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Privacy Policy

Privacy Policy for Lyfe Three, Inc.

At Lyfe Three, Inc., we respect your privacy and are committed to protecting the personal information of our students, families, supporters, donors, volunteers, and website visitors. This Privacy Policy explains what information we collect, how we use it, and the choices available to you.


Who We Are

Lyfe Three, Inc. is a nonprofit organization dedicated to empowering youth through education, expression, and empowerment by providing academic support, enrichment activities, social-emotional learning, STEAM programming, workforce development, family engagement, and cultural experiences.


Contact Information

Lyfe Three, Inc.
1046 Broad Street
New Bern, NC 28560
Phone: (252) 497-2206
Email: info@lyfethree.org


Information You Provide

When you interact with our website, register for programs, make a donation, subscribe to communications, or contact us, we may collect:

  • Name 
  • Email address 
  • Phone number 
  • Mailing address 
  • Student and parent/guardian information 
  • Student grades and progress
  • Donation information 
  • Volunteer application information 
  • Any information submitted through contact forms 


Information Collected Automatically

When you visit our website, certain information may be collected automatically, including:

  • IP address 
  • Browser type 
  • Device information 
  • Pages viewed 
  • Date and time of visits 
  • Referring website addresses 

This information helps us improve website performance and user experience.


How We Use Your Information

We may use information collected through our website to:

  • Respond to inquiries and requests 
  • Process donations 
  • Register participants for programs and events 
  • Communicate program updates and organizational news 
  • Send newsletters and fundraising communications 
  • Improve website functionality and user experience 
  • Evaluate program effectiveness 
  • Meet legal, reporting, and grant compliance requirements 


Student and Family Information

Information collected through program applications or enrollment forms is used solely for program administration, communication, safety, evaluation, and compliance with applicable funding requirements.

We do not sell or share student information for marketing purposes.


Cookies and Analytics

Our website may use cookies and similar technologies to:

  • Remember user preferences 
  • Monitor website traffic 
  • Analyze visitor behavior 
  • Improve website performance 

You may disable cookies through your browser settings; however, some website features may not function properly.


Third-Party Services

We may use trusted third-party providers for services such as:

  • Online donations 
  • Email communications 
  • Website hosting 
  • Analytics 

These providers have access only to the information necessary to perform their services and are expected to maintain appropriate security protections.


Information Sharing

Lyfe Three, Inc. does not sell, rent, or trade personal information.

We may disclose information:

  • When required by law 
  • To protect the safety of participants or others 
  • To comply with grant or regulatory reporting requirements 
  • To trusted service providers performing services on our behalf 


Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction.

While we strive to protect your information, no internet transmission or electronic storage method can be guaranteed to be 100% secure.


Children's Privacy

Protecting children's privacy is especially important to us.

Our website is not intended to collect personal information directly from children under the age of 13 without parental consent. Any student information collected through program registration is provided by a parent or legal guardian.


Email Communications

You may choose to receive newsletters, announcements, and updates from Lyfe Three, Inc.

You may unsubscribe from email communications at any time by clicking the unsubscribe link included in our emails or by contacting us directly.


Links to Other Websites

Our website may contain links to external websites. Lyfe Three, Inc. is not responsible for the privacy practices or content of third-party websites. We encourage visitors to review the privacy policies of any external sites they visit.


Your Rights

You may request to:

  • Access personal information we maintain about you 
  • Correct inaccurate information 
  • Remove your information from marketing communications 
  • Ask questions about our privacy practices 

To make a request, please contact us using the information listed above.


Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with an updated effective date.

Your continued use of the website after changes are posted constitutes acceptance of the revised policy.

Document retention policy

 The purpose of this Document Retention and Destruction Policy is to establish guidelines for the creation, maintenance, retention, storage, and destruction of records maintained by Lyfe Three, Inc. ("the Organization"). This policy is designed to:

  • Ensure compliance with federal, state, and local laws and regulations;
  • Meet grant and audit requirements;
  • Protect confidential information;
  • Preserve important organizational records;
  • Support efficient business operations; and
  • Reduce unnecessary storage costs and legal risks.

Scope

This policy applies to all records maintained by Lyfe Three, Inc., regardless of format, including:

  • Paper documents
  • Electronic files
  • Emails
  • Databases
  • Photographs and videos
  • Financial records
  • Personnel records
  • Grant documentation
  • Board records

This policy applies to employees, board members, volunteers, contractors, and consultants who create, receive, maintain, or dispose of organizational records.


General Retention Principles

  1. Records shall be maintained for the period required by law, regulation, contract, grant requirement, or organizational need.
  2. Records may be maintained in electronic or paper format.
  3. Electronic copies are acceptable when they accurately reproduce the original document and remain accessible for the required retention period.
  4. Records shall be stored securely and protected from unauthorized access, destruction, or alteration.

Record Retention Schedule

Permanent Records

The following records shall be retained permanently:

  • Articles of Incorporation
  • IRS Determination Letter
  • Bylaws and amendments
  • Board meeting minutes
  • Board committee minutes
  • Corporate resolutions
  • Organizational policies
  • Annual reports
  • Real estate records
  • Property deeds and titles
  • Major grant award documents
  • Historical program records deemed significant by the Board

Financial Records (7 Years)

The following records shall be retained for a minimum of seven (7) years:

  • General ledgers
  • Bank statements
  • Canceled checks
  • Deposit records
  • Accounts payable records
  • Accounts receivable records
  • Financial statements
  • Expense reports
  • Credit card statements
  • Tax filings
  • Audit reports
  • Procurement records
  • Vendor documentation
  • Supporting documentation for expenditures

Federal Grant Records (7 Years Minimum)

Records related to federal, state, and private grants shall be retained for at least seven (7) years after submission of the final expenditure report or grant closeout, unless a longer period is required by the funding agency.

Examples include:

  • Grant applications
  • Award notices
  • Budgets
  • Budget amendments
  • Reimbursement requests
  • Program reports
  • Attendance records
  • Student participation records
  • Evaluation reports
  • Monitoring reports
  • Procurement records
  • Supporting documentation for grant expenditures

Personnel Records (7 Years After Separation)

Personnel records shall be retained for at least seven (7) years following separation of employment:

  • Employment applications
  • Resumes
  • Personnel files
  • Performance evaluations
  • Payroll records
  • Time and effort certifications
  • Training records
  • Disciplinary records
  • Benefit records

Student and Program Records (7 Years)

The following records shall be retained for seven (7) years:

  • Enrollment forms
  • Attendance records
  • Parent communications
  • Academic progress records
  • Surveys
  • Incident reports
  • Transportation logs
  • Program participation records

Contracts and Legal Records

Contracts, leases, insurance policies, and legal agreements shall be retained for seven (7) years following expiration or termination.


Litigation Hold

If the Organization becomes aware of:

  • Pending litigation,
  • Threatened litigation,
  • Government investigations,
  • Audit findings,
  • Open records requests, or
  • Other legal actions, all destruction of relevant records shall immediately cease.

The Executive Director, Program Director, Board President, or legal counsel may issue a Litigation Hold Notice requiring records to be preserved beyond normal retention periods.


Electronic Records Management

Electronic records shall:

  • Be backed up regularly;
  • Be protected by passwords and security controls;
  • Remain accessible throughout the retention period;
  • Be securely deleted when eligible for destruction.

The Organization shall maintain reasonable safeguards against unauthorized access, cyber threats, and accidental loss.


Record Destruction Procedures

When records have met retention requirements and are not subject to a Litigation Hold:

Paper Records

Paper records shall be destroyed through:

  • Shredding
  • Secure document destruction services
  • Other methods that render the information unreadable

Electronic Records

Electronic records shall be:

  • Permanently deleted;
  • Removed from storage systems; or
  • Destroyed using secure deletion methods when appropriate.


Confidential Information

Special care shall be taken when destroying records containing:

  • Student information
  • Personnel information
  • Financial information
  • Social Security numbers
  • Medical information
  • Donor information
  • Grant-related data

Confidential records shall never be discarded in unsecured trash receptacles.


Responsibility

The Board of Directors has ultimate oversight responsibility for this policy.

The Program Director and Fiscal Officer are responsible for:

  • Implementing the policy;
  • Maintaining retention schedules;
  • Coordinating record destruction;
  • Ensuring compliance with grant requirements; and
  • Training staff regarding records management responsibilities.


Annual Review

This policy shall be reviewed annually by the Board of Directors and revised as necessary to ensure compliance with applicable laws, grant requirements, and nonprofit best practices.

Whistle blower policy

 Lyfe Three, Inc. is committed to maintaining the highest standards of integrity, accountability, ethical conduct, and compliance with all applicable federal, state, and local laws. This Whistleblower Policy provides a safe and confidential process for reporting suspected wrongdoing and protects individuals who report concerns in good faith from retaliation.


Who May Report Concerns

This policy applies to:

· Employees

· Board Members

· Volunteers

· Contractors and Consultants

· Vendors

· Parents and Guardians

· Program Participants

· Members of the Public


Reportable Concerns

Individuals are encouraged to report any suspected misconduct, including but not limited to:

· Fraud, theft, or embezzlement

· Misuse of organizational funds or assets

· Financial irregularities

· Conflicts of interest

· Violations of organizational policies

· Violations of federal, state, or local laws

· Violations of grant requirements

· Abuse of authority

· Harassment or discrimination

· Falsification of records or reports

· Threats to public health or safety

· Retaliation against a whistleblower


How to Report a Concern

Concerns may be reported to:

Board Chair
Lyfe Three, Inc.

Board Secretary
Lyfe Three, Inc.

Board Treasurer
Lyfe Three, Inc.

Program Director
Lyfe Three, Inc. (unless involved in the reported concern)

Reports may be submitted in writing, by email, by telephone, or in person.


Anonymous Reporting

Anonymous reports are accepted. While anonymous reports may limit the Organization’s ability to gather additional information, Lyfe Three, Inc. will review and investigate all credible concerns to the extent possible.


Investigation Process

Upon receiving a report:

1. The concern will be reviewed promptly.

2. A fair and impartial investigation will be conducted.

3. Confidentiality will be maintained to the extent possible.

4. Appropriate corrective action will be taken when warranted.

The Organization may engage legal counsel, auditors, or other professionals when necessary.


Protection Against Retaliation

Lyfe Three, Inc. prohibits retaliation against any individual who, in good faith:

· Reports a concern

· Participates in an investigation

· Provides information related to an investigation

Retaliation may result in disciplinary action up to and including termination of employment, removal from volunteer service, or removal from the Board of Directors.


Federal Grant Whistleblower Protections

As a recipient of federal grant funding, including funding administered through the 21st Century Community Learning Centers (21st CCLC) program, Lyfe Three, Inc. complies with federal whistleblower protections under 41 U.S.C. §4712 and 2 CFR §200.217.

Protected disclosures may include information regarding:

· Gross mismanagement of a federal grant

· Gross waste of federal funds

· Abuse of authority

· Violations of law, rule, or regulation related to a federal grant

· Substantial and specific dangers to public health or safety


Confidentiality

Lyfe Three, Inc. will maintain the confidentiality of reports and investigations to the extent permitted by law and consistent with a thorough investigation.


Record Retention

Whistleblower reports and investigation records will be maintained in accordance with the Organization’s Record Retention Policy and applicable federal grant requirements.


Good Faith Reporting

Individuals are expected to make reports honestly and in good faith. Reports made in good faith will be protected even if the allegations are not ultimately substantiated.

Knowingly false reports may result in disciplinary action.


 

ADDITIONAL FEDERAL WHISTLEBLOWER COMPLIANCE PROVISIONS

Federal Whistleblower Compliance

Lyfe Three, Inc. complies with all applicable federal whistleblower protection laws and regulations, including:

  • 41 U.S.C. §4712
  • 2 CFR §200.217
  • 41 U.S.C. §4304
  • 10 U.S.C. §4701
  • 10 U.S.C. §4310

These protections apply to employees working on, supporting, administering, or benefiting from federally funded grants and contracts.

In accordance with federal law, an employee shall not be discharged, demoted, suspended, threatened, harassed, or otherwise discriminated against as a reprisal for making a protected disclosure regarding a federal contract or grant.

Protected disclosures include information that the employee reasonably believes is evidence of:

  • Gross mismanagement of a federal contract or grant;
  • Gross waste of federal funds;
  • Abuse of authority relating to a federal contract or grant;
  • A substantial and specific danger to public health or safety; or
  • A violation of law, rule, or regulation related to a federal contract or grant.

Written Employee Notification

To comply with 2 CFR §200.217, Lyfe Three, Inc. shall provide written notice of whistleblower rights and protections to all employees.

Notification shall occur through one or more of the following methods:

  • Employee onboarding and orientation materials;
  • Employee handbook distribution;
  • Annual staff training;
  • Distribution of the Whistleblower Policy;
  • Internal staff communications; and
  • Posting of the policy on the organization's website and/or internal staff portal.

The Organization shall maintain documentation demonstrating that employees have received notice of these rights.


Questions

Questions regarding this policy may be directed to the Program Director or Board Chair of Lyfe Three, Inc.

  

Approved by the Board of Directors of Lyfe Three, Inc.

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