Privacy Policy

This Privacy Policy explains how LeadRefinery LLC (“LeadRefinery,” “we,” “us,” or “our”), handles personal information. It covers our website, our communications with businesses and prospective clients, and the calls, text messages, and emails placed through our platform on behalf of our business clients.

1.About LeadRefinery and This Policy

LeadRefinery is a Florida limited liability company that provides a business-to-business technology platform. Our platform places outbound telephone calls using an artificial, AI-generated voice, and can deliver a link by text message or email, in each case on behalf of our business clients and to contacts those clients supply.

We do not generate, buy, or sell leads, and we do not use affiliates or third-party lead vendors. We do not originate or purchase the contact records worked through our platform. Every contact record is supplied by the client on whose behalf it is worked, and it is used only for that client. Our platform is lead management software: it works records our clients already own.

This Policy does not apply to the practices of our clients, or of any other company whose website or application you visit — including any application form you may be directed to by a link we deliver. Those organizations have their own privacy policies.

2.Our Two Roles — Please Read

We handle personal information in two very different capacities. Your rights, and the right point of contact, depend on which one applies.

A. Information we handle for our own purposes

When you visit our website, contact us, request information, or interact with us as a business contact or client user, we decide how and why your information is used. In privacy terms we act as a “controller” or “business” for that information, and this Policy governs it directly.

B. Information we handle on behalf of our clients

The merchant contact records worked through our platform — and the call, message, and outcome data generated from contacting them — are processed on behalf of the client that supplied them. That client decides who is contacted, what is offered, and on what legal basis. In privacy terms we act as a “service provider” or “processor” for that information, under a written agreement that limits how we may use it.

If you were contacted through our platform and want to exercise privacy rights over your information, the client on whose behalf the contact was made is generally the right party to address. We will help route your request — see Section 13. You do not need to contact anyone else to stop receiving communications: we will honor an opt-out request made directly to us, regardless of which client is involved.

3.Information We Collect

Website visitors and business contacts

• Contact and business details you give us — name, business email address, telephone number, company name, job title, and anything you include in a form or message.
• Correspondence — emails, messages, and records of our communications with you.
• Device and usage information — IP address, browser and device type, pages viewed, referring pages, and dates and times of access, collected automatically as described in Section 9.
• Prospect information — business contact details obtained from public sources and third-party business-data providers, used to contact businesses about our services.

Client account users

• Account and access information — name, business contact details, login credentials, permissions, and records of activity in the platform.
• Verified mobile number — where an account holder chooses to verify a mobile telephone number, that number and the record of their SMS consent, as described in Section 5.

Information processed on behalf of clients

• Merchant contact records supplied by the client — typically business name, contact name, telephone number, email address, business address, industry, and related business information.
• Call content — audio recordings and/or transcripts of calls placed through the platform, where recording or transcription occurs (see Section 4).
• Call and message metadata — date, time, duration, telephone numbers involved, delivery status, call outcome and disposition, and transfer records.
• Compliance records — suppression and do-not-call screening results, opt-out requests, and related records we keep to demonstrate compliance.

4.Calls, Recording, and AI Voice

Calls use an artificial, AI-generated voice

Calls placed through our platform are made using an artificial, AI-generated voice rather than a live person. The voice agent identifies the business on whose behalf the call is made and provides the disclosures required by applicable law. You may ask to be removed from further contact at any point during a call, and that request will be honored.

Call recording and transcription

Calls placed through our platform may be recorded and/or transcribed. We use recordings and transcripts to operate and improve the service, to handle and route the call, to maintain records of what was said and of opt-out requests, to monitor quality, and to demonstrate compliance with telemarketing and consumer-protection laws.

Where notice or consent to recording is required, notice is given at the beginning of the call. If you do not wish to be recorded, you may say so or end the call.

Voice data

We use call audio and transcripts only for the purposes described above. We do not use call audio to create voiceprints or other biometric identifiers, we do not use voice data to identify or authenticate individuals, and we do not use it to infer characteristics about you.

