Privacy Policy

1. Information We Collect

Information you provide. When you submit a form, request pricing, apply as a media partner, join a waitlist, or contact us, we collect what you enter: name, company, title, email address, telephone number, and any message or notes; product or service interests, monthly volume, geographic interests, and similar campaign-fit details; for mortgage properties, an NMLS identifier; for media partner applications, business, traffic-source, and compliance information; and your consent selections.

Consent records. To evidence consent under the Telephone Consumer Protection Act and, where applicable, the Fair Credit Reporting Act, we record the exact text of each consent disclosure you agreed to, its version, the date and time you agreed, the page on which you agreed, your IP address, and your browser user agent.

Information collected automatically. When you visit our websites we collect your IP address, browser and device information, the pages you view, the page you landed on, the site that referred you, and campaign identifiers carried in the URL (for example utm_source, utm_medium, utm_campaign, utm_term, utm_content, gclid, fbclid, msclkid). We record the first such visit in your session and the most recent, so that we can attribute an inquiry to the campaign that produced it. We use cookies, local storage, and similar technologies for these purposes and for site function, security, and analytics.

Information from others. We may receive information about you from buyers and partners (for example, whether an inquiry was accepted), from service providers (for example, telephone number validation), and from publicly available sources.

2. How We Use Information

We use personal information to: route your inquiry to buyers, service providers, or partners who can respond to it; contact you about your inquiry by phone, text, and email, as permitted by law and by the consent you gave; evaluate whether an inquiry meets campaign, buyer, and compliance criteria; validate and enrich contact and attribute information; attribute inquiries to the campaigns and sources that produced them and pay partners accordingly; operate, secure, debug, and improve our websites and services; prevent fraud, invalid traffic, and abuse; maintain records of consent and honor opt-out requests; comply with legal obligations and enforce our agreements; and, with your consent where required, send marketing communications.

3. Selling and Sharing Personal Information

Loyalty LTD sells personal information as described in our California Privacy Notice. You may direct us not to sell your personal information at any time.

In the course of providing our services, we disclose the personal information you submit — and related consent and attribution records — to third parties for money or other valuable consideration. Under the California Consumer Privacy Act and similar laws, this is a sale of personal information. Recipients include buyers of leads and calls (such as home services contractors, mortgage lenders and brokers, debt relief providers, and insurance agencies and brokers), service providers acting on our behalf, and, where you selected one, the partner network named on the form.

We may also disclose identifiers and internet activity to advertising partners for cross-context behavioral advertising, which the CCPA calls sharing.

You may opt out of the sale and sharing of your personal information at any time through our Do Not Sell or Share My Personal Information page. Opting out stops future sales and sharing; it does not recall information already disclosed to a buyer who received it before your request, and it may mean we cannot route your inquiry.

We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.

• California Privacy Notice
• Do Not Sell or Share My Personal Information

4. Other Disclosures

We may disclose personal information to affiliates and subsidiaries of Loyalty LTD; to service providers who host, store, process, validate, transmit, or analyze data on our behalf, including cloud hosting, database, email delivery, telephony, and analytics providers; to professional advisors; to government agencies, regulators, courts, or law enforcement where required by law or legal process, or where we believe disclosure is necessary to protect rights, safety, or property; to prevent fraud or enforce our agreements; and to a successor in connection with a merger, acquisition, financing, or sale of assets.

5. Telephone and Text Communications

If you provide a telephone number and consent to be contacted, we and the buyers or partners to whom we route your inquiry may call or text you, including using automated technology, artificial or prerecorded voice, and SMS or MMS, as described in our TCPA Consent Disclosure. Consent is not a condition of purchase. You may revoke consent at any time by replying STOP to any text, by telling any representative during a call, or by contacting us at the address below. We retain consent and revocation records for at least five (5) years.

6. Cookies and Tracking

We use cookies, local and session storage, pixels, and similar technologies to operate the site, remember your preferences, secure our services, understand traffic, and attribute inquiries to campaigns. You can control cookies through your browser settings; disabling them may affect site function. We honor Global Privacy Control signals as an opt-out of sale and sharing where required by law.

7. Data Retention

We retain personal information for as long as needed to fulfill the purposes described in this Policy, to comply with legal, regulatory, tax, and accounting obligations, to resolve disputes, and to enforce our agreements. Consent records are retained for at least five (5) years. Inquiry records are retained for as long as needed to serve the inquiry, evidence attribution and payment, and defend claims.

8. Security

We maintain administrative, technical, and physical safeguards reasonably designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Children

Our websites and services are directed to businesses and to adults. We do not knowingly collect personal information from children under thirteen (13), and we do not knowingly sell or share the personal information of consumers under sixteen (16). If you believe a child has provided us personal information, contact us and we will delete it.

10. Third-Party Sites and Partners

Our websites may link to third-party sites, and the buyers and partners to whom we route inquiries are independent businesses with their own privacy practices. This Policy does not govern their collection or use of your information once you deal with them directly.

11. Your Choices and Rights

Depending on where you live, you may have the right to know what personal information we have collected about you, to access it, to correct it, to delete it, to opt out of its sale or sharing, to limit the use of sensitive personal information, and not to be discriminated against for exercising those rights. You may exercise these rights through our Data Privacy Request page or our Do Not Sell or Share page, or by emailing privacy@loyaltyltd.co. We will verify your identity before acting on a request and will respond within the time required by applicable law (generally 45 days, extendable once by 45 days with notice). You may designate an authorized agent to make a request on your behalf; we may require proof of authorization.

12. California Privacy Notice

This section applies to California residents and supplements the rest of this Policy as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”).

Personal information does not include publicly available information, de-identified or aggregated information, or information excluded from the CCPA's scope, such as information covered by the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, HIPAA, or the Driver's Privacy Protection Act. Where a Loyalty LTD property handles information subject to the FCRA or GLBA, that information is governed by those laws and any notice provided under them.

Categories of personal information collected in the preceding twelve (12) months, the sources, and whether sold or shared:

12. California Privacy Notice (continued)

We do not collect the following categories in connection with our websites: C (protected classifications), E (biometric information), or J (non-public education information). We do collect H (sensory data): calls may be recorded with notice, and our partner intake flow collects photographic images of government identity documents submitted by media and business partners.

We do collect sensitive personal information, as that term is defined by the CCPA as amended by the CPRA. This is limited to Social Security numbers, driver's license, state identification and passport numbers, financial account information, and images of government identity documents, collected from media and business partners for identity verification, tax, and compliance purposes. We do not collect precise geolocation; uploaded images have location metadata stripped before storage. We do not sell sensitive personal information and we do not share it for cross-context behavioral advertising. Our California Privacy Notice describes this category and your right to limit its use and disclosure in full.

Purposes. The purposes described in Section 2.

Categories of third parties to whom we sell or share. Buyers of leads and calls in the categories described in Section 3; partner networks you select; advertising partners.

Categories of third parties to whom we disclose for business purposes. Service providers and contractors described in Section 4.

Your rights. The right to know, access, correct, delete, opt out of sale and sharing, to limit the use and disclosure of sensitive personal information, and not to be discriminated against, described in Section 11. Submit requests through the Data Privacy Request page, the Do Not Sell or Share page, or privacy@loyaltyltd.co. Requests to limit the use and disclosure of sensitive personal information may be submitted to privacy@loyaltyltd.co.

Financial incentives. We do not offer financial incentives in exchange for personal information.

Shine the Light. California residents may request a list of third parties to whom we disclosed personal information for their direct marketing purposes in the preceding calendar year by writing to privacy@loyaltyltd.co.

• California Privacy Notice
• Do Not Sell or Share My Personal Information

13. Other State Privacy Rights

Residents of states with comprehensive privacy laws may have similar rights to those described in Sections 11 and 12, including the right to opt out of the sale of personal information, targeted advertising, and certain profiling, and the right to appeal a denied request. Use the same channels to exercise them.

14. Changes to This Policy

We may update this Policy from time to time. Updates are posted with a new effective date. Continued use after posting means you accept the updated Policy.

15. Contact

Validated Lead Group is a brand of Loyalty LTD.

• Loyalty LTD, a Nevada limited liability company
• 2206 Heavenly View Drive, Henderson, Nevada 89014
• (424) 704-5950
• privacy@loyaltyltd.co