security and technical logs — as long as reasonably needed to keep the service secure and working

16. Data Security

We protect information with measures such as secure sign-in, role-based permissions, program and class scoping, private file storage, and short-lived links for recordings. No system can be guaranteed completely secure, and we do not publish security details that could help someone attack the service.

17. 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.

18. Cookies

We use essential cookies and similar local storage to keep users signed in and to keep the platform secure. We do not use advertising cookies. 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.

19. Your Rights and Choices

Depending on where you live, you — or a parent/guardian on a Student's behalf — may ask us to:

• provide access to the personal information we hold
• correct inaccurate information
• delete information, where appropriate
• restrict or object to certain processing
• provide a portable copy of information you provided
• withdraw consent, including parent/guardian authorization
• end a program enrollment or access

20. Connected AI Apps (Agent Integrations)

If a user 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.

21. Contact and Complaints

Students can delete Pitch Practice attempts themselves. For privacy and security questions and other requests — including access, correction, account or data deletion — contact Kingsway Education Technologies LLC at privacy@kingswayyea.org. For general support, contact info@kingswayyea.org. We aim to respond within one month. If a Student's account was provided by an Organization, we may coordinate the request with that Organization.

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