5.Text Messages and Email

We operate two separate messaging programs. They have different audiences, different content, and different consent.

Account verification messages (one-time passcodes)

When a LeadRefinery account holder enters their own mobile telephone number in our application and checks the SMS consent box, we send a one-time passcode by text message to confirm the number belongs to them. These messages contain a numeric code and its expiry, and nothing else. We do not send marketing, promotional, or sales text messages to account holders.

Consent is optional. It is not a condition of purchase, it is not a condition of creating or using a LeadRefinery account, and it is given separately from acceptance of our Terms of Use or any other agreement. Reply STOP to opt out or HELP for help. Message frequency may vary. Message and data rates may apply. Full program terms are in our SMS Terms of Service.

Messages sent on behalf of clients

Where a contact has expressed interest during a call, our platform may send a text message or email containing a link to the client’s application or website. We do not send marketing text messages or emails on our own behalf to contacts in our clients’ records.

• Text messages. Reply STOP to any message to stop receiving further messages, and HELP for assistance. Message and data rates may apply. Message frequency varies.
• Email. Commercial emails include a functioning unsubscribe mechanism and accurate sender identification, as required by the CAN-SPAM Act.

An opt-out received on any channel is applied across all channels — see Section 8.

6.How We Use Information

We use personal information for the following purposes:

• To provide, operate, maintain, and support the platform and our services, including placing calls and delivering messages at our clients’ direction.
• To verify that a mobile telephone number belongs to the account holder who submitted it, and to secure account access.
• To perform compliance screening — including do-not-call, suppression, reassigned-number, and line-type checks — and to enforce calling windows, contact frequency limits, and opt-outs.
• To maintain records required for legal compliance, to respond to disputes, regulatory inquiries, and legal claims, and to establish or defend legal rights.
• To secure the platform, prevent fraud and abuse, and troubleshoot technical problems.
• To communicate with businesses and prospective clients about our services, and to respond to inquiries.
• To evaluate and improve our platform, models, and service quality. For this purpose we use operational data such as call outcomes and dispositions, together with de-identified and aggregated data. We do not use this information to build profiles about individual consumers, and we do not use it to improve any other company’s products or services.
• To comply with legal obligations and enforce our agreements.

7.How We Share Information

We share personal information only as described below.

• With our clients. Contact records, call outcomes, dispositions, and related results are made available to the client on whose behalf the contact was made.
• With service providers. We use third parties to operate the platform — including telephony and messaging carriers, cloud hosting and storage providers, voice and transcription technology providers, and compliance and suppression data vendors. They may access personal information only to perform services for us, and are bound by confidentiality and data-protection obligations.
• With professional advisors. Attorneys, accountants, auditors, and insurers, as needed.
• For legal reasons. Where we believe disclosure is required by law, subpoena, or legal process, or is necessary to protect the rights, property, or safety of LeadRefinery, our clients, or others.
• In a business transaction. In connection with a merger, acquisition, financing, or sale of assets, subject to appropriate protections.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising, as those terms are defined under applicable state privacy laws.

SMS opt-in data and consent

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages. All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Your mobile information will not be sold or shared with third parties for promotional or marketing purposes.

8.Do Not Call and Your Communication Choices

You can stop receiving communications placed through our platform at any time, and you do not need to identify the client involved to do so.

How to opt out

• On a call — tell the agent you do not want to be contacted, or ask to be placed on the do-not-call list.
• By text — reply STOP to any message you receive.
• By email — use the unsubscribe link, or write to privacy@leadrefinery.ai.
• Directly — email privacy@leadrefinery.ai with the telephone number or email address you want suppressed.

What happens when you opt out

We maintain a written internal do-not-call policy and an internal do-not-call list. When we receive an opt-out request through any channel, we record it and suppress the contact information across our platform — including across telephone, text message, and email, and across all campaigns and clients operating on the platform — within the period required by law, and promptly in practice.

We also screen contact records against the National Do Not Call Registry and applicable state do-not-call registries before and during campaigns. You may register your number with the National Do Not Call Registry at donotcall.gov.

Opting out does not require you to give us any information beyond what is needed to identify the contact information to suppress, and we will not charge you or treat you differently for opting out.

9.Cookies, Analytics, and Opt-Out Signals

Our website uses cookies and similar technologies to operate the site, remember preferences, and understand how the site is used. Where we use analytics tools, we use them only to measure aggregate site traffic and to improve our website. We do not use our website analytics for advertising, and we do not sell or share website-analytics data for cross-context behavioral advertising or targeted advertising.

Most browsers let you refuse or delete cookies through their settings. Disabling cookies may affect how the site functions.

Where required by applicable state law, we recognize and honor universal opt-out preference signals, including the Global Privacy Control (GPC), transmitted by your browser or device.

10.How Long We Keep Information

We keep personal information only as long as needed for the purposes described in this Policy, and then for as long as necessary to comply with legal obligations, resolve disputes, and establish or defend legal claims. Because telemarketing and consumer-protection laws require callers to retain records — including consent, suppression, and call records — we retain compliance records for the periods those laws require.

For information processed on behalf of a client, retention is governed by our agreement with that client. On expiration or termination, or at the client’s direction, we return and/or delete the client’s contact records — other than de-identified and aggregated data, routine backups that age out on our normal cycle, and records we are required by law to retain.

Do-not-call and opt-out records are retained on an ongoing basis: we must keep them in order to continue honoring your opt-out.

11.Security

We maintain an information-security program with administrative, technical, and physical safeguards appropriate to the nature of the information we handle, including access controls and encryption of data in transit. Our platform is multi-tenant and is designed to logically separate each client’s data and traffic across the application, database, and telephony layers.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12.Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding personal information we hold about you as a controller or business:

• To know what personal information we collect, use, disclose, and retain, and the categories of sources and recipients.
• To access or obtain a copy of your personal information, including in a portable format.
• To correct inaccurate personal information.
• To delete personal information, subject to legal exceptions — including our obligation to keep do-not-call and compliance records.
• To opt out of the sale of personal information, sharing or processing for targeted advertising, and certain profiling. As noted in Section 7, we do not engage in these activities.
• To limit the use of sensitive personal information, where applicable.
• To not be discriminated against for exercising your rights.

How to exercise your rights

Email privacy@leadrefinery.ai or write to us at the address in Section 16. We will need enough information to verify your identity and locate your records; we use that information only to process your request. An authorized agent may submit a request on your behalf with proof of authorization.

We respond within the timeframes required by applicable law. If we decline your request, you may appeal by replying to our response or writing to privacy@leadrefinery.ai with the subject line “Privacy Appeal.” If your appeal is denied, you may contact your state attorney general.

If your request concerns information we process on behalf of a client, see Section 13.

13.If You Were Contacted Through Our Platform

If you received a call, text message, or email placed through our platform, the following applies.

• To stop the contact: use any method in Section 8. We will honor your request directly and suppress your contact information across our platform. You do not need to know which client was involved.
• To find out who was calling: the voice agent identifies the business on whose behalf the call is made at the start of the call. If you did not catch it, contact us at privacy@leadrefinery.ai with the telephone number contacted and the approximate date, and we will identify the client for you.
• To exercise access, correction, or deletion rights: the client that supplied your contact information decides how that information is used, so it is generally the right party to address, and it holds the record of where your information came from. Contact us and we will identify the client and forward your request. We will also act on the client’s instructions with respect to your information.
• To obtain call recordings or transcripts: contact us at privacy@leadrefinery.ai. We will respond as required by applicable law, and will verify your identity before releasing any recording.

14.Children’s Privacy

Our website and services are directed to businesses, not to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us personal information, contact us and we will delete it.

15.Changes to This Policy

We may update this Policy from time to time. We will post the updated version here and revise the “Last updated” date above. If we make material changes, we will provide additional notice as required by law. Your continued use of our website or services after an update means you acknowledge the revised Policy.

16.How to Contact Us

For privacy questions, requests, or opt-out requests: