Locks of Love (“LOL”) has created this policy to demonstrate our commitment to privacy. The following statement explains our information-gathering and dissemination practices for our web site at www.locksoflove.org, or information that is received directly to the organization. This policy may change from time to time, so please check back periodically. Throughout this policy, “we,” “us,” and “our” will mean LOL. This policy does not apply to the practices of persons or entities that LOL does not control, manage or employ.
How does LOL protect my information?
In the event that we collect your credit card information, we will additionally utilize software to encrypt your credit card information you input. Despite use of these safeguards, there are inherent risks in transmission of electronic information. We cannot guarantee and do not represent that your information will always be secure from unauthorized access.
We also may use a managed hosting provider and/or other subcontractors to assist us with the provision and maintenance of our site. If we do, we will impose on such provider confidentiality obligations for the treatment of information.
What information does LOL collect from me as an end user?
You can browse our Sites without telling us who you are or giving us any personally identifiable information about yourself. When you interact with us through your computer, our website does record certain non-identifying site usage data, such as the number of hits and visits to our Sites.
How does LOL use my information?
LOL does not sell, share or disclose personal information with persons or entities not affiliated with or employed by LOL except with your consent or when we reasonably determine it is necessary to do so in order to comply with the law or protect the safety, property or legal rights of LOL or others. This includes information being communicated through our website or sent to us directly.
What about the privacy policies of sites linking to the Sites or to which the Sites link?
We provide links on our Sites to other web sites provided by third parties. In addition, some users access our Sites via another site or a link on another site. We have no control over the sites that link to our Sites or to which our Sites link. We are not responsible for the privacy practices or the content of any site other than our Sites. The existence of a link between our Sites and other third party sites does not imply an endorsement of these other sites. We are not responsible for the content of such other sites, nor for the treatment of personal information you might provide while visiting such other sites.
This Policy prohibits retaliation against an employee of Locks of Love (referred to here as a “Whistleblower”) who reports an activity that the Whistleblower reasonably believes to be illegal, fraudulent or dishonest conduct involving Locks of Love’s Board of Directors, employees or resources.
All members of Locks of Love’s Organization are responsible for reporting fraudulent, dishonest, or illegal conduct involving Locks of Love board members, officers, employees, volunteers or resources. Such reporting should be made acceding to the Locks of Love policy or applicable law. If a situation is not addressed by existing Locks of Love policy or if the appropriate manager or supervisor fails to act on such a report according to Locks of Love’s Policy, a Whistleblower may report the matter to the General Manager. If the employee does not feel comfortable reporting the information to the General Manager, he or she is expected to report the information to the Board President.
Locks of Love employees may not retaliate against a Whistleblower with the intent or effect of adversely affecting the terms or conditions of employment. If the Whistleblower has made a confidential report, Locks of Love will exercise reasonable care to keep the Whistleblower’s identity and report confidential, unless (1) the Whistleblower agrees to the disclosure; (2) disclosure is necessary to allow Locks of Love or law enforcement officials to investigate or respond effectively to the report; (3) disclosure is required by law; or (4) the person(s) accused of violations by the Whistleblower are entitled to the information as a matter of institutional due process in disciplinary proceedings.
Whistleblowers who reasonably believe that they have been retaliated against by a Locks of Love employee may file a written complaint to the General Manager or Board President. If retaliation is proven, the retaliating employee(s) are subject to appropriate disciplinary actions or remedies provided in law or equity, including immediate termination. The prohibition against retaliation is not intended to prohibit managers or supervisors from exercising legitimate supervisory responsibilities in the usual scope of their duties and based on Locks of Love’s workplace expectations, other Locks of Love policies and valid performance-related factors.
Locks of Love is committed to equal opportunity for all persons without regard to sex, age, race, color, religion, creed, national origin, marital status, disability or sexual orientation. It is the policy of Locks of Love to comply with all federal, state and local laws and regulations regarding equal opportunity. In keeping with that policy, Locks of Love is committed to maintaining a work environment that is free of unlawful discrimination and harassment. Accordingly, Locks of Love will not tolerate unlawful discrimination against or harassment of any of our employees or others present at our facilities by anyone, including any supervisor, co-worker, vendor, client, or customer of Locks of Love.
Unlawful Discrimination and Harassment:
Unlawful discrimination includes treating someone less well in opportunities for work, promotions, shifts, overtime or other conditions of employment because of his or her race, national origin, sex, age, religion, disability or other protected attribute. Harassment consists of unwelcome or unwanted conduct, whether verbal, physical or visual, that is based upon a person’s protected status. Examples of unlawful harassment include words, gestures, stories, jokes or nicknames that are derogatory, demeaning or insulting to a person based upon his or her race, national origin, sex, disability, age, religion or other protected attribute.
Sexual harassment deserves special mention. Sexual harassment consists of:
Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, or offensive work environment.
Examples of sexual harassment may include, but are not limited to the
following conduct by any employee, whether male or female:
Unwanted sexual advances or propositions, offering employment benefits in exchange for sexual favors, making or threatening reprisals after a negative response to sexual advances, sexual innuendo, suggestive comments, sexually oriented “kidding” or “teasing,” jokes about gender-specific traits, making sexual gestures or comments, displaying sexually suggestive objects, pictures, cartoons or postures, impeding or blocking another’s movement, physical contact, such as patting, pinching, or brushing against another’s body, and continued requests for a date after a rejection.
