Privacy Policy

1. Information We Collect

a. Information You Provide Directly

• Account registration: First name, last name, email address, phone number, and password.
• Payment information: Billing details (credit/debit card numbers, billing address) processed securely through our third-party payment processors (Stripe, FanBasis). We do not store full card numbers on our servers.
• Account preferences: Selected states, plan type, dialer settings, and other dashboard configurations you set.
• Communications: Messages, support tickets, and correspondence you send to us.
• SMS information: If you elect to receive marketing texts, we record your account phone number, affirmative opt-in, consent timestamp, checkout source, and disclosure version. We also process opt-out requests and message delivery information to operate the program.

b. Information Collected Automatically

• Log data: Browser type, operating system, referring URL, pages visited, time and date of visits, and time spent on pages.
• Analytics data: We use privacy-safe IP hashing for analytics — we do not store raw IP addresses. Session data is used only for aggregate traffic analysis.
• Third-party pixels and tags: Meta and Google tools on our website collect information about your visit. See Section 7.
• Cookies and similar technologies: See Section 7 for details.
• Affiliate tracking: If you arrive via an affiliate or creator referral link, we record the referral source to credit the referring party.

c. Information About Lead Contacts

As a lead generation company, we also collect and process data about insurance prospects (lead contacts) that we provide to our customers. Lead contact data is sourced from individuals who have voluntarily expressed interest in insurance or related financial products through third-party partner networks and opt-in forms. This data includes contact information (name, phone, email, address) and demographic/interest data relevant to the vertical purchased (e.g., mortgage balance, VA status, Medicare eligibility). We do not sell this information for purposes unrelated to insurance lead delivery.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Create, authenticate, and manage your account
• Process payments and fulfill purchased services (lead delivery, dialer access)
• Send transactional communications: account confirmation, payment receipts, subscription renewals, lead delivery notifications
• Send SMS/text messages if you have opted in (see Section 6)
• Respond to customer support inquiries and resolve disputes
• Detect and prevent fraud, unauthorized access, and abuse
• Analyze usage patterns to improve our platform and services
• Comply with applicable legal and regulatory obligations
• Track affiliate and creator referral attribution for commission purposes
• Send service-related announcements (we do not send unsolicited marketing emails without your consent)

3. Legal Basis for Processing (Where Applicable)

Where required by law (such as under the GDPR for users in applicable jurisdictions), we process your personal data under one or more of the following legal bases:

• Contract: Processing is necessary to perform the contract we have with you (delivering services you purchased).
• Legitimate interests: Processing is necessary for our legitimate business interests (fraud prevention, analytics, platform improvement) where those interests are not overridden by your rights.
• Consent: Where we have obtained your explicit consent (e.g., SMS opt-in).
• Legal obligation: Processing is required to comply with applicable law.

4. Sharing and Disclosure of Information

We sell or provide insurance lead contact data to customers who purchase leads, as described in Section 1(c). That data can include a prospect's name, phone number, email address, and relevant insurance-interest information. Apart from that lead-delivery business, we do not sell or rent our customers' account information to third parties for their own marketing purposes. Other disclosures include:

• Service providers: Third-party vendors who process data on our behalf to operate our platform, including payment processors (Stripe, FanBasis), email delivery providers (Resend), SMS providers, cloud hosting providers, and analytics tools. These vendors are bound by data processing agreements and may only use your data to provide services to us.
• Advertising and analytics partners: Meta Platforms, Inc. and Google LLC receive information about your visits to our website through the tools described in Section 7, for advertising and measurement.
• Affiliate and creator partners: We share limited transaction data (confirmation of subscription) with creators and affiliates for the sole purpose of calculating commission owed to them. We do not share your full personal details.
• Legal compliance: We may disclose your information if required by law, regulation, court order, subpoena, or governmental authority, or to protect the rights, property, or safety of Penguin Leads LLC, our users, or others.
• Business transfers: If Penguin Leads LLC is involved in a merger, acquisition, financing, or sale of business assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a materially different privacy policy.
• With your consent: We may share information with third parties when you have given us explicit consent to do so.

5. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information, including:

• Encrypted data transmission using TLS (HTTPS)
• Bcrypt hashing for all stored passwords — we never store passwords in plain text
• HTTP-only, secure session cookies to prevent cross-site scripting (XSS) attacks
• Payment card data handled exclusively by PCI-DSS compliant third-party processors; we do not store full card numbers
• Role-based access controls limiting employee access to personal data

Despite these measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your information. In the event of a data breach that affects your rights, we will notify you as required by applicable law.

