Privacy Policy

This policy explains what personal information Life Leads Plus collects through this website, the client portal and our calling and messaging systems, why we collect it, who we share it with, how long we keep it, and the choices you have, including how to opt out of marketing contact and how to request access or deletion.

1. Scope and who we are

Life Leads Plus (“Life Leads Plus,” “we,” “us”) is organized under the laws of the State of Colorado. This policy applies to personal information we collect through this website, the Life Leads Plus client portal, our call routing and messaging systems, and our own marketing communications (together, the “Services”).

This policy covers two distinct groups of people:

• Clients — licensed insurance agencies, their owners, and the agents and team members who use the Services.
• Consumers — individuals who contact us or are connected to a client’s agent through the Services in connection with an insurance inquiry.

Where we determine the purposes and means of processing, we act as a controller. Where we process information on behalf of a client or a carrier under their instructions, we act as a service provider or processor, and that party’s own privacy notice governs their use of the information. Once information is transferred to a client or a carrier, their handling of it is governed by their policies and is outside our control.

2. Information we collect

2.1 Information you give us

• Application form data: your agency name, your name, email address, mobile phone number, licensed states, number of agents, verticals, pricing model and call preferences, caller ages, delivery hours, and any message you add. If you complete the first step of the form, we receive what you entered there even if you don’t send the rest.
• Account data: names, email addresses, and roles of the team members you invite to the portal, the telephone number you designate for call delivery, and your program settings.
• Payment data: payments may be processed by third-party payment processors. We do not store full card numbers or full bank account numbers. We receive limited transaction records such as a payment identifier, amount, date, and status.
• Consumer inquiry data: name, telephone number, mailing address or ZIP code, state, email address, date of birth or age range, and information about the coverage being sought.
• Application data: carrier, plan, face amount, premium, policy or submission number, applicant name, applicant state, and submission status, logged for billing and reporting.
• Correspondence: the content of messages, support requests, complaints, and opt-out or rights requests you send us.

2.2 Communication metadata and content

Because the Services route calls and send messages, we necessarily collect information about those communications:

• Call records: calling and called telephone numbers, date, time, duration, billable status, disposition, the agent to whom the call was transferred, and the program.
• Call recordings: where calls are recorded or monitored, the audio recording and any transcript or notes derived from it. Recording practices, and the notice and consent required, are described in our TCPA & Compliance Policy.
• SMS and MMS: message content, sending and receiving numbers, timestamps, delivery receipts and error codes, carrier responses, opt-in and opt-out keywords, and message status.
• Consent records: the consent language displayed, the web page or form on which consent was given, date and time, IP address, browser user agent, and the values submitted. These records are retained to evidence prior express written consent.

2.3 Information collected automatically

• IP address and approximate location derived from it, device and browser type, operating system, screen size, and language.
• Pages viewed, referring URL, campaign tags in the link you followed, links clicked, time on page, and dates and times of access.
• Server and application logs, error reports, and security event records.

2.4 Information from third parties

• Marketing partners: consumer inquiry data and the associated consent record, where a Consumer submitted a request through a partner’s property.
• Service providers: telephony and messaging carriers, payment processors, and fraud or deliverability tools.

3. Cookies and tracking technologies

We and our providers may use cookies, local storage, pixels, and similar technologies to keep you signed in to the portal, remember preferences, measure traffic and page performance, secure the Services and detect abuse, and attribute inquiries to the source that generated them.

This website sets no cookies and uses no analytics or third-party tracking.

Most browsers let you refuse or delete cookies through their settings. Blocking cookies that are strictly necessary will prevent parts of the portal from working. Where required by law, we present a consent mechanism for non-essential technologies, and you may change your choice at any time.

4. How we use information

We use personal information to:

• Respond to your application, set up your program, and administer accounts.
• Route inbound calls from the states and during the hours a client selects, and connect the parties.
• Send and receive SMS and MMS messages relating to an inquiry or an account.
• Record calls, billable status, and applications against an account, calculate fees, draw them from a prepaid balance, process payments, and issue statements.
• Review return requests against call records and recordings.
• Provide reporting, analytics, and support to clients about their own activity.
• Maintain and evidence consent, honor do-not-call and opt-out requests, and meet our recordkeeping and regulatory obligations.
• Monitor for fraud, duplicate or falsified applications, abuse, and security incidents.
• Operate, debug, secure, and improve the Services.
• Communicate with you about the Services, including service and transactional messages, and, where permitted, marketing about our own programs.
• Comply with law, respond to lawful requests, and establish, exercise, or defend legal claims.

We do not use call recordings, message content, or Consumer inquiry data to train third-party generative artificial intelligence models for purposes unrelated to providing the Services.

5. How we share information

We disclose personal information in the following circumstances:

• With clients. Consumer inquiry data is disclosed to the client whose agent receives the call, so that the agent can respond and, if the Consumer chooses, complete an application. Clients are contractually required to use it only for that purpose.
• With insurance carriers. Application information may be transmitted to or recorded with the carrier through which an application is submitted.
• With service providers. Payment processors, telephony and SMS carriers, cloud hosting and infrastructure, email delivery, analytics, and security vendors, each engaged to process information on our behalf under contractual restrictions.
• For legal reasons. Where we believe disclosure is required by law, subpoena, regulator request, or court order, or is necessary to investigate suspected fraud or to protect the rights, property, or safety of any person.
• In a business transfer. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this policy or a successor notice.
• With your direction or consent. Where you ask us to share information with someone else.

We do not disclose personal information to third parties for their own independent marketing purposes without a lawful basis and, where required, your consent. We do not sell information submitted by clients through our application form.

6. Sale, sharing and targeted advertising

Several state privacy laws define “sale” and “sharing” broadly, and those definitions can extend to disclosures made for valuable consideration even where no money changes hands for the data itself. Our core activity involves connecting Consumers with licensed agents at client agencies that pay us per submitted application or per billable call.

Depending on the state and the circumstances, that disclosure to a client may be treated as a “sale” or “sharing” of personal information. We therefore make the opt-out rights described in Section 9 available to all Consumers regardless of their state of residence. We do not knowingly sell or share the personal information of individuals under 16.

Where this website uses advertising tools listed in Section 3, they may be used to measure and improve our own advertising. We do not use personal information for profiling that produces legal or similarly significant effects. If that changes, we will update this policy and provide any opt-out required by law before the change takes effect.

7. How long we keep information

We keep personal information only as long as necessary for the purposes described here, and then delete it or de-identify it. Retention is driven by the following:

Where we are required to keep information to demonstrate compliance, such as consent and opt-out records, we retain it even after a deletion request and limit its use to that purpose.

8. Security safeguards

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of traffic in transit using TLS, access controls and authentication for the portal, segregation of each client’s data so that one client cannot access another’s, agent-level access so that each agent sees only their own customers, least-privilege access for personnel, logging and monitoring of administrative actions, and vendor diligence with contractual confidentiality and security terms.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and for notifying us promptly of any suspected unauthorized use. If a breach affecting your personal information occurs, we will notify you and any regulator as required by applicable law.

9. Your rights and choices

9.1 Rights that may be available to you

• Access — confirm whether we process your personal information and obtain a copy, including the categories collected, the sources, the purposes, and the categories of recipients.
• Correction — have inaccurate personal information corrected.
• Deletion — request deletion, subject to exceptions where we must retain information by law or to evidence consent and opt-out status.
• Portability — receive a copy in a portable, readily usable format where technically feasible.
• Opt out of sale or sharing — direct us not to sell or share your personal information as those terms are defined in Section 6.
• Limit use of sensitive information — where we process sensitive personal information beyond what is necessary to provide the Services.
• Non-discrimination — we will not deny service, charge a different price, or provide a lesser quality of service because you exercised a privacy right.
• Appeal — if we decline a request, you may appeal by contacting us again and referencing the original request.

