Privacy Policy

Inner Circle Leads LLC ("Inner Circle Leads," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, sell, share, and protect personal information when you visit our website, respond to our ads, complete a lead form, submit information through Meta Instant Forms, or otherwise interact with us.

Inner Circle Leads LLC is a lead generation and marketing company. We are not an insurance carrier. We do not issue, underwrite, approve, price, or service insurance policies.

When you submit information to us, we may share, sell, transfer, or disclose your information to licensed insurance agents, insurance agencies, insurance carriers, marketing partners, lead buyers, and service providers so they may contact you about life insurance, Indexed Universal Life, annuities, and related insurance products.

By using our website, submitting a form, or interacting with our ads, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We may collect personal information directly from you, from advertising platforms, from service providers, and from lead verification or compliance tools.

The information we collect may include:

Contact information

Name, phone number, email address, mailing address, and state of residence.

Lead form and quiz information

Information you submit through a form, quiz, or Meta Instant Form, including age, business type, owner status, income range, funding capacity, insurance status, family/dependent information, retirement account or lump-sum information, financial concerns, policy interests, and timing for reviewing options.

Insurance-related information

Information about your interest in life insurance, Indexed Universal Life, annuities, living benefits, death benefit protection, cash value potential, mortgage protection, income replacement, or other related products.

Health-related information you choose to provide

We may collect basic health-related responses if you voluntarily provide them as part of a form, quiz, or agent review process. We do not collect medical records through our website or lead forms.

Technical and device information

IP address, browser type, device type, operating system, referring URL, pages visited, time on page, cookies, pixels, analytics data, ad campaign data, Meta Lead ID, form ID, ad ID, ad set ID, and similar online identifiers.

Consent and compliance records

We may collect and store records related to your consent, including timestamp, ad source, lead source, form version, disclosure language shown, consent checkbox status, TrustedForm certificate data, LeadConduit data, IP address where available, and delivery records.

2. How We Use Your Information

We may use your information to:

• Respond to your request for information.
• Match you with licensed insurance agents, agencies, carriers, or marketing partners.
• Route your inquiry based on age, state, product interest, income range, funding capacity, and other eligibility-related information.
• Allow licensed agents or agencies to contact you about life insurance, Indexed Universal Life, annuities, and related insurance products.
• Confirm, document, and verify your consent to be contacted.
• Operate, maintain, and improve our websites, landing pages, ads, forms, and lead funnels.
• Analyze ad performance, lead quality, and campaign effectiveness.
• Prevent fraud, abuse, unauthorized submissions, or misuse of our services.
• Maintain suppression, opt-out, and Do Not Call records.
• Comply with applicable laws, regulations, legal processes, and contractual obligations.
• Protect our rights, property, users, partners, and business.

3. How We Share, Sell, Or Disclose Information

Because Inner Circle Leads LLC is a lead generation company, we may share, sell, transfer, or disclose your personal information to third parties, including:

Licensed insurance agents and agencies

We may share or sell your information to licensed insurance agents and agencies so they may contact you about life insurance, Indexed Universal Life, annuities, and related insurance products.

Insurance carriers and product providers

Where appropriate, your information may be shared with insurance carriers or product providers to help determine product availability, underwriting requirements, or policy options.

Marketing partners and lead buyers

We may share or sell your information to marketing partners or lead buyers who are expected to use the information only for the purposes disclosed at the time of collection and in this Privacy Policy.

Service providers and vendors

We may share information with vendors that help us operate our business, including CRM platforms, lead-routing platforms, form providers, analytics vendors, call tracking vendors, email/SMS providers, cloud hosting providers, compliance vendors, fraud prevention vendors, and data storage providers.

TrustedForm, ActiveProspect, LeadConduit, and consent verification vendors

We may share information with consent verification and lead-routing providers to document your consent, verify lead authenticity, and support legal compliance.

Advertising and analytics platforms

We may share certain online activity data with advertising platforms, analytics providers, and retargeting vendors to measure, optimize, and improve our marketing.

Legal and compliance parties

We may disclose information to attorneys, regulators, courts, law enforcement, or other parties when we believe disclosure is required or appropriate to comply with law, enforce agreements, prevent fraud, or protect rights and safety.

Business transfers

If we are involved in a merger, acquisition, sale of assets, financing, restructuring, or similar transaction, your information may be transferred as part of that transaction.

4. Licensed Agent Contact

By submitting a form, quiz, or lead request, you understand that a licensed insurance agent, agency, carrier, or marketing partner may contact you by phone, text, or email to discuss insurance options.

The agent or agency that contacts you is responsible for discussing product availability, suitability, underwriting, pricing, policy details, and licensing requirements.

Inner Circle Leads LLC does not guarantee approval, rates, policy availability, coverage amounts, cash value performance, tax treatment, living benefit availability, or suitability of any product.

5. Calls, Texts, Emails, And Consent

Where you provide consent, you authorize Inner Circle Leads LLC and its licensed insurance agent, agency, carrier, and marketing partners to contact you by phone, text message, and email about life insurance, Indexed Universal Life, annuities, and related insurance products.

This contact may include the use of automated dialing systems, artificial or prerecorded voice messages, SMS/MMS messages, and other communication technologies where permitted by law.

Consent is not required as a condition of purchasing any product or service. Message and data rates may apply.

