Privacy Policy

1. Introduction and Scope

No Luck Leads, LLC ("Company," "we," "us," or "our") operates a lead generation and publishing platform connecting insurance agencies, home services businesses, and real estate professionals with qualified customer calls and inquiries. This Privacy Policy describes how we collect, use, disclose, store, and protect your information when you:

• Visit our website at noluckleads.com or any of our subdomains
• Use our lead generation, call routing, or marketing services
• Communicate with us via phone, email, or contact forms
• Interact with our advertising campaigns on third-party platforms
• Submit inquiries as a potential customer seeking services from our business partners

This Privacy Policy applies to all information collected through our Services and any related services, sales, marketing, or events (collectively, the "Services").

BY ACCESSING OR USING OUR SERVICES, YOU SIGNIFY YOUR ACKNOWLEDGMENT OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide to us, including but not limited to:

• Contact Information: Name, email address, phone number, mailing address, company name
• Business Information: Industry type, service area/geographic coverage, licensing information, years in business, call volume preferences, budget allocation
• Account Credentials: Username, password, security questions
• Payment Information: Credit card numbers, billing addresses, bank account details (processed through secure third-party payment processors)
• Communication Data: Content of emails, chat messages, phone conversations, and any other communications with us
• Survey Responses: Information provided in response to surveys, questionnaires, or feedback forms
• Marketing Preferences: Opt-in/opt-out selections, communication preferences

2.2 Information Collected Automatically

When you access our website or Services, we automatically collect:

• Device Information: IP address, browser type and version, operating system, device type, unique device identifiers, screen resolution
• Usage Data: Pages visited, time spent on pages, click-through data, referring URLs, exit pages, search queries
• Location Data: General geographic location based on IP address, GPS data if permitted
• Cookies and Tracking Technologies: See Section 11 for detailed information

2.3 Call Recording and Monitoring Disclosure

2.4 Information from Third Parties

We may receive information about you from third-party sources, including:

• Public databases and data aggregators
• Social media platforms (Facebook, LinkedIn, etc.)
• Advertising partners and networks
• Business partners and referral sources
• Credit reporting agencies (for payment verification)
• Lead verification services

3. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data based on the following legal grounds:

• Consent: Where you have given explicit consent for specific processing activities
• Contract Performance: Where processing is necessary to fulfill our contractual obligations to you
• Legal Obligation: Where processing is required to comply with applicable laws
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights

4. How We Use Your Information

We use collected information for the following purposes:

4.1 Service Delivery

• Provide, operate, maintain, and improve our lead generation and call routing services
• Process transactions and manage billing
• Route qualified calls to appropriate business partners
• Verify call quality and qualification criteria compliance
• Respond to inquiries and provide customer support

4.2 Marketing and Communications

• Send marketing communications (only with your explicit consent)
• Deliver targeted advertising on third-party platforms
• Conduct market research and analytics
• Provide promotional offers and special deals

4.3 Security and Compliance

• Detect, prevent, and address fraud, abuse, and security issues
• Monitor and enforce compliance with our Terms of Service
• Comply with legal obligations, court orders, and government requests
• Protect our rights, property, and safety, and that of our users

4.4 Analytics and Improvement

• Analyze usage patterns to improve our website and services
• Generate aggregated, anonymized statistics and reports
• Develop new products, features, and services
• Conduct A/B testing and optimization

5. Information Sharing and Disclosure

5.1 Service Providers and Vendors

We share information with third-party service providers who perform services on our behalf, including:

• Payment processors (e.g., Stripe, PayPal)
• Cloud hosting providers (e.g., AWS, Google Cloud)
• Call routing and telephony providers
• Email marketing platforms (e.g., Mailchimp, SendGrid)
• Analytics providers (e.g., Google Analytics)
• Advertising platforms (e.g., Meta/Facebook, Google Ads)
• CRM and marketing automation tools
• Customer support platforms

These service providers are contractually obligated to use your information only for the purposes of providing services to us and must maintain appropriate security measures.

5.2 Business Partners (Lead Buyers)

Lead information (including name, phone number, location, and expressed interest) is shared with our verified business partners who have contracted with us to receive qualified leads. These partners include:

• Insurance agencies (auto, home, life, health, Medicare)
• Home services contractors (HVAC, roofing, plumbing, electrical)
• Real estate agents, brokers, and teams
• Other licensed professionals in our service industries

5.3 Legal and Regulatory Disclosure

We may disclose your information when required or permitted by law, including:

• In response to subpoenas, court orders, or legal process
• To comply with federal, state, or local government requests
• To cooperate with law enforcement investigations
• To protect our legal rights or defend against legal claims
• To prevent fraud, security threats, or illegal activity

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, asset sale, or similar transaction, your information may be transferred to the successor entity. We will notify you via email and/or prominent website notice of any such change in ownership and your choices regarding your information.

5.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for any purpose, including industry analysis, marketing, and research.

6. Data Security

We implement comprehensive security measures designed to protect your information, including:

• TLS/SSL encryption for all data transmitted between your browser and our servers
• Encryption of sensitive data at rest using AES-256 encryption
• Secure server infrastructure with firewalls and intrusion detection
• Role-based access controls limiting employee access to personal data
• Regular security audits and vulnerability assessments
• Employee training on data protection and security practices
• PCI DSS compliance for payment card processing
• Multi-factor authentication for administrative access
• Regular data backups with secure off-site storage

DISCLAIMER: Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You provide information at your own risk.

