Data protection · United States

Privacy Policy

Last updated: November 1, 2026 · version 2026-11-01 · text under review by counsel

1. Who we are

This Privacy Policy describes how IKAN EXPERIENCE LLC, a limited liability company organized under the laws of the State of Delaware, United States, on January 17, 2023, with registered office at 611 South DuPont Highway, Suite 102, Dover, Delaware 19901 (Registered Agent: ZenBusiness Inc.) and mailing address at 2852 N. Cicero Ave., Chicago, Illinois 60641 (“IKAN,” “we,” “us”), collects, uses, shares and protects personal information in connection with our investment program, our educational and travel experiences, and our online platform available at www.ikanglobal.com. For operations with our Mexican affiliate, IKAN EXPERIENCE GROUP, S.A.P.I. de C.V., please refer to the Aviso de Privacidad 🇲🇽.

2. Information we collect

Depending on your relationship with IKAN (investor, client, parent or guardian, student, teacher, school, vendor, or team member), we may collect:

3. How we use your information

4. How we share information

We do not sell your personal information. We share it only with:

5. Children’s privacy

Our platform and investment services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13. Information about student participants in our educational programs is provided by their parents or legal guardians with their consent, is used solely to operate the program safely, and is protected consistent with the Children’s Online Privacy Protection Act (COPPA) and other applicable law. Parents and guardians may review, correct or request deletion of their child’s information at any time by contacting us.

5a. Program participants, including minors: health information

When a minor joins a program, a parent or legal guardian (the “declarant”) provides the information through a personal link and declares that they hold parental authority or guardianship. Adult participants are their own declarant.

5b. Team members: sick leave and health information

For team members, sick-leave and disability certificates are processed as sensitive health information, with the team member’s express consent, solely to run payroll, meet social-security obligations and justify absences. Only People & Culture and Payroll can access them, and they are retained for the periods required by labor and social-security law.

To manage time off, IKAN also processes, as sensitive information, pregnancy, expected date of birth or adoption, and the supporting documents for maternity, paternity, bereavement and sick leave, solely to grant and pay the leave required by law. People & Culture records them with the team member’s express consent; managers are only told that the person is away, never the reason.

5c. Team members: employee relations

Incident reports, administrative records, disciplinary measures and employment notices may contain statements by the team member, witnesses and third parties (for example, the affected person in a harassment case) and, exceptionally, sensitive information(health-related or about harassment). This information is processed solely to document the procedure required by Mexico’s Federal Labor Law and to protect the rights of the parties; the platform asks for facts and not for health information, access is limited to the team member (what was served on them), their reporting line, People & Culture, whoever authorizes the measure and the General Management, and every access is logged. Where the law requires express consent for sensitive information, it is obtained in writing or electronically. The team member is notified of each document at their personal e-mail, with no attachment. The retention period is set by the company’s retention policy, validated by counsel, and is never shorter than labor law requires.

For remote work, IKAN processes the country and address from which the person works and the workplace health-and-safety checklist for that location, to meet its remote-work obligations (equipment, utilities allowance, training and the right to disconnect).

Under the vacation and flexible work policy, IKAN processes the declared city and country from which a team member will work during Remote Work or Work From Anywhere weeks, the time difference and the acknowledgment of the immigration and tax notice; daily presence (office, home office, remote or out of office) derived from approvals and the weekly schedule, without geolocation or attendance tracking; the reasons for a home-office suspension, known only to People & Culture, the person and whoever suspended it; and department coverage (who in the same department is out on given dates), shown to approvers as a head count. Purpose: apply the policy, organize operations and comply with labor law. Retention: to be defined with counsel. Text pending review by counsel.

5d. Team members: performance, KPIs, surveys and NOM-035

IKAN processes each team member’s key performance indicators (KPIs), 360 reviews (manager, self, peers, internal clients and upward feedback), calibration and development plan, to follow up on work, give feedback, plan training and recognize results. Peer, internal-client and upward reviews are anonymous: neither the respondent nor the date is stored, and results are shown only in groups of five or more. No KPI or review is, by itself, grounds for discipline or termination.

Engagement, pulse and eNPS surveysare anonymous and shown only in aggregate once the survey closes. For Mexico’s NOM-035 Guide I (severe traumatic events), IKAN stores only the outcome (whether a clinical assessment is needed) as sensitive information, with the express consent given when answering; referrals are tracked by reference number and only the designated People & Culture lead knows the name. Exit interviewsare voluntary and confidential to People & Culture. Retention period: TO BE DEFINED by Legal.

5e. Team members: attendance records and remote check-in photos

For team members under Mexico’s Federal Labor Law, IKAN records clock-in and clock-out times (date, time, the time clock or channel used, the network addressthe record came from and the person’s time-clock number), the applicable schedule, late arrivals and absences, and the justifications submitted with their evidence. The direct manager is notified of late arrivals, absences and missing clock-ins. Purpose: keep the attendance records required by law (LFT arts. 804 III and 805), pay wages correctly for days worked and, if late arrivals accumulate, follow the employee-relations procedure. Late arrivals are never deducted from pay. Attendance is never recorded for independent contractors.

Biometric data.The office time clock may identify the person by fingerprint or face; that template lives in the device and the platform receives only the person’s number, date and time. Using fingerprint or face requires the person’s express written consent when enrolled, and a non-biometric alternative (time-clock number and password) is always available.

Remote check-in and check-out. They use a photo of the person and, when the policy requires it, one of the work area, with the server’s time and without location. The network address, browser and a digital fingerprint (hash) of each photo are also kept. The work-area photo may show the home and other people: please photograph only the work area, without people, minors, documents or home details. Photos and evidence are kept in a private repository and are seen only by the person, their direct manager who approves their attendance, and People & Culture; every view is logged.

Health data. A justification for medical care, its details and its evidence are seen only by the person and People & Culture, who resolves it; the direct manager only sees that a reserved reason exists. No diagnoses are requested.

Imported history.Attendance history recorded in the company’s previous attendance platform (IKANHR, acting as a processor for IKAN) is brought into this platform for the same purpose (pending review by counsel).

Retention. Photos are kept for the period set in the attendance policy and then deleted; no photo is collected until that period is defined. Attendance records are kept during employment and for one year after (LFT art. 804), then deleted. The person can view their photos in My attendance and exercise their access, rectification, cancellation and objection rights through the channel in section 7. Text pending review by counsel.

5f. Team members: punctuality and administrative measures under the internal policy

Using the days recorded by attendance tracking, IKAN keeps the monthly count of late arrivals, the notices a person gives their direct manager when they will be late or absent (with the time they gave them), written reminders (which are neither a sanction nor a pay deduction), the months with an incident considered in the monthly review and, if late arrivals recur within the year, the proposal to review the casewith People & Culture and Legal, always with the person’s right to be heard. Purpose: to apply the company’s internal policy objectively and keep a record. Late arrivals are never deducted from pay.

Who sees it.The person, their direct manager (count, notices and reminders of their team), People & Culture, Legal and Executive Management, each to the extent required; every view by a third party is logged.

Health data. Giving an illness or a medical appointment as the reason for a notice, and providing a prescription or a sick-leave certificate, requires your express consent, given by accepting this version of the notice; without it, the platform does not offer those reasons. The health reason and its support are seen only by the person and People & Culture: the direct manager receives the notice without the reason. No diagnoses are requested.

Retention. Notices, reminders and follow-up records are kept during employment and for the period set by Legal afterwards (TO BE DEFINED). The person can see their history in My compliance and exercise their access, rectification, cancellation and objection rights through the channel in section 7. Text pending review by counsel.

5g. People joining the company: onboarding file, document reading, card and welcome kit

Before their first day, a person joining the company completes their onboarding file from a personal link. Nothing is stored or read until they accept this policy (or, if People helps them in person, until their signed acceptance is recorded).

Document reading with artificial intelligence. The ID (both sides of the INE or a passport), proof of address, birth certificate, tax certificate, bank statement and other onboarding documents are sent to Anthropic, PBC (United States), an artificial intelligence provider acting as a processor, only to read their data and prefill the form; the person confirms or corrects every field and, if the reading fails, People reviews the document manually. The provider does not use this information for its own purposes.

Corporate card.When the position includes a card, the issuing bank (a processor) receives the person’s work name, email and phone, never personal ones; the card stays blocked until it is handed over with its use policy.

Introduction to the team and welcome kit. The invitation only shows the name and position of the direct manager; once the person joins, their name and position are shared with their team. No photos. To prepare the welcome equipment and items, the size chosen by the person is recorded.

Onboarding that does not go ahead. If the onboarding is cancelled, documents and personal data are kept for the period the company sets with counsel (90 days by default) and are then deleted; only a record that the process existed remains. Text pending review by counsel.

5h. Contacts at educational institutions: quotes and acceptance records

When an educational institution receives a quote for our programs, we process the contact details of the people the institution registered with us (name, position, work email and phone) to send them the document and their personal response link. The quote contains no personal data of students.

Record of the response.If the institution accepts or declines the quote through the link, we record the name and position of the person responding, their declaration that they are authorized to respond on behalf of the institution, the date and time, the network address and browser used, the version of this notice and the fingerprint of the accepted document, as evidence of the institution’s decision. That record is kept for the period the company defines (TO BE DEFINED, validated with counsel) and is then deleted or anonymized. Accepting a quote expresses the institution’s interest; the program is formalized through the separately signed contract or agreement, to which its own notice applies.

5i. Families in sales follow-up and satisfaction survey to institutions

Source of the data.A family's data is provided by the student's parent or guardian (the student is a minor): directly to our account manager, or through the school's enrollment portal, which sends us its report (indirect source). A minor's data is always provided by the guardian; we do not collect it from the minor. When our account manager registers a family, they record —under their name, with date and time— that the person who provided the data stated they are the parent or guardian, the relationship, and how this notice was shown to them. A record without that evidence receives no outbound contact.

Data and single purpose.We process the guardian's name, phone and email, the student's name, the folio of their registration in the enrollment portal (not an identity document), the school, the program and the school year, for a single purpose and no secondary purposes: following up on the enrollment(up to three contacts with their date, the status of interest and, when the portal or our Collections area records a payment, marking the enrollment). The "enrolled" status is only set with a recorded payment and is never reverted. No health data is collected in this follow-up. Access to contact details is limited to staff with an express faculty and every lookup is logged; schools only receive aggregated counts, never for groups of fewer than five families. This also applies to families in other Latin American countries.

Processors. To run the platform we use hosting and database providers (Supabase and Vercel, with servers in the United States) and an email provider (Resend), acting as processors that do not use the data for their own purposes.

Retention. Data is kept for the school year of the program plus the additional period the company sets (TO BE DEFINED, validated with counsel); it is then anonymized. Duplicate records are flagged, not deleted, to preserve the record of their capture.

Your rights. The parent or guardian may exercise the rights of access, rectification, deletion and objection, or revoke consent, through the contact in section 7. The request is logged with its receipt date and response deadline and is resolved by our Legal area. While an objection, deletion or revocation is being resolved, the family is not contacted again. When deletion is granted, every copy is anonymized (the family record, the payments linked to its folio, surveys and archived documents), and an encrypted fingerprint is kept so the data is not registered again even if a source brings it back.

Satisfaction survey to institutions.We may send the contact your institution registered with us a personal single-use link to rate your experience with the program from 0 to 10 and leave an optional comment. We record the rating, the comment, the contact's name and email, the date and time, the network address and the browser as evidence of the answer; the link expires within the period the company sets and cannot be used twice. Ratings are used in aggregate by region or country to measure the health of the relationship with institutions and are kept for the same period as the record in section 5h. You may ask not to receive it through the contact in section 7. Section updated October 30, 2026; wording pending review by counsel.

5j. Families who register for virtual demonstrations

Section pending validation by counsel.

When a parent or guardian registers for a virtual demonstrationof our programs from the link shared by the school, we process their name, email and phone number, and the student’s first name and grade (the student’s last name is optional). The minor’s information is provided by their parent or guardian, who states that they hold that role. We do not collect health or other sensitive data.

Main purpose: giving you access to the demonstration (sending the session link and, once the company enables them, its reminders) and recording attendance. Separate, optional marketing purpose: sending you information about our programs, only if you check the corresponding box, which is unchecked by default; you may withdraw at any time with the unsubscribe link or by exercising your rights. Declining does not prevent you from attending the demonstration.

Processors: our corporate email and calendar provider (Google Workspace), our email delivery provider (Resend), our database and storage provider (Supabase) and our platform hosting provider (Vercel). Retention: the registration is kept for the period set by the company on the platform and then anonymized. While the registration is active we also keep the network address and browser used to register; both are erased when it is anonymized. The record that you accepted this notice (date and version) is kept as evidence. You may exercise your rights as described in section 7; if you ask us to delete your data, your registration is anonymized and your email is not captured again.

5k. Business partners, phone calls, group onboarding, sales assistant and travel requests for sales routes

Partner portal. If you represent a business partner with an account in the partner portal, we process your name, your email and the activity you record (requests, manual downloads, date and time, network address and browser) in order to manage the business relationship with your partner account. We keep a record that you accepted this notice (version, date, network address and browser). If a request includes the details of a school contact person (name, email and phone), you confirm you are authorized to share them; that person is treated as described for school and institution contacts, including their privacy rights, and if they already exercised them, their details are not captured. The school, opportunity and quote information shown in the portal is confidential to the company. A deactivated access is kept for the period set by the company and then removed.

Phone calls. When an account manager makes or receives a call through the company phone system —with a school contact, a parent or guardian, or anyone else, even if they are not registered in the platform— we record the number, date and time, duration, who answered and the link to the recording kept by the phone system provider; the platform does not download or copy the recording and every time someone opens it is logged. The phone system announces the recording at the start of each call, and the platform does not record calls until Legal confirms that announcement. The phone system provider acts as a processor. Call records are kept for the period set by the company; technical notices sent by the phone system that the platform could not match are kept without the full number or the recording, unless the company set a period to reprocess them: in that case they are kept in full only for that period. If you asked not to be contacted, the platform will not dial your number; if you request deletion, the number is reduced to its last four digits, the link to the recording is removed and the provider is asked to delete it.

Group onboarding.When a won group is handed over, we record what the sales operations team needs: the school’s WhatsApp group link, the presentations and, if a banner is requested, the name, mobile number and delivery addressof the person who receives it. The banner details are only available to Operations, who ships it, the person who entered the onboarding and staff authorized to view personal data; they are not included in the PDF file or in the notices. This privacy notice, published on the company website, is how the person receiving the banner is informed. The onboarding notice (folio, group, school, account manager, program, travel date, estimated students and presentations) is sent by email and to Google Chat spaces that only include people from the company’s corporate domain; the corporate email and messaging provider (Google Workspace) acts as a processor. If the person who receives the banner requests deletion, their details are removed from the onboarding record and its file is regenerated without them; notices already sent cannot be recalled.

Sales assistant. The assistant answers with documents uploaded by the company (masterfiles, operations and policies), which are declared free of student, parent and third-party data and stored without personal data or prices. The question is stripped of personal data before it is sent to the artificial intelligence provider, which acts as a processor, and it does not include the name of the person asking. Queries are kept for the period set by the company.

Flight and hotel requests for sales routes. To book the trip of an authorized sales route we process the legal name, date of birth, passport number and expiration date, and mobile number of the traveler; when a team member travels, the passport is taken from their HR file and anything they enter is proposed to that file. The traveler and Operations (who books) or users authorized to view sensitive data see them in full, with every access logged; everyone else sees them masked. The email notice only carries the link to the record. The data is shared with the airline, agency or hotel providing the service, as necessary to perform it. After the trip it is kept for the period set by the company (in months, from the return date); it is then masked and the PDF file is deleted. Processorsfor this section: the phone system provider, the corporate email, calendar and messaging provider (Google Workspace), the email delivery provider (Resend), the database and storage provider (Supabase), the platform hosting provider (Vercel) and the sales assistant’s artificial intelligence provider; data may be stored outside Mexico under each provider’s contractual safeguards. Section updated on November 1, 2026; wording pending review by counsel.

6. Security and retention

We maintain administrative, technical and physical safeguards, including encryption in transit, role-based access controls, PIN-protected electronic signatures, restricted-access document storage and audit logs. We retain personal information for as long as needed for the purposes described above and as required by applicable legal, tax and accounting obligations, after which it is deleted or anonymized.

7. Your rights and choices

Depending on your state of residence (including under the Delaware Personal Data Privacy Act and similar state laws), you may have the right to know what personal information we hold about you, to access a copy of it, to correct inaccuracies, to request deletion, and to opt out of certain processing. Regardless of where you live, we extend these choices to all our users: contact us at enrique@ikaneducation.co.uk and we will verify your identity and respond within the timeframes required by applicable law. We will not discriminate against you for exercising your rights. If we deny a request, you may appeal by replying to our decision, and you may also contact your state Attorney General.

8. International transfers

IKAN operates in the United States and Mexico. Your information may be processed in either country by IKAN and by the service providers described above, always subject to the safeguards of this Policy.

For team members, our corporate email and calendar provider (Google Workspace) acts as a processor: it receives the company calendar events (days off, company events, approved absences without their reason and, unless you opt out, birthdays and work anniversaries) that the platform copies into each team member's corporate calendar. This is a disclosure to a service provider, not a sale or transfer; the data may be stored outside your country under the provider's contractual safeguards.

9. Cookies

The platform uses only strictly necessary cookies to keep your session active and secure. We do not use third-party advertising cookies.

Sales and outreach emails may include a one-pixel image and tracking links to learn whether they were opened and which links were clicked (section 3). These are not browser cookies or third-party advertising, and you may object to them as described in section 3. Text pending validation by counsel.

9 bis. Personal wealth (single-owner vault)

The “Personal wealth” module is a strictly personal space for the user who activates it (the owner). The data the owner records (assets, liabilities, accounts, transactions, loans and decisions) is processed only for the owner’s own use; the company has no access to its content and no other platform user can open it. Data that identifies accounts, people or merchants is stored encrypted. Processors: Supabase and Vercel (infrastructure), Plaid and Interactive Brokers (read-only connections the owner activates), an AI provider (aggregated figures only for the board and, with prior consent, statement transcription) and Resend (emails to the owner). Acceptance of these terms is recorded with the current version of this Policy. Retention period: to be defined by the owner; every access is logged in an append-only record.

Asset documents (section updated on October 26, 2026, vault version 2026-10-26). If the owner attaches deeds, appraisals, insurance policies, invoices, contracts or account statements to record an asset, the COMPLETE document is sent to Anthropic, PBC (United States), an artificial intelligence provider acting as a processor, only to read it and propose the asset’s data; this processing takes place outside Mexico and requires a separate consent, distinct from the statement consent, granted once and recorded with its version. These documents may contain personal data of third parties (co-owners, notaries, creditors, insurers): the platform asks the provider not to transcribe them, omits them from quotations and stores the reading and the file name encrypted, only inside the owner’s vault, with no access by the company. The owner may withdraw the consent in the vault settings and withdraw each document with their PIN: the file and its reading are deleted, while the file fingerprint and the log are kept as evidence. Text pending review by counsel.

10. Changes to this Policy

We may update this Policy to reflect legal or service changes. Updates will be posted on this page (www.ikanglobal.com/privacy) with a new “Last updated” date.

11. Contact us

IKAN EXPERIENCE LLC · Attn: Luis Enrique Castillo Fucugauchi (Privacy Contact) · 2852 N. Cicero Ave., Chicago, IL 60641, United States · enrique@ikaneducation.co.uk