Privacy Policy

Exam Preparation Academy (EPA)
A Division of Global Human Resources Development Limited
Effective Date: February 1, 2025
Last Updated: February 1, 2026

1. Introduction

Exam Preparation Academy (“EPA,” “we,” “us,” or “our”) respects privacy as a matter of trust, not merely compliance. This Privacy Policy explains how we collect, use, store, disclose, protect, and otherwise process personal information through our website, forms, learning platforms, communication channels, sessions, workshops, and related services.

EPA provides academic and educational support services, including Academic Research & Scholarly Writing support, tutoring, SBA support, professional development, and corporate workforce education. Because our users may include school-aged learners, university students, working adults, and corporate participants, the information we handle can vary in sensitivity and context. We therefore aim to collect only what we reasonably need, use it for clear purposes, and protect it with appropriate administrative, technical, and organizational safeguards.

By using the EPA website or services, you acknowledge this Privacy Policy. If you do not agree with it, you should not use the website or submit personal information to EPA.

2. Who We Are

The data controller for information collected through the EPA website and services is:

Exam Preparation Academy (EPA)
A Division of Global Human Resources Development Limited
service@epa.globalhrd.net

Where required by law, EPA may identify a Data Protection Officer, privacy contact, or other designated compliance contact for data protection matters.

3. Information We Collect

EPA may collect personal information directly from you, from a parent or guardian acting on behalf of a learner, from a corporate client, from a referral source authorized to share your details, or automatically through website technologies.

The information we collect may include your name, email address, telephone number, billing address, school or employer name, grade level or study level, subject area, academic needs, training interests, scheduling preferences, emergency contact information where appropriate, communications with EPA, payment confirmations, attendance records, learning progress information, and any documents you voluntarily submit for support.

For academic services, this may also include assignment prompts, drafts, class outlines, rubrics, reading lists, resumes, reflective statements, SBA materials, or other content you choose to provide. For workforce education, it may include participant rosters, job roles, training objectives, attendance logs, feedback forms, and completion records.

We may also collect device and usage data, such as IP address, browser type, pages visited, referral source, date and time of visit, cookie identifiers, and similar analytics information.

We do not ask users to provide more personal information than is reasonably necessary for the service being delivered.

4. Information Relating to Minors

EPA may serve minors, especially in tutoring and SBA support contexts. Where a learner is under 18, EPA may require a parent or legal guardian to make the booking, provide instructions, manage payment, and consent to the collection and use of the learner’s information as appropriate.

EPA does not knowingly collect personal information online from a child under 13 without the involvement and consent of a parent or legal guardian where applicable law requires that protection. If we learn that information has been submitted in a manner that does not meet our requirements, we may suspend the account or delete the information, subject to legal and operational obligations. FTC guidance continues to require notice and verifiable parental consent where covered online services collect personal information from children under 13.

5. How We Collect Information

We collect information in several ways. Sometimes you provide it directly by filling out a website form, booking a session, requesting a quotation, registering for a class, sending a message, submitting an academic document, completing a survey, or making a payment.

Sometimes information is collected automatically through cookies, analytics tools, server logs, and similar website technologies.

In some cases, a parent, guardian, employer, or corporate client may provide information on your behalf, especially where they are arranging a service for you.

6. Why We Use Personal Information

EPA may use personal information to:

provide and manage our services;
evaluate inquiries and determine service suitability;
schedule sessions, classes, meetings, and training engagements;
communicate with learners, parents, guardians, and clients;
prepare lessons, training materials, and academic support plans;
review submitted documents and provide feedback or instruction;
process payments and maintain financial records;
verify identity where reasonably necessary;
monitor service quality and improve our programs;
send administrative notices, reminders, invoices, receipts, and updates;
respond to complaints, support requests, and disputes;
protect EPA, its staff, users, and systems from fraud, misuse, or legal risk;
comply with legal, regulatory, tax, recordkeeping, and reporting obligations.

Where we send promotional messages, we will do so in line with applicable law and provide a practical way to opt out.

7. Legal and Operational Basis for Processing

EPA processes personal information on one or more of the following grounds as appropriate to the context: your consent, the need to take steps at your request before entering into a contract, the need to perform a contract with you, compliance with legal obligations, the protection of legitimate educational or business interests, and the protection of the rights, safety, and integrity of EPA, its clients, and others.

Current official guidance in Jamaica emphasizes fairness, lawfulness, purpose limitation, data minimization, accuracy, and storage limits, while EU guidance likewise emphasizes lawful, fair, transparent, purpose-specific, and limited processing.

8. Cookies and Similar Technologies

EPA may use cookies, pixels, session identifiers, analytics tools, and similar technologies to keep the website functioning, remember preferences, understand traffic patterns, improve usability, measure campaign performance, and support website security.

You can usually control cookies through your browser settings. Disabling some cookies may affect website performance or reduce functionality.

Where required, EPA will provide a cookie notice or consent mechanism for non-essential cookies.