6. SMS / Text Messaging

If you separately check the optional marketing SMS box at checkout, you give affirmative written consent to receive recurring automated promotional text messages from Penguin Leads LLC at the number provided. Marketing texts may include offers for our AGED Unlimited Leads Dialer, product announcements, and free-trial offers. Providing a phone number or agreeing to purchase terms alone does not enroll you in marketing messages.

Any informational or service-message consent is separate from marketing consent; agreeing to informational messages does not authorize promotional texts. We use SMS consent details to document your choice, deliver requested messages, honor opt-outs, and provide support.

7. Cookies, Pixels and Tracking Technologies

We use the following cookies and similar technologies:

• Strictly necessary cookies: Required for you to use the site (session authentication, security). You cannot opt out of these.
• Our own analytics: We collect page view and session data for internal analytics using hashed IP addresses. We do not store raw IP addresses for this.
• Third-party advertising and analytics tools: Through Google Tag Manager, our website loads tools from Meta Platforms, Inc. (the Meta Pixel) and Google LLC (Google Analytics, Google Ads and DoubleClick). These tools set cookies or use similar identifiers and send information about your visit to Meta and Google, including the web addresses and pages you view, buttons you click, forms you start or submit, purchases, your browser and device, your IP address, and cookie or advertising IDs. We use this to measure and improve our advertising and to show ads to people who have visited our site. Meta and Google may combine it with other information they hold and use it under their own privacy policies.
• Affiliate/referral cookies: We store referral codes in your browser's localStorage for up to 30 days to properly attribute affiliate and creator commissions.

Your choices: You can block or delete cookies in your browser settings, use ad-blocking tools, and change your ad settings with Meta and with Google. Disabling strictly necessary cookies may affect your ability to log in and use the platform. By using our website, you consent to the use of these tools as described here and in the "Website Tracking, Cookies and Pixels — Your Consent" section of our Terms of Service.

8. Your Privacy Rights

a. General Rights

Regardless of your location, you may:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your account and associated personal data (subject to legal retention requirements)
• Opt out of SMS communications at any time by replying STOP

b. California Residents — CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you, the sources from which we collected it, the business purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions (legal compliance, completing a transaction, etc.).
• Right to Correct: You may request that we correct inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We sell or provide insurance prospect contact information to lead-buying customers. If you are a lead contact and wish to opt out of a sale or request information about your rights under applicable law, contact us at support@penguinlead.com. We do not share SMS subscriber consent for another party's marketing.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond what is necessary to provide our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise your CCPA rights, contact us at support@penguinlead.com. We will verify your identity before processing your request. Authorized agents may submit requests on your behalf with appropriate written authorization.

c. Other State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas, and other states with enacted privacy laws may have similar rights. We will honor verified requests consistent with applicable state law. Contact us at support@penguinlead.com to submit a request.

9. Data Retention

We retain your personal information for as long as your account is active, as needed to provide services, or as required by law. Specifically:

• Account data: Retained for the duration of your account and for up to 3 years after account closure for legal and business purposes.
• Payment records: Retained for 7 years to comply with tax and financial record-keeping laws.
• Support tickets: Retained for 2 years.
• Analytics data: Aggregated and anonymized; retained indefinitely. Raw session data is purged after 90 days.

To request account deletion, contact us at support@penguinlead.com. We will process deletion requests within 30 days, except where retention is required by law.

10. CAN-SPAM Compliance

All commercial email communications from Penguin Leads LLC comply with the CAN-SPAM Act. Each email includes: a clear identification of the sender, a non-deceptive subject line, our physical mailing address, and a clear and conspicuous opt-out mechanism. We honor opt-out requests within 10 business days. To unsubscribe from marketing emails, click the unsubscribe link in any email or contact us at support@penguinlead.com.

11. Children's Privacy

Our services are intended solely for licensed insurance professionals and business users aged 18 and older. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will delete it promptly. If you believe we have collected information from a minor, contact us immediately at support@penguinlead.com.

12. Third-Party Links

Our website may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party sites you visit.

13. International Users

Our services are intended for users in the United States. If you access our services from outside the United States, your information may be transferred to and processed in the United States, where privacy laws may differ from those in your country. By using our services, you consent to this transfer.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will post the updated policy on this page with a new "Last Updated" date and, where appropriate, notify you by email or a prominent notice on our website. Your continued use of our services after any changes become effective constitutes your acceptance of the revised policy.