Kelly Legacy Estates, Kelly Legacy Institute, Kelly Legacy Publications, the Office of the Fiduciary, and the Kelly Legacy Estates Living Trust (collectively, "KLE", "Institution", "we", "us", or "our") are committed to maintaining the privacy and security of information collected through our educational, governance, and administrative platforms. This Privacy Policy describes the types of information we may collect, how we use and protect that information, and the choices available to you.

This Policy applies to all websites, applications, forms, communications, and services operated by KLE (collectively, the "Platforms"). By accessing or using our Platforms, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

We may collect the following categories of information:

• Identifying Information: Name, postal address, email address, telephone number, and other identifiers you provide when contacting us, registering for programs, or submitting institutional review requests.
• Institutional and Educational Records: Information regarding your participation in governance education, access credentials, completion records, and communications with the Office of the Fiduciary.
• Technical and Usage Data: IP address, browser type, operating system, referring URLs, pages viewed, time spent, and interaction data collected through cookies and similar technologies.
• Communications Content: Emails, messages, forms, and other correspondence you send to KLE, including attachments and metadata.
• Payment and Access Information: Transaction records related to contributions, access credentials, or institutional access infrastructure (but we do not directly store full payment card numbers; payment processing is handled by third‑party processors).

We do not collect sensitive personal information (such as government IDs, social security numbers, or precise geolocation) unless you voluntarily provide it in the context of a specific request, and we use such information only for the purpose for which it was provided.

We collect information from the following sources:

• Directly from you: When you fill out forms, submit institutional review requests, register for governance access, communicate with us via email or contact forms, or otherwise provide information to KLE.
• Automatically through your use of our Platforms: Through cookies, server logs, and analytics tools, as described in Section 7.
• From third parties: Where permitted, we may receive information from third‑party service providers (e.g., email verification services) to improve data accuracy or security.

We use collected information for the following purposes:

• To provide, operate, and maintain our educational and governance Platforms;
• To process institutional review requests, access credential applications, and administrative correspondence;
• To communicate with you about governance matters, policy updates, publications, and institutional announcements;
• To authenticate users and enforce our Terms of Use and Intellectual Property Policy;
• To improve our Platforms, content, and user experience through analytics and research;
• To comply with legal obligations, respond to lawful requests, and protect the rights, property, or safety of KLE, our users, or others; and
• For any other purpose disclosed to you at the time of collection or with your consent.

We do not use your information for automated decision‑making that produces legal or similarly significant effects without human review.

KLE maintains educational and administrative records as part of its governance infrastructure. These records include information about your participation, credentials, communications, and institutional interactions. Such records are used to document governance status, facilitate continuity, and support institutional accountability. Access to these records is restricted to authorized personnel and is not shared except as described in this Policy or required by law.

Educational records are maintained in accordance with our Record Policy, which is available at /legal/record-policy.html.

Any communication you send to KLE, including through contact forms, email, or institutional review requests, may be retained as part of our administrative record. While we treat such communications as confidential to the extent consistent with institutional governance, they are not protected by attorney‑client privilege or any similar legal confidentiality unless a separate written agreement explicitly provides otherwise. Do not send sensitive or privileged information unless you are comfortable with this retention practice.

We use cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage, and maintain security. Cookies are small text files stored on your device. We may use both session cookies (which expire when you close your browser) and persistent cookies (which remain until deleted).

We may also use third‑party analytics services (such as Google Analytics) to collect information about how users interact with our Platforms. These services may use their own cookies to track browsing behavior. You can opt out of certain analytics by adjusting your browser settings or using opt‑out tools provided by the analytics provider.

You may disable cookies in your browser settings, but some features of our Platforms may not function properly as a result.

We may use third‑party service providers to assist with hosting, data storage, email delivery, analytics, payment processing, and other operational functions. These providers have access to your information only to perform tasks on our behalf and are contractually obligated to maintain the confidentiality and security of that information, and not to use it for any other purpose.

Our Platforms may contain links to third‑party websites or services. KLE is not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third‑party sites you visit.

When you make contributions or obtain access credentials through KLE platforms, payment processing is handled by third‑party payment processors (e.g., Stripe, cryptocurrency networks). We do not store full payment card numbers or private keys. Information collected by payment processors is subject to their respective privacy policies. We may store transaction identifiers, amounts, and dates to maintain accurate administrative records.

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share information in the following circumstances:

• With your consent: When you direct us to share information with a third party.
• With service providers: As described in Section 8, to perform functions on our behalf.
• For legal compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.
• To protect rights and safety: To investigate, prevent, or take action regarding suspected fraud, security incidents, violations of our policies, or threats to the safety of any person.
• In the event of reorganization: If KLE undergoes a merger, acquisition, or similar transaction, information may be transferred as part of that transaction, subject to the same privacy commitments.

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to maintain accurate educational and administrative records, to comply with legal obligations, to resolve disputes, and to enforce our agreements. Specific retention periods are set forth in our Record Policy. After the retention period, information will be anonymized, aggregated, or securely deleted.

KLE takes reasonable technical, administrative, and physical measures to protect information from loss, unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit (TLS), access controls, regular security assessments, and employee training. However, no transmission or storage system is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

You may have certain rights regarding your personal information, including:

• Access: Request a copy of the information we hold about you.
• Correction: Request that we correct inaccurate or incomplete information.
• Deletion: Request that we delete your information, subject to legal and recordkeeping obligations.
• Opt‑out of communications: Unsubscribe from promotional emails by following the instructions in the email. Administrative communications (e.g., policy updates, security notices) will continue as necessary.

To exercise these rights, contact us at kellylegacyestatesllc@gmail.com. We will respond within a reasonable timeframe and may request verification of your identity.

Our Platforms are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have inadvertently collected such information, we will take steps to delete it promptly. By using our Platforms, you represent that you are at least 18 years of age or have obtained parental or guardian consent.

Your use of KLE Platforms and your provision of information do not create an attorney‑client, fiduciary‑client, financial advisory, or confidential legal relationship between you and KLE, unless a separate written agreement explicitly states otherwise. Communications through our Platforms are not privileged and may be subject to disclosure as required by law.

Our Platforms are operated from the United States. If you access our Platforms from outside the United States, you acknowledge that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using our Platforms, you consent to such transfer and processing.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. The most current version will be posted at https://kellylegacyestates.com/legal/privacy.html with the "Last Updated" date. Material changes will be notified through our Platforms or by direct communication where appropriate. Your continued use after any changes constitutes acceptance of the revised Policy.

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Kelly Legacy Estates – Privacy Office
Email: kellylegacyestatesllc@gmail.com
Subject: Privacy Inquiry

We will respond to all legitimate requests within a reasonable time.