Privacy Policy

This Privacy Policy is published by Inner Circle Leads, an Arizona limited liability company, doing business as Inner Circle Leads ("Inner Circle," "we," "us," "our"). It explains what personal information we collect, how we use it, who we share it with, and the choices and rights you have.

We handle personal information for two very different groups, and we address each separately:

• Section A — Agents: licensed insurance producers, agencies, and their staff who hold an account with us, pay membership fees, and purchase leads.
• Section B — Consumers: people who respond to our advertising and submit a quote or information request through a platform lead form or one of our landing pages.
• Section C — For Everyone: rights, retention, cookies, security, and other matters that apply to everyone.

Who We Are

Inner Circle Leads is an advertising, lead generation, and sales-technology company. We run advertising campaigns on social media and digital platforms, collect consumer requests through platform lead forms and landing pages, deliver those requests to licensed insurance professionals who purchase them, and provide a technology platform those professionals use to follow up.

We are not an insurance company, agency, or broker, and we are not affiliated with or endorsed by any government agency or program, including the Social Security Administration, the Department of Veterans Affairs, or Medicare. We are compensated by the insurance professionals who receive consumer requests. We do not charge consumers.

Section AAgents

A1. Information We Collect From Agents

• Business and contact information: name, agency name, business address, email, telephone number.
• Licensing information: producer license numbers, resident and non-resident states, lines of authority, carrier appointments, National Producer Number.
• Account credentials and authentication data.
• Payment metadata: card brand, expiration date, last four digits, and billing address. Full card numbers and security codes are collected directly by our payment processor and do not reach our systems.
• Platform activity: leads purchased, delivered, worked, and dispositioned; contact attempts placed through platform channels; call and message logs for platform-connected communications, which may include recordings and transcripts where recording is enabled; compliance attestations and acknowledgments; support communications.
• Technical data: IP address, device and browser information, login timestamps, and usage data.
• Tax information where required for reporting.

A2. How We Use Agent Information

• To provide membership services: onboarding, platform provisioning, lead routing and delivery, dialer and messaging integrations, and support.
• To bill you and manage your account, including recurring membership charges and lead purchases.
• To operate compliance controls: propagating do-not-contact suppression, enforcing calling windows and frequency caps on platform channels, logging attestations, auditing contact activity, and investigating consumer complaints.
• To communicate with you about your account, deliveries, billing, compliance, and our services, including through automated and AI-assisted tools as described in A4.
• To improve our platform, advertising, and services, and to produce aggregated analytics.
• To protect against fraud and abuse, enforce our agreements, and comply with law.

A3. How We Share Agent Information

We do not sell Agent account information, and it is not part of any lead product. We share it only:

• with service providers that process it on our instructions — cloud hosting, CRM and marketing automation (including GoHighLevel), telephony and messaging providers, payment processors, email delivery, analytics, and professional advisors;
• with consumers, when necessary to respond to a complaint or privacy request — for example, telling a consumer which professional received their information when they ask, as state law may require;
• with regulators, carriers, or law enforcement where legally required, in response to a subpoena or legal process, or to protect rights, safety, or the integrity of our services; and
• with a successor or acquirer in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy continuing to apply.

A4. Communications With Agents, Including Automated And AI-Assisted Tools

We communicate with Agents by email, text, phone, and in-platform notification. Some of those communications are automated, and some are AI-assisted — for example, automated delivery and opt-out notices, chat-based support assistants, and AI-assisted outreach about your account or our services. Where you are interacting with an automated or AI system rather than a person, we will say so, and you may ask for a human.

By providing your telephone number, you agree that we may call or text you at it — including using automated dialing or texting technology, and artificial, prerecorded, or AI-generated voice — about your account and our services. Marketing consent is not a condition of purchase. You may opt out of marketing calls and texts at any time by replying STOP or emailing [email protected]. Transactional and compliance notices continue for as long as you hold an account.

A5. Consumer Data You Receive From Us

When we deliver a lead to you, you become responsible for that consumer's personal information on your own systems. Your rights and obligations in it — permitted use, security, deletion on request, honoring suppression, and no resale — are set out in Sections 7 and 8 of the Agent Membership Agreement. This Privacy Policy tells consumers that we will notify you of their deletion and opt-out requests and require you to honor them.

Section BConsumers

B1. Where We Collect Consumer Information

We collect consumer information in two ways:

Platform lead forms. Most consumer requests are submitted through lead forms native to the advertising platform where you saw our ad (for example, Meta Instant Forms on Facebook and Instagram, or TikTok lead forms). The platform collects your responses and provides them to us. The consent language and disclosures you saw on that form, and the platform's record of your submission, are retained by us as the record of your consent.

Our landing pages. Some advertisements direct you to a landing page we operate, where you complete a form. On those pages, we use an independent consent certification service that records your session as described in B4.

