This Record Verification & Retention Policy (the "Policy") governs the creation, maintenance, verification, retention, and disclosure of records held by 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"). This Policy applies to all educational, administrative, governance, and institutional records maintained by KLE.

KLE maintains records to support its educational mission, governance infrastructure, institutional continuity, and administrative accountability. This Policy describes the types of records we keep, how you may request verification, the limitations of our verification services, and the retention periods applicable to different categories of records.

This Policy applies to the following categories of records maintained by KLE:

• Educational records (course participation, completion, and assessment records);
• Governance records (credentials, access classifications, and institutional roles);
• Administrative records (correspondence, intake forms, and internal documentation);
• Financial and contribution records (transaction identifiers, amounts, and dates);
• Institutional publications and doctrine archives; and
• Technical and system logs related to platform use.

This Policy does not apply to records that are not under KLE’s control, including records maintained by third‑party platforms (e.g., email providers, payment processors) subject to their own policies.

KLE maintains educational records to document participation, completion, and governance status. These records include:

• Enrollment and registration information;
• Records of curriculum access and completion;
• Issued credentials and access classifications;
• Communications related to governance participation; and
• Internal administrative notes necessary for continuity.

Educational records are maintained for the benefit of the Institution and its authorized participants, subject to the limitations described in this Policy.

Records are created when you interact with KLE through forms, applications, registrations, communications, or platform use. KLE strives to maintain accurate, complete, and secure records in accordance with industry standards. However, we rely on the accuracy of the information you provide. You are responsible for notifying us of any material changes to your information.

Records are maintained in electronic and, where necessary, physical formats, stored in secure environments with access restricted to authorized personnel.

If you require verification of a record held by KLE (e.g., participation in a program, issuance of a credential, or administrative correspondence), you may submit a written verification request to kellylegacyestatesllc@gmail.com with the subject line "Record Verification Request." Your request must include:

• Your full name and any identifiers used in your interactions with KLE;
• A clear description of the record you seek to verify;
• The approximate date or time period of the record; and
• Any supporting information that may assist us in locating the record.

KLE will respond to reasonable verification requests within a commercially reasonable time, typically 30 business days. We may require identity confirmation (Section 7) before responding.

KLE provides record verification on a best‑efforts basis. We do not guarantee that all records will be retrievable, especially those beyond stated retention periods. Verification is limited to confirming the existence and content of records as maintained by KLE. We do not provide:

• Legal opinions regarding the effect or validity of records;
• Governmental or court recognition of any record;
• Professional licensure or certification validation;
• Notarization or apostille services; or
• Third‑party authentication beyond our own institutional attestation.

KLE reserves the right to refuse verification requests that are excessive, repetitive, or would require disproportionate effort.

To protect your privacy and prevent unauthorized disclosure, KLE will require reasonable identity confirmation before fulfilling record verification requests or disclosing non‑public records. Identity confirmation may include verifying your email address, matching information in our records, or requesting additional documentation. If we cannot reasonably confirm your identity, we may deny the request.

KLE treats non‑public records as confidential to the extent required by law and institutional policy. We do not disclose records to third parties without your consent, except:

• To comply with a lawful subpoena, court order, or government request;
• To protect the rights, property, or safety of KLE, our participants, or the public;
• To enforce our policies or investigate potential violations;
• To third‑party service providers who perform functions on our behalf (e.g., cloud storage, archival services) under confidentiality obligations; or
• As otherwise required or permitted by law.

Records that you have voluntarily made public (e.g., through publications or public forums) are not subject to confidentiality protections.

KLE retains records for the following periods:

• Educational and governance records: Indefinitely or until the participant requests deletion, subject to legal and operational requirements.
• Administrative correspondence and intake forms: For 7 years from the last interaction.
• Financial and contribution records: For 7 years for compliance and accounting purposes.
• System logs and technical data: For up to 12 months, after which they are aggregated or anonymized.
• Archived publications and doctrine: Indefinitely as part of the institutional archive.

These periods are guidelines and may be extended for legal, security, or operational reasons.

While KLE endeavors to preserve records in accordance with this Policy, we do not guarantee the permanent, error‑free, or uninterrupted retention of any record. Technical failures, disasters, or operational necessities may result in the loss of records. You are solely responsible for maintaining your own copies of important records.

KLE strongly recommends that all participants maintain their own copies of records that may be important for personal, legal, or tax purposes. KLE shall not be liable for any loss or damage resulting from the loss or unavailability of records stored by KLE, except as required by law.

If you believe that a record maintained by KLE is inaccurate or incomplete, you may submit a written correction request to kellylegacyestatesllc@gmail.com. We will review your request and, if appropriate, correct our records. We may not be able to correct records that were created from information you previously provided and that we have no independent basis to verify.

KLE uses third‑party platforms for certain functions (e.g., email services, form processing, payment processing, document storage). Records maintained by those third parties are subject to their own privacy and retention policies. KLE is not responsible for the retention practices of third‑party platforms. We encourage you to review the policies of any third‑party platforms you use in connection with KLE.

KLE may retain records beyond stated retention periods when necessary to comply with legal obligations, respond to pending legal or regulatory matters, enforce our agreements, or protect the Institution’s rights. Records subject to legal hold will be preserved until the hold is lifted.

KLE is not an accredited educational institution, government agency, or professional licensing body. Records maintained by KLE do not constitute professional certifications, licenses, or governmental recognitions unless expressly stated otherwise in a separate written agreement. No record maintained by KLE should be represented as official government‑issued identification, professional credential, or court‑recognized authentication.

KLE may update this Policy from time to time. The most current version will be posted at https://kellylegacyestates.com/legal/record-policy.html with the "Last Updated" date. Material changes will be communicated through our Platforms or by direct email. Your continued interaction with KLE after any changes constitutes acceptance of the revised Policy.

For questions regarding this Record Verification & Retention Policy, or to submit a verification or correction request, please contact us at:

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