Privacy Policy

01Scope of This Policy

This Privacy Policy applies to information collected through the OFFLEADS website, marketplace platform, and related services (collectively, the "Service"), operated by Offleads Inc. ("OFFLEADS," "we," "us," or "our"). It covers three distinct groups of people whose information we may handle:

• Buyers — agencies and other purchasers who use the Service to acquire calls, leads, and data.
• Publishers — media buyers, affiliates, call centers, and other traffic sources who submit inventory to the marketplace.
• Consumers — the individuals whose contact information appears within the calls, form-fill leads, or aged data transacted on the marketplace. OFFLEADS does not collect consumer information directly in most cases; it is submitted by Publishers, as described in Section 4.

By using the Service, you acknowledge the practices described in this Policy. If you do not agree, please do not use the Service.

02Information We Collect

We collect information in the following ways:

03How We Use Information

We use the information described above to:

• Operate, maintain, and improve the marketplace, including matching Buyers with available inventory;
• Screen calls and leads for quality, intent, duration, and compliance signals prior to sale;
• Process payments, payouts, and resolve billing or quality disputes;
• Verify Publisher and Buyer eligibility, licensing, and compliance with these policies;
• Communicate with you about your account, orders, or applications;
• Detect, investigate, and prevent fraud, abuse, or violations of our Terms;
• Comply with legal obligations and respond to lawful requests from public authorities.

We do not sell consumer call or lead data to parties outside of the specific, exclusive marketplace transaction for which it was submitted.

04Consumer Call & Lead Data

Much of the personal information that flows through the OFFLEADS marketplace belongs to consumers who were contacted, or who submitted a form, through a Publisher's advertising or outreach — not through OFFLEADS directly. In these cases:

• Publishers represent to us that they obtained all consents required by applicable law (including the TCPA) before submitting a consumer's information to the marketplace.
• OFFLEADS screens submitted inventory for basic quality and compliance indicators but does not independently verify every individual consent record at the point of collection.
• Once a call or lead is sold, the receiving Buyer becomes independently responsible for how that consumer's information is used, consistent with the consent under which it was originally collected.
• Consumers who believe their information was submitted to our marketplace without proper consent may contact us using the details in Section 14, and we will investigate the originating Publisher.

05How We Share Information

We share information in the following circumstances:

• With Buyers — consumer call and lead data is shared with the single Buyer who purchases that specific, exclusive inventory item.
• With service providers — payment processors, cloud hosting, call-routing and screening technology, analytics, and customer support tools, under contractual confidentiality obligations.
• For legal reasons — where required to comply with a subpoena, court order, or other legal process, or to protect the rights, property, or safety of OFFLEADS, our users, or the public.
• In a business transfer — in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

We do not share Buyer or Publisher account information with unrelated third parties for their own independent marketing purposes.

06Cookies & Tracking

We use cookies and similar technologies to keep you logged in, remember preferences, understand how the Service is used, and measure the performance of our marketing. You can control cookies through your browser settings; disabling certain cookies may affect functionality of the Service.

07Data Retention

We retain account, transaction, and consumer call/lead data for as long as reasonably necessary to fulfill the purposes described in this Policy, resolve disputes, enforce our agreements, and comply with legal, tax, and regulatory recordkeeping obligations. Retention periods vary by data type; call recordings and consent records tied to a transaction are generally retained for the period required to support compliance audits and dispute resolution.

08Data Security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction. No system is completely secure, and we cannot guarantee the absolute security of information transmitted to or stored on the Service.

09Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information, including the rights below. To exercise any of these rights, contact us using the details in Section 14 — we will verify your request and respond within the timeframe required by applicable law.

Residents of California, Colorado, Virginia, and other states with comprehensive privacy laws may have additional statutory rights, including the right to non-discrimination for exercising these rights.

10Do Not Call & Consent

If you have received a call or message through our network and no longer wish to be contacted, you may request removal by contacting us at the email in Section 14 with the phone number in question, or by using any opt-out mechanism provided directly by the calling agency. We require Publishers to honor Do-Not-Call requests and to maintain records of consumer consent consistent with the TCPA and applicable state law.

11Children's Privacy

The Service is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete it.

12International Users

The Service is operated in the United States and intended primarily for U.S.-based Buyers, Publishers, and consumers. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your home jurisdiction.

13Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be indicated by updating the "Last Updated" date above and, where appropriate, through direct notice. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.

14Contact

Questions about this Privacy Policy, or requests to exercise your privacy rights, can be directed to us using the details below.