B2. Information Consumers Give Us

When you complete a form, we collect what you enter, which typically includes:

• Identifiers: first and last name, ZIP code or address, email address, telephone number.
• Demographic information: date of birth or age range, gender, state of residence, marital status.
• Insurance-related information you choose to provide: the type and amount of coverage you are interested in, whether you currently have coverage, beneficiary relationship, general health and tobacco-use responses relevant to a life insurance quote, employment or income range, and military or veteran status where relevant to the product advertised.
• Your consent selections: which consent checkboxes you checked, the exact disclosure text you were shown, and when.

Some of this may be treated as sensitive personal information under certain state laws — health-related responses in particular. We collect only what is needed to route your request to an appropriate licensed professional, and we do not use sensitive personal information to infer characteristics about you.

We do not ask for and do not want your Social Security number, driver's license number, financial account numbers, or payment card information. Do not enter them into our forms. If a licensed professional later needs any of that for an actual insurance application, that exchange is between you and them, under their privacy practices.

B3. Information We Collect Automatically Or Receive From Others

• Technical and interaction data on our landing pages: IP address, browser and device information, referring URL, pages viewed, form-field interactions, and submission timestamps.
• Campaign attribution: which advertisement, ad set, creative, and platform brought you to the form, and any click identifiers the platform passes to us.
• From advertising platforms: your form responses (for platform lead forms) and campaign performance data.
• From consent certification vendors: a certificate and session record documenting your landing-page submission (B4).
• From data validation vendors: whether a telephone number is active, its line type, whether it has been reassigned, and whether it appears on do-not-call registries.
• From the licensed professional who received your request: dispositions — whether they reached you, whether you asked not to be contacted, and whether your information was inaccurate.
• From communications with you: records of calls, texts, and emails placed through our platform, including recordings and transcripts where recording is enabled and disclosed, and AI-generated summaries of those communications.

B4. Session Recording On Our Landing Pages

On landing pages we operate, we record your interaction with the form. An independent third-party consent certification service captures the page as displayed to you, your interactions with it, the consent language you were shown, which boxes you checked, your IP address, and the timestamp of your submission, and issues a certificate we retain.

We do this for one reason: so that if there is ever a dispute about whether you agreed to be contacted, there is an independent, tamper-evident record of exactly what you saw and did. It is limited to our lead forms, is configured to mask sensitive field content where feasible, is not used for advertising or profiling, and is never sold.

Platform-native lead forms are not recorded by us; the platform's own submission record serves as the record of your consent there.

B5. How We Use Consumer Information

• To deliver what you asked for: to connect you with a licensed insurance professional who can discuss coverage with you. That is what the advertisement offered and what your submission requested.
• To contact you about your request, by us and by the licensed professional to whom it is directed, consistent with the consent you gave (B7).
• To document consent and defend its integrity (B4).
• To operate our business: routing, delivery, billing the professionals who purchase requests, support, improving our advertising, and aggregated analytics that do not identify you.
• To honor your choices: maintaining do-not-contact and suppression records, and propagating your opt-out and deletion requests.
• To protect against fraud and abuse and to comply with law.

B6. How We Share And Sell Consumer Information

We sell consumer lead information. When you submit a request, we provide your information — including your name, telephone number, email address, and the insurance-related information you entered — to a licensed insurance professional who pays us for it. Under the privacy laws of California, Colorado, Connecticut, Texas, Virginia, and other states, this is a "sale" of personal information, and it may also be a "share" for targeted advertising. We say so plainly.

How assignment works

• Your request is provided to one licensed insurance agent or agency at a time. That professional has an exclusive period in which to contact you.
• If they do not reach you within that period, your request may later be provided to a different licensed professional, so that someone follows up on the request you made. Your consent, as shown on the form, covers contact by the professional to whom your request is directed at any given time.
• Once you tell anyone — us or any agent — to stop, your information is suppressed and is never provided to another professional.

After delivery, the professional controls their copy of your information under their own privacy practices, licensing obligations, and applicable law. We contractually require them to use it only for insurance marketing, sales, and servicing; to honor your do-not-contact and deletion requests; and not to resell or redistribute it. We enforce those terms, but we do not control their systems.

We also share consumer information with

• Service providers that process it on our instructions: cloud hosting; CRM and marketing automation (including GoHighLevel); telephony, messaging, and AI communication providers; consent certification; data validation and DNC scrubbing; email delivery; analytics; and professional advisors.
• Advertising platforms, in the form of limited data (typically hashed identifiers and conversion events) used to measure and optimize campaigns and build audiences. Depending on your state, this may qualify as "sharing" for targeted advertising, and you may opt out (C1).
• Legal and corporate recipients as described in A3.

We do not sell sensitive personal information for the purpose of inferring characteristics about you, and we do not knowingly sell the personal information of anyone under 18.

