Privacy Policy — Website & Educational Services — Evergreen v1.0

Effective September 8, 2026

1. Scope

This Privacy Policy explains how Kirkwood Global Enterprise LLC, formerly Never Be Without Accessories LLC, d/b/a Enchanted Pen Academy ("EPA") may collect, use, store, disclose, and protect information through its public website and in connection with EPA educational services, enrollment, communications, approved technology platforms, and related operations, except where a separate notice expressly applies.

2. Information EPA May Collect

Parent / Guardian Information

Name

Email address

Telephone number

Billing/account information

Communication preferences

Consultation and enrollment information

Student Information

Name

Grade level

Educational concerns and instructional needs

Enrollment and placement information

Attendance

Instructional progress

Diagnostic/assessment information

Learning-platform information necessary to provide services

Voice and image captured in authorized session recordings

Usernames and access codes for EPA-provisioned student accounts

Website / Inquiry Information

Information voluntarily submitted through inquiry, consultation, registration, download, or enrollment forms

Communications sent to EPA

Information associated with use of EPA's website or linked services, subject to technical verification

3. How EPA Uses Information

Respond to inquiries and schedule consultations

Process enrollment and establish family/student accounts

Administer billing and payments

Schedule and provide instruction

Conduct instructional diagnostics and placement

Monitor progress and communicate with parents/guardians

Provide learning-platform access

Deliver requested educational resources and communications

Maintain appropriate educational, operational, and business records

Improve EPA services and comply with applicable legal obligations

4. Students and Minors

EPA serves children, but parents or guardians are expected to manage enrollment, payment, contractual consent, recording/media choices, and other administrative interactions on behalf of minor students. EPA does not intentionally ask children to independently enter into service agreements or authorize payment. EPA obtains verifiable parental consent before collecting personal information from a child under 13 and gives parents a separate children's privacy notice describing what EPA collects, how it is used, and how a parent can review or delete it.

5. Educational Records and Diagnostic Information

Student diagnostic, placement, progress, instructional, and observation information is treated as private student information. EPA's internal procedures require identifiable diagnostic information to remain in approved EPA systems and prohibit placement of identifiable student data in public or unapproved AI tools. Student accounts, EPA devices, and approved platforms are governed by the separate EPA Technology & Student Account Consent & Acceptable Use Agreement, and the platforms in use are listed on the EPA Approved Technology & Student Data Platform Schedule.

6. Third-Party Service Providers

EPA uses third-party providers to support functions such as website hosting, scheduling, billing, live instruction, classroom/resource access, educational practice, email communication, marketing, analytics, and business administration.

The current working technology map includes Microsoft 365 and SharePoint for business administration, internal records, and controlled documents; Teachworks for enrollment, scheduling, and billing; LessonSpace, Google Meet, and Lalilo for instruction; Google Workspace for Education and Google Classroom for managed student accounts and instructional use, which EPA is developing and has not yet implemented; and Canva, approved enterprise AI workflows, Mailchimp, and Teachers Pay Teachers. Website host, form processor, payment processor, analytics, cookie, pixel, retention, and certain vendor-specific details remain subject to technical verification. EPA uses only enterprise or education tiers of AI tools that do not use EPA data to train models, and identifiable student information is not entered into any consumer AI tool.

7. Email and Educational Resources

EPA may use information provided by an adult to deliver requested resources and related communications. Users should have an appropriate way to unsubscribe from marketing email. Transactional or service-related communications may still be sent when necessary to provide EPA services.

8. Recording, Images, and Media

Enrollment does not automatically authorize EPA to record student instructional sessions or publicly use student media. Recording and publicity are governed through separate consent procedures.

9. Disclosure

EPA may disclose information when reasonably necessary to operate educational services, process payments, provide approved platform access, communicate with enrolled families, comply with law, protect legitimate rights or safety, or work with authorized service providers. EPA does not sell personal information and does not use student information for targeted advertising. EPA does not disclose a child's personal information to a third party for any purpose beyond providing EPA services without separate parental consent.

10. Security

EPA uses reasonable administrative, operational, and technical measures intended to protect personal and student information. No electronic system can guarantee absolute security. EPA requires sensitive student information to be handled through approved systems rather than unsecured screenshots, informal public links, or unapproved AI chats. EPA maintains a written information security program that names the person responsible for it and the risks it is designed to address. If personal information is exposed, EPA follows a written incident-response procedure and notifies affected families, and any regulator required by law, without unreasonable delay.

11. Data Retention

EPA retains information for as long as reasonably necessary to provide services, administer enrollment and billing, maintain appropriate records, fulfill legal or contractual obligations, and resolve disputes or operational issues. Different record categories may have different retention periods.

EPA keeps enrollment and billing records for four years after an account closes, instructional and diagnostic records for three years after a student leaves, session recordings for 90 days, and marketing contact details until the person unsubscribes, after which EPA keeps only the minimum record needed to honor the opt-out. Information is deleted at the end of these periods unless EPA has recorded a legal, safety, or dispute reason for keeping it longer.

12. Cookies, Analytics, and Tracking

EPA's website or its providers may use cookies or similar technologies for site operation, analytics, embedded services, or user experience. The exact technologies currently active are being verified through EPA's Website Cookie & Tracking Technology Audit.

13. External Links

EPA may link to third-party services and platforms. Their own privacy practices may apply after a user enters those services. EPA remains responsible for its own provider selection and data-handling practices.

14. Parent/Guardian Requests

Parents/guardians may contact EPA to request correction of inaccurate information, update contact details, ask how information is being used, withdraw certain optional permissions, or make other applicable privacy requests. Some records may need to be retained for legitimate business, contractual, safety, or legal purposes. A parent may also review the personal information EPA holds about their child, refuse to allow further collection or use of it, and ask EPA to delete it.

15. Changes to This Policy

EPA may revise this Privacy Policy as services, technology, business practices, or legal obligations change. The published version displays an effective date, and material changes are communicated to enrolled families before they take effect.

16. Contact

Enchanted Pen Academy
Email: info@enchanted-pen-academy.com