9.2 How to exercise a right

Contact us using the details in Section 14. Tell us which right you are exercising and give us enough information to locate your records, such as the telephone number or email address you used. We will verify your identity before acting, typically by confirming information already in our records, and we do not use verification information for any other purpose.

We respond within the period required by applicable law, generally 45 days, and may extend once where reasonably necessary with notice to you. An authorized agent may submit a request on your behalf with proof of authorization. There is no charge for a reasonable number of requests.

9.3 Communication opt-outs

To stop text messages: reply STOP to any message. Reply HELP for assistance.

To stop calls: tell the caller you wish to be placed on the internal do-not-call list, or call us at (303) 555-0100.

To stop marketing email: use the unsubscribe link in the message or contact us directly.

Opt-out requests are honored across channels. We may still send transactional messages about an existing account, such as billing notices. Full details are in our TCPA & Compliance Policy.

10. State privacy disclosures

10.1 Colorado

Colorado residents have the rights described in Section 9 under the Colorado Privacy Act, including the rights to access, correct, delete, and obtain a portable copy of personal data, to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects, and to appeal a refused request. Where required, we honor recognized universal opt-out mechanisms such as Global Privacy Control.

10.2 California

California residents have the rights described in Section 9 under the California Consumer Privacy Act as amended. The categories of personal information we collect, as those categories are defined in Cal. Civ. Code § 1798.140, are: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data derived from IP address; audio and electronic information, including call recordings and message content; professional or employment-related information, in the case of clients; and inferences drawn from the foregoing. Sources, purposes, and recipients are described in Sections 2, 4, and 5. We retain each category as described in Section 7.

Where the information you provide relates to insurance eligibility, it may include elements treated as sensitive personal information. We use it only to provide the Services and for the purposes permitted without a right to limit under § 1798.121.

California’s “Shine the Light” law permits residents to request information about disclosures to third parties for their direct marketing purposes. You may make that request using the details in Section 14.

10.3 Other states

Residents of states including Virginia, Connecticut, Utah, Texas, Oregon, and Montana have comparable rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and certain profiling, together with a right to appeal a refused request. We extend the rights in Section 9 to residents of every state.

10.4 Insurance-specific privacy law

Personal information collected in connection with an insurance transaction may also be subject to state insurance privacy statutes and to the Gramm-Leach-Bliley Act. Where those laws apply, we handle the information in accordance with them, and certain exemptions to general state privacy laws may apply.

11. Children’s privacy

The Services are intended for adults. We do not knowingly collect personal information from anyone under 18, and the products offered are not directed to children. If we learn that we have collected information from a child under 13, or have sold or shared the information of anyone under 16 without required consent, we will delete it or cease the activity. Contact us if you believe a child has provided information.

12. Other disclosures

12.1 Do Not Track

Browsers may transmit a “Do Not Track” signal. There is no common industry standard for responding to it, and we do not currently respond. Where required, we honor recognized opt-out preference signals such as Global Privacy Control for the opt-out described in Section 6.

12.2 Third-party links

The Services may link to sites we do not operate. We are not responsible for their privacy practices, and we encourage you to read their notices.

12.3 Location of processing

The Services are intended for use in the United States, and information is processed and stored in the United States. If you access the Services from elsewhere, you do so on your own initiative and are responsible for compliance with local law.

13. Changes to this policy

We may update this policy. The “Last updated” date above reflects the most recent revision. If we make material changes, we will provide notice through the Services or by contacting you before the change takes effect. Continued use after the effective date constitutes acceptance.

14. Contact us

To ask a question about this policy, exercise a privacy right, or submit a complaint, contact us by telephone or by mail:

Life Leads Plus
123 Main Street, Suite 100
Denver, CO 80202
United States
(303) 555-0100

Please mark written requests “Attn: Privacy Request” and include the telephone number or email address associated with your information so that we can locate your records.