B7. Calls, Texts, And Emails — Including Automated And AI-Assisted Contact

What you agreed to. The consent language displayed on the form at the moment you submitted it governs how we and the receiving professional may contact you. That language is versioned and archived, and you may request a copy of the exact text you were shown by emailing [email protected].

Automated and AI-assisted contact. Where the consent you gave authorizes it, contact from us and from the licensed professional handling your request may be made using automated dialing and texting technology, AI-assisted text and email messaging, and artificial, prerecorded, or AI-generated voice calls. This means some texts, emails, and calls you receive may be generated or conducted by an automated or artificial-intelligence system rather than a person. Where the law requires it, automated and AI communications will identify themselves as such, and you may ask at any time to speak with a licensed person instead. Communications may be recorded or transcribed where permitted by law and disclosed to you.

Text messaging. Message frequency varies; message and data rates may apply; reply STOP to cancel and HELP for help; consent to texts is not a condition of any purchase. Your mobile number and your SMS consent are provided only to the licensed insurance professional handling your request and are never sold or shared with any other third party for unrelated marketing.

How to stop — any reasonable method works. You can withdraw consent at any time, by any reasonable means:

• Reply STOP to any text (or any words that reasonably convey a stop request)
• Tell anyone who calls you — including an automated or AI caller — to stop calling, in any wording
• Email [email protected]
• Use the unsubscribe link in any email

Federal rules give us ten business days to process a revocation; our internal standard is one business day. A revocation received on any channel stops marketing calls, texts, and emails from us and from every professional to whom we provided your information. We add you to a permanent internal suppression list, and your information is not provided to any further professional. You may still receive contact for a short period while suppression propagates, or from a professional who obtained your information from a source other than us; if contact continues, tell us and we will address it.

Section CFor Everyone

C1. Your Privacy Rights

Depending on where you live, you may have the right to know and access the personal information we hold about you and the categories of third parties we disclosed or sold it to; to receive a portable copy; to correct inaccuracies; to delete it, subject to legal exceptions; to opt out of sale and of sharing for targeted advertising; to limit the use of sensitive personal information; to opt out of profiling that produces legal or similarly significant effects; to appeal a denial; and not to be discriminated against for exercising these rights.

These rights are provided by law to residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, among others. We extend the substance of these rights to residents of every state.

How to exercise them:

• Email [email protected] with the subject "Privacy Request"
• Use the web form at https://innercircleleads.com/privacy-request
• Click "Do Not Sell or Share My Personal Information" in the footer of every page
• Call [TOLL-FREE NUMBER]
• Write to the address above

We will verify your identity using information associated with your submission or account and respond within 45 days, extendable once by 45 days with notice. Authorized agents may submit requests with written proof of authority. To appeal a denial, reply to our decision with the subject "Privacy Appeal"; if we deny the appeal, you may contact your state attorney general.

Global Privacy Control. We honor GPC and similar browser-level opt-out preference signals as a valid opt-out of sale and sharing for the browser sending them.

An important limit on deletion. Once a consumer's information has been provided to a licensed professional, we can delete our copy but cannot delete theirs. We will notify them of the request and contractually require them to honor it; you may also need to contact them directly, and we will tell you who received your information if you ask. We also retain consent and suppression records after a deletion request, because we are legally required to be able to demonstrate that we honored your opt-out. We retain the minimum necessary for that purpose.

No financial incentives. We do not offer consumers financial incentives in exchange for personal information.

C2. Retention

C3. Cookies And Tracking

We use strictly necessary cookies (session integrity, security, form function); analytics cookies (site and campaign performance); advertising cookies and pixels, including advertising-platform pixels, to measure conversions and build audiences; and, on landing pages, the session recording described in B4. Where required, we present a consent banner before non-essential technologies load. You can control cookies through your browser and opt out of sale/sharing via the footer link or GPC. We do not respond to browser Do Not Track signals, which lack a common standard, but we do honor GPC.

C4. Security

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the data: encryption in transit and at rest for sensitive fields, role-based and least-privilege access, logging and monitoring, vendor security review, and an incident response plan. No system is perfectly secure. If a breach affecting your personal information occurs, we will notify you and applicable regulators as required by law.

C5. Children

Our services are for adults. We do not knowingly collect personal information from anyone under 18, do not market insurance products to minors, and do not knowingly sell a minor's personal information. If you believe a minor's information was submitted, contact [email protected] and we will delete it.

C6. Other Notices

Nevada residents may opt out of the sale of certain covered information by sending a verified request to [email protected].

California "Shine the Light": you may request information about disclosures to third parties for their direct marketing purposes.

Third-party sites: this Policy does not apply to sites we do not control, including those of insurance professionals, carriers, and advertising platforms.

United States only: our services are directed to U.S. residents and our systems are in the United States.

C7. Changes To This Policy

We will post updates here with a new effective date. For material changes to how we use or share previously collected information, we will provide additional notice — by email or a prominent notice on the Site — before the change takes effect. Prior versions are archived and available on request.