You may opt out at any time by replying STOP to text messages, following unsubscribe instructions in emails, telling a caller you do not want to be contacted, or emailing us at [email protected].

We may maintain records of your consent, opt-out requests, call attempts, message history, and related compliance information.

6. Opt-Out And Do Not Call Requests

You may opt out of future communications at any time.

To opt out of texts, reply STOP.

To opt out of emails, use the unsubscribe link or contact us directly.

To request no further calls, tell the caller or contact us by email.

Contact us for opt-out requests:

We maintain internal suppression and opt-out records. If your information has already been shared with a licensed agent, agency, carrier, or marketing partner, you may also need to make your opt-out request directly to that party.

7. Cookies, Pixels, And Tracking Technologies

We may use cookies, tracking pixels, server-side tracking, analytics tools, and similar technologies to operate our website, measure ad performance, understand visitor behavior, improve landing pages and forms, prevent fraud, retarget visitors with relevant advertising, and attribute leads to campaigns, ads, and traffic sources.

These tools may collect information such as IP address, device type, browser type, pages visited, ad source, click IDs, and interaction data.

You can control cookies through your browser settings. Some browser settings may affect how our website functions.

8. Sale Or Sharing Of Personal Information

We may sell or share personal information as those terms are defined under applicable state privacy laws.

This may include sharing or selling lead information to licensed insurance agents, agencies, carriers, and marketing partners so they may contact you about insurance products and related services.

It may also include sharing online identifiers or advertising data with advertising and analytics platforms for targeted advertising, retargeting, measurement, and optimization.

You may request to opt out of the sale or sharing of your personal information by emailing [email protected] with the subject line "Do Not Sell Or Share My Personal Information."

You may also submit a request through our privacy choices page: tradesemanlifeinsurance.com/privacy-choices

9. State Privacy Rights

Depending on where you live, you may have rights under applicable state privacy laws. These rights may include the right to:

• Know what personal information we collect, use, disclose, sell, or share.
• Access personal information we maintain about you.
• Correct inaccurate personal information.
• Delete personal information, subject to legal exceptions.
• Obtain a copy of your personal information.
• Opt out of the sale or sharing of personal information.
• Opt out of targeted advertising.
• Limit the use or disclosure of sensitive personal information where applicable.
• Appeal a denied privacy request where applicable.
• Not be discriminated against for exercising privacy rights.

To exercise your rights, contact us at:

We may need to verify your identity before fulfilling certain requests. Verification may require matching information you provide with information we already maintain.

10. California Privacy Notice

This section applies to California residents.

In the past 12 months, we may have collected, used, disclosed, sold, or shared the following categories of personal information:

• Identifiers, including name, phone number, email, IP address, and lead ID.
• Personal information categories, including contact details, state, age, and form responses.
• Commercial information, including product interests, policy interests, and lead source.
• Internet or network activity, including website visits, ad clicks, and device data.
• Geolocation data, including approximate location from IP or state selection.
• Professional or employment-related information, including business type, owner status, and income type.
• Inferences, including product interest, qualification indicators, lead scoring, routing, and campaign optimization.
• Sensitive personal information, including health-related responses, income ranges, and financial ranges, if voluntarily provided.

We may disclose, sell, or share these categories of information with licensed insurance agents, agencies, carriers, marketing partners, service providers, advertising platforms, analytics providers, compliance vendors, CRM providers, and legal/compliance parties.

California residents may request access, deletion, correction, and opt-out of sale or sharing by emailing [email protected] with the subject line "Do Not Sell Or Share My Personal Information" or by submitting a request through tradesemanlifeinsurance.com/privacy-choices.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including lead delivery, agent matching, legal compliance, fraud prevention, dispute resolution, suppression management, and business records.

We may retain consent, lead source, communication, and compliance records for an extended period, including where appropriate for telemarketing, consent, legal defense, and compliance purposes.

12. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, loss, misuse, disclosure, or alteration.

However, no website, system, transmission, or storage method is completely secure. We cannot guarantee absolute security.

13. Children's Privacy

Our website, ads, forms, and services are intended for adults. We do not knowingly collect personal information from children under 18.

If you believe a child has submitted personal information to us, contact us and we will take appropriate steps to delete the information.

14. Third-Party Websites And Services

Our website, ads, forms, or communications may link to third-party websites or services, including Meta, insurance agencies, carriers, CRM tools, or other service providers.

We are not responsible for the privacy practices, content, or security of third-party websites or services. You should review their privacy policies before providing information to them.

15. Financial And Insurance Product Disclaimer

Inner Circle Leads LLC is a lead generation and marketing company.

We do not issue insurance policies, approve applications, determine underwriting eligibility, provide tax advice, provide legal advice, or guarantee product availability.

Any insurance product, including life insurance, Indexed Universal Life, annuities, or related products, is subject to eligibility, underwriting, carrier approval, state availability, policy terms, funding, and policy design.

Policy features vary. Not all applicants qualify. Cash value growth, policy loan access, living benefits, tax treatment, and other features depend on the policy, carrier, funding, underwriting, and applicable law.

You should consult a licensed insurance agent and, where appropriate, a qualified tax, legal, or financial professional before making decisions.

16. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this page.

Your continued use of our website, forms, or services after any update means you accept the revised Privacy Policy.

17. Contact Us

For questions, privacy requests, opt-out requests, or Do Not Sell or Share requests, contact us at: