Privacy Policy

Effective Date: January 1, 2025
Last Updated: August 15, 2025

1. Information We Collect

We collect personal information through the following channels and for the following purposes:

Learner Enrollment & Assessment Data

When you enroll in a Thrive program, we collect your name, date of birth, mailing address, phone number, email address, preferred language, self-reported educational history, and employment status. During the intake assessment process, we generate diagnostic test scores (TABE, CASAS, BEST Plus) that indicate your current academic skill levels. Throughout your enrollment, we maintain records of your attendance, class participation, assessment results, and program completion status. This data is collected because it is required by our federal and state funders (WIOA Title II, NC Community College System) to document program outcomes and demonstrate the effectiveness of publicly funded adult education services.

Website Usage Data

When you visit thrivelearningcommunity.org, our web server may automatically collect standard technical information including your IP address, browser type, operating system, referring URL, pages visited, and time spent on each page. This data is collected through server access logs and is used solely for website performance monitoring and aggregate traffic analysis. We do not use third-party behavioral tracking cookies, retargeting pixels, or advertising networks on this website.

Volunteer & Donor Information

When you apply to volunteer, we collect your name, contact information, and background check authorization. When you make a donation, we collect your name, contact information, and payment method details. Payment processing is handled by our PCI-compliant third-party payment processor; Thrive does not store credit card numbers or bank account details on our own systems.

Contact Form & Email Communications

When you submit a message through our website contact form or email us directly, we collect the information you provide (name, email, message content) for the sole purpose of responding to your inquiry.

2. FERPA Compliance & Learner Data Rights

As an educational institution, Thrive Learning Community is subject to the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g. Under FERPA, enrolled learners (who are adults, since our minimum enrollment age is 18) have the following rights regarding their educational records:

• Right to Inspect: You have the right to review your educational records within 45 days of submitting a written request to the Director of Instruction.
• Right to Amend: You have the right to request correction of records you believe to be inaccurate or misleading.
• Right to Consent: We will not disclose personally identifiable information from your educational records to third parties without your written consent, except as permitted by FERPA (e.g., to authorized federal and state education officials for audit and compliance purposes).
• Right to File a Complaint: You have the right to file a complaint with the U.S. Department of Education regarding alleged FERPA violations.

3. How We Use Your Information

We use the personal information we collect for the following purposes and no others:

• To administer enrollment, placement, instruction, and assessment within our educational programs
• To comply with federal and state reporting requirements under WIOA Title II and the NC Adult Education and Family Literacy Act
• To communicate with learners about schedules, program updates, and institutional announcements
• To process volunteer applications and conduct background checks
• To process and acknowledge charitable donations
• To respond to inquiries submitted through our website or email
• To monitor website performance and improve user experience
• To produce aggregate, de-identified statistical reports about program outcomes for grant applications, annual reports, and public accountability

4. We Never Sell Your Data

Thrive Learning Community has never sold, rented, leased, or exchanged personal information about our learners, volunteers, donors, or website visitors to any third party for commercial, marketing, or any other purpose. We have no intention of ever doing so. This is an unconditional, organizational commitment. Your data is used exclusively for the educational and operational purposes described in this policy.

5. Data Sharing & Third-Party Disclosures

We share personal information only with the following categories of recipients, and only to the minimum extent necessary for the stated purposes:

• Federal and State Education Agencies: Aggregate and individual-level learner outcome data is reported to the NC Community College System and the U.S. Department of Education as required by WIOA Title II. This reporting is mandated by federal law and is a condition of our grant funding.
• Background Check Provider: Volunteer applicant information is shared with our contracted background check vendor for criminal history screening, as required by our child safety and facility access policies.
• Payment Processor: Donor payment information is processed by our PCI-compliant third-party payment vendor. We do not retain payment card data.
• Legal Obligations: We may disclose information when required by law, court order, or legal process.

We do not share personal information with marketing companies, data brokers, advertising networks, social media platforms, or any commercial entity.

6. Data Security

We implement administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction. Learner records are stored in a password-protected, encrypted student information system with role-based access controls. Physical records are maintained in locked file cabinets within secured office spaces. Electronic communications containing personal data are transmitted over encrypted connections. Staff members receive annual training on data privacy, FERPA compliance, and information security best practices. While no system can guarantee absolute security, we continuously evaluate and improve our security measures in accordance with nonprofit information security standards.

7. Data Retention

Learner educational records are retained for a minimum of seven years following the learner's last date of enrollment, consistent with federal adult education recordkeeping requirements and IRS document retention guidelines for tax-exempt organizations. After the retention period, records are securely destroyed through cross-cut shredding (physical documents) or certified data wiping (electronic records). Donor records are retained for the minimum period required by IRS regulations for charitable contribution documentation. Website usage logs are retained for 12 months and then automatically purged.

8. CCPA & State Privacy Rights

While Thrive Learning Community is headquartered in North Carolina, we respect the data privacy rights of all individuals. If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information, including the right to know what information we collect, the right to delete your information, and the right to opt out of the sale of personal information. As stated above, we never sell personal information, so there is nothing to opt out of. For any CCPA-related requests, contact our Privacy Officer at privacy@thrivelearningcommunity.org.

9. Children's Privacy

Our educational programs are designed for adults ages 18 and older. Our website is not directed at children under the age of 13. We do not knowingly collect personal information from children. Our on-site childcare service collects minimal information (child's first name, age, parent/guardian name, emergency contact, and any allergies) solely for the purpose of providing safe childcare during class sessions. This information is not stored electronically and is destroyed at the end of each program semester.

10. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, applicable laws, or operational requirements. Material changes will be communicated to enrolled learners via email and posted on this page with an updated "Last Updated" date. We encourage you to review this policy regularly.

11. Contact Our Privacy Officer

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or have a privacy-related concern, please contact:

Privacy Officer
Thrive Learning Community, Inc.
1240 Ridgewood Boulevard, Suite 305
Raleigh, NC 27604
Email: privacy@thrivelearningcommunity.org
Phone: (919) 555-0237