Privacy Policy
Effective date: [Month Day, Year] · Last updated: [Month Day, Year]
Template: requires review and customization before publication. This draft must be reviewed by qualified U.S. legal counsel and updated to reflect the company's actual data practices, vendors, campaigns, applicable state laws and thresholds. A privacy policy alone does not make a business compliant.
1. Who we are
[Registered legal entity name], doing business as Phoenix Leads Network ("Phoenix Leads Network," "we," "us"), is a lead generation company located at [business address]. We generate consumer inquiries through digital advertising and online forms and provide those inquiries to businesses that buy leads.
2. Scope
This policy covers personal information we collect:
- from visitors to this website;
- from business customers and prospective lead buyers; and
- from consumers who submit inquiries through online forms we operate or that are operated for our campaigns ("campaign forms").
Each campaign form also displays its own disclosure explaining who is collecting the information, why, and with whom it may be shared. If a campaign form disclosure is more specific than this policy, the form disclosure describes how that submission is handled.
3. Information we collect
| Category | Examples | Source |
|---|---|---|
| Identifiers and contact details | Name, email address, phone number, postal address, ZIP code | You, through our forms |
| Inquiry information | Service requested, property or household details you choose to provide, timeframe, answers to form questions | You, through campaign forms |
| Business information | Company name, role, website, lead requirements | Business customers and prospects |
| Consent and disclosure records | Date and time of submission, the disclosure version shown, consent choices, page URL | Generated when you submit a form |
| Internet and device information | IP address, browser type, pages viewed, referring ad or page | Your browser, our service providers |
| Inferences | [Describe only if actually created, e.g. eligibility for a campaign based on answers given] | Derived from the above |
[State whether any sensitive personal information is collected for any campaign (for example, health or financial information). If so, describe it, its purpose and any right to limit its use. Remove this note if none is collected.]
4. How we use information
- To operate campaigns and process consumer inquiries.
- To match inquiries with businesses as described in the campaign form disclosure.
- To respond to business inquiries, provide services to buyers and administer agreements.
- To maintain consent, disclosure and transaction records.
- To detect fraud, duplicates and invalid submissions, and to secure our systems.
- To measure and improve advertising and website performance.
- To comply with legal obligations and enforce our terms.
5. Sharing and sale of personal information
Lead buyers. Our business is providing consumer inquiries to businesses. When you submit a campaign form, we provide your information to the business or businesses described in that form's disclosure, in exchange for payment. Under some state laws this is a "sale" of personal information. Depending on the campaign, your information may go to one business (exclusive) or to more than one business (shared). The disclosure on each form explains which applies.
Categories of recipients may include: [list actual buyer categories, e.g. home service contractors, licensed insurance agencies].
Service providers. We use vendors for hosting, form processing, email, analytics, advertising and security, under contracts that limit their use of personal information.
Advertising partners. [Describe any pixels or tags that share data with advertising platforms for cross