7. Data Retention

We retain your information for the following periods:

• Account Information: For the duration of your account plus 7 years after closure for tax and legal compliance
• Call Recordings: 90 days unless required for dispute resolution, legal proceedings, or compliance (up to 7 years)
• Transaction Records: 7 years as required by tax and financial regulations
• Marketing Data: Until you opt out or 3 years of inactivity
• Website Analytics: 26 months (Google Analytics default)
• Lead Data: 3 years from the date of collection or as required by our business partners

After the applicable retention period, we will securely delete or anonymize your information, unless longer retention is required by law or for legitimate business purposes.

8. Your Rights and Choices

Depending on your location and applicable law, you may have the following rights:

8.1 General Rights

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal exceptions)
• Opt-out of Marketing: Unsubscribe from marketing communications at any time via the link in our emails or by contacting us
• Data Portability: Request your data in a structured, machine-readable format
• Restrict Processing: Request limitation of processing in certain circumstances
• Object to Processing: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw previously given consent at any time

8.2 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

We will respond to your request within 30 days (or 45 days for complex requests). We may require verification of your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

9. International Data Transfers

Our servers and operations are located primarily in the United States. If you access our Services from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

For transfers from the EEA, UK, or Switzerland, we rely on:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions where applicable
• Your explicit consent where appropriate

By using our Services, you consent to the transfer of your information to the United States and other jurisdictions as described in this Privacy Policy.

10. Third-Party Tracking and Advertising

We use third-party advertising and analytics services that collect information about your online activities across websites and devices. These services include:

10.1 Meta/Facebook Pixel

We use the Meta Pixel to track conversions, optimize ad delivery, and build audiences for advertising campaigns. This involves sharing data such as your IP address, browser information, and actions taken on our website with Meta Platforms, Inc.

10.2 Google Analytics

We use Google Analytics to understand how visitors interact with our website. You can opt out using the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout

10.3 Interest-Based Advertising

We participate in interest-based advertising. You can opt out of interest-based advertising through:

• Network Advertising Initiative: https://optout.networkadvertising.org/
• Digital Advertising Alliance: https://optout.aboutads.info/
• European Interactive Digital Advertising Alliance (for EU): https://www.youronlinechoices.eu/

11. Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar technologies. For detailed information, please see our separate Cookie Policy.

Types of Cookies We Use:

• Essential Cookies: Required for basic website functionality
• Analytics Cookies: Help us understand how visitors use our site
• Advertising Cookies: Used to deliver relevant advertisements
• Preference Cookies: Remember your settings and preferences

Managing Cookies:

You can control cookies through your browser settings. Note that disabling cookies may limit certain features of our website. Most browsers allow you to refuse cookies or alert you when cookies are being sent.

12. Do Not Track Signals

Our website does not currently respond to "Do Not Track" (DNT) browser signals. There is no industry consensus on how to respond to DNT signals, and we will continue to monitor developments in this area.

13. Third-Party Links

Our website may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices, content, or security of these external sites. We encourage you to review the privacy policies of any third-party sites before providing information. This Privacy Policy applies only to our Services.

14. Children's Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we discover we have collected information from a child under 18, we will promptly delete it. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@noluckleads.com.

15. 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 update the "Last updated" date at the top of this policy
• We will notify you by email (if we have your email address) at least 30 days before changes take effect
• We may post a prominent notice on our website

Your continued use of our Services after changes become effective constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

16. State-Specific Privacy Rights

16.1 California Residents (CCPA/CPRA)

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

• Right to Know: You have the right to know what personal information we collect, use, share, or sell about you
• Right to Delete: You can request deletion of your personal information, subject to certain exceptions
• Right to Correct: You can request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: You can opt out of the "sale" or "sharing" of your personal information
• Right to Limit Use of Sensitive Personal Information: You can limit our use of sensitive personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

Authorized Agents: You may designate an authorized agent to submit requests on your behalf. We may require written authorization and verification of both your identity and the agent's authority.

Response Timing: We will respond to verifiable consumer requests within 45 days, which may be extended by an additional 45 days if necessary.

16.2 Virginia Residents (VCDPA)

Virginia residents have rights under the Virginia Consumer Data Protection Act (VCDPA), including:

• Right to confirm processing and access your personal data
• Right to correct inaccuracies
• Right to delete your personal data
• Right to obtain a copy of your data in a portable format
• Right to opt out of targeted advertising, sale of personal data, and profiling

To appeal our decision on a request, email privacy@noluckleads.com with subject "VCDPA Appeal."

16.3 Colorado Residents (CPA)

Colorado residents have rights under the Colorado Privacy Act (CPA) similar to those described above for Virginia residents, including access, correction, deletion, portability, and opt-out rights.

16.4 Connecticut Residents (CTDPA)

Connecticut residents have rights under the Connecticut Data Privacy Act (CTDPA) similar to those described above for Virginia residents.

16.5 Utah Residents (UCPA)

Utah residents have rights under the Utah Consumer Privacy Act (UCPA), including access, deletion, and opt-out rights.

16.6 Nevada Residents

Nevada residents may submit a request directing us not to sell their personal information. To submit such a request, email privacy@noluckleads.com with subject "Nevada Do Not Sell Request."

17. Data Processing Agreement

For business clients who require a Data Processing Agreement (DPA) for GDPR or other compliance purposes, please contact us at privacy@noluckleads.com. We can provide a DPA that includes:

• Description of processing activities
• Technical and organizational security measures
• Sub-processor disclosures
• Data subject rights procedures
• Data breach notification procedures
• Standard Contractual Clauses for international transfers

18. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

For GDPR-related inquiries: If you are in the EEA and have concerns about our data practices that we have not adequately addressed, you have the right to lodge a complaint with your local data protection authority.