9. Payment Information

Payments may be processed by third-party payment providers rather than directly by EPA. EPA may receive limited payment-related information such as confirmation of payment, partial card details, billing name, transaction identifiers, and payment status. We do not represent that we store full card numbers unless expressly stated and securely managed.

Clients should review the privacy and security terms of any payment processor used at checkout, as those providers process payment data under their own policies and compliance regimes.

10. How We Share Information

EPA does not sell personal information. We may disclose personal information only where reasonably necessary, including to:

staff, tutors, consultants, facilitators, and administrators who need the information to perform their duties;
technology vendors, cloud storage providers, scheduling tools, payment processors, email services, website hosts, and learning management systems supporting our operations;
corporate clients, but only to the extent appropriate for commissioned training, attendance records, progress summaries, or agreed reporting;
professional advisers, insurers, auditors, and legal counsel where necessary;
regulators, law enforcement, courts, or public authorities where required by law or where disclosure is reasonably necessary to establish, exercise, or defend legal rights.

We expect service providers handling information on our behalf to maintain confidentiality and appropriate security.

11. International Transfers

EPA may use service providers or technology platforms that store or process information outside the country where the user is located. Where cross-border transfers occur, EPA aims to use reasonable contractual, technical, and organizational safeguards appropriate to the nature of the data and the applicable legal framework.

EU guidance notes that transfers of EU personal data outside the EU require recognized safeguards.

12. Data Retention

EPA keeps personal information only for as long as it is reasonably necessary for the purpose for which it was collected, for service continuity, for dispute resolution, for legitimate business records, and for compliance with legal, tax, accounting, and regulatory obligations.

Retention periods may vary depending on the type of data. Inquiry records may be kept for a shorter period than active client files. Financial records may be retained longer where required for accounting or tax purposes. Learning records, attendance logs, or corporate training records may be kept long enough to support service follow-up, quality review, and reporting obligations.

Jamaica’s official data protection guidance expressly notes that personal data should not be kept longer than necessary and that retention should be addressed clearly in a privacy notice.

13. Data Security

EPA uses reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, loss, or disclosure. These measures may include controlled access, password protection, limited staff permissions, secure platforms, contractual confidentiality measures, secure payment tools, and internal handling procedures.

No online system is absolutely secure, and EPA cannot promise perfect security. Still, we take privacy incidents seriously and will respond in line with our legal obligations and operational responsibilities.

Official Jamaican guidance states that data controllers are expected to report certain security breaches and contraventions promptly, including reports within 72 hours after awareness in the relevant context.

14. Your Rights

Subject to applicable law and lawful limitations, you may have the right to request access to personal information we hold about you, request correction of inaccurate or incomplete information, request deletion in appropriate circumstances, object to certain processing, request restriction of processing, withdraw consent where consent is the basis of processing, and request a copy of data you have provided where such a right applies.

EPA will review requests in good faith and respond within a reasonable period, subject to identity verification and any lawful exceptions.

Official Jamaican materials state that data subjects have rights that include access, correction, and deletion in appropriate circumstances.

15. Marketing Communications

If you opt in to receive updates, promotions, newsletters, or service announcements, EPA may send communications about programs, workshops, offers, or new services. You may opt out of marketing communications at any time by using the unsubscribe link where available or by contacting us directly.

Operational messages relating to bookings, payments, changes, security, or service delivery may still be sent even if you opt out of promotional messages.

16. Academic Materials and Confidentiality

EPA understands that submitted academic work, drafts, personal statements, CVs, and related learning materials may be sensitive. We handle these materials for service delivery, quality review, supervision, and recordkeeping. We do not publish or disclose client academic materials publicly without permission, except where required by law or necessary to protect legal rights.

If EPA uses anonymized excerpts for staff training or quality improvement, it will do so only in a manner designed to avoid identifying the learner where reasonable and lawful.

17. Third-Party Websites and Embedded Tools

The EPA website may contain links to third-party websites, plug-ins, payment pages, scheduling tools, or educational platforms. EPA is not responsible for the privacy practices of those third parties. Users should review the privacy notices of any external services they use through or after leaving the EPA website.

18. Complaints and Regulatory Contact

If you have a privacy concern, we encourage you to contact EPA first so we can try to resolve it promptly and fairly. If you believe your rights have been violated, you may also have the right to complain to the appropriate regulator or supervisory authority.

For Jamaica-based processing, the Office of the Information Commissioner is the public authority overseeing compliance with the Data Protection Act.

19. Changes to This Privacy Policy

EPA may revise this Privacy Policy from time to time to reflect legal developments, operational changes, technological updates, or service expansion. The updated version will be posted on the website with a revised effective date. Continued use of the website or services after the updated version becomes effective constitutes acceptance of the revised policy to the extent permitted by law.

20. Contact Us

For privacy questions, requests, or complaints, please contact:

Exam Preparation Academy (EPA)
A Division of Global Human Resources Development Limited
service@epa.globalhrd.net