The purposes of this document retention policy are for Locks of Love, (the “Organization”) to enhance compliance with the Sarbanes-Oxley Act and to promote the proper treatment of corporate records of the Organization.
Section 1. General Guidelines
Records should not be kept if they are no longer needed for the operation of the business or required by law. Unnecessary records should be eliminated from the files. The cost of maintaining records is an expense which can grow unreasonably if good housekeeping is not performed. A mass of records also makes it more difficult to find pertinent records.
From time to time, the Organization may establish retention or destruction policies or schedules for specific categories of records in order to ensure legal compliance, and also to accomplish other objectives, such as preserving intellectual property and cost management. Several categories of documents that warrant special consideration are identified below. While minimum retention periods are established, the retention of the documents identified below and of documents not included in the identified categories should be determined primarily by the application of the general guidelines affecting document retention, as well as the exception for litigation relevant documents and any other pertinent factors.
Section 2. Exception for Litigation Relevant Documents The Organization expects all officers, directors, and employees to comply fully with any published records retention or destruction policies and schedules, provided that all officers, directors, and employees should note the following general exception to any stated destruction schedule: If you believe, or the Organization informs you, that Organization records are relevant to litigation, or potential litigation (i.e., a dispute that could result in litigation), then you must preserve those records until it is determined that the records are no longer needed. That exception supersedes any previously or subsequently established destruction schedule for those records.
Section 3. Minimum Retention Periods for Specific Categories
(a) Organizational Documents. Organizational records include the Organization’s articles of incorporation, by-laws and IRS Form 1023, Application for Exemption Organizational records should be retained permanently. IRS regulations require that the Form 1023 be available for public inspection upon request.
(b) Tax Records. Tax records include, but may not be limited to, documents concerning payroll, expenses, proof of contributions made by donors, accounting procedures, and other documents concerning the Organization’s revenues. Tax records should be retained for at least seven years from the date of filing the applicable return.
(c) Employment Records/Personnel Records. State and federal statutes require the Organization to keep certain recruitment, employment and personnel information. The Organization should also keep personnel files that reflect performance reviews and any complaints brought against the Organization or individual employees under applicable state and federal statutes. The Organization should also keep in the employee’s personnel file all final memoranda and correspondence reflecting performance reviews and actions taken by or against personnel. Employment applications should be retained for three years. Retirement and pension records should be kept permanently. Other employment and personnel records should be retained for seven years.
(d) Board and Board Committee Materials. Meeting minutes should be retained in perpetuity in the Organization’s minute book. A clean copy of all other Board and Board Committee materials should be kept for no less than three years by the Organization.
(e) Press Releases/Public Filings. The Organization should retain permanent copies of all press releases and publicly filed documents under the theory that the Organization should have its own copy to test the accuracy of any document a member of the public can theoretically produce against the Organization.
(f) Legal Files. Legal counsel should be consulted to determine the retention period of particular documents, but legal documents should generally be maintained for a period of ten years.
(g) Marketing and Sales Documents. The Organization should keep final copies of marketing and sales documents for the same period of time it keeps other corporate files, generally three years. An exception to the three-year policy may be sales invoices, contracts, leases, licenses, and other legal documentation. These documents should be kept for at least three years beyond the life of the agreement.
(h) Development/Intellectual Property and Trade Secrets. Development documents are often subject to intellectual property protection in their final form (e.g., patents and copyrights). The documents detailing the development process are often also of value to the Organization and are protected as a trade secret where the Organization:
- (i) derives independent economic value from the secrecy of the information; and
- (ii) has taken affirmative steps to keep the information confidential.
The Organization should keep all documents designated as containing trade secret information for at least the life of the trade secret.
(i)Contracts. Final, execution copies of all contracts entered into by the Organization should be retained. The Organization should retain copies of the final contracts for at least three years beyond the life of the agreement, and longer in the case of publicly filed contracts. Correspondence. Unless correspondence falls under another category listed elsewhere in this policy, correspondence should generally be saved for two years.
(j)Banking and Accounting. Accounts payable ledgers and schedules should be kept for seven years. Bank reconciliations, bank statements, deposit slips and checks (unless for important payments and purchases) should be kept for three years. Any inventories of products, materials, and supplies and any invoices should be kept for seven years. Insurance. Expired insurance policies, insurance records, accident reports, claims, etc. should be kept permanently.
(k) Audit Records. External audit reports should be kept permanently. Internal audit reports should be kept for three years.
Section 4. Electronic Mail E-mail that needs to be saved should be either:
- (i) printed in hard copy and kept in the appropriate file; or
- (ii) downloaded to a computer file and kept electronically or on disk as a separate file.
The retention period depends upon the subject matter of the e-mail, as covered elsewhere in this policy.
By conventional mail:
Locks of Love
234 Southern Blvd.
West Palm Beach, FL 33405
By telephone: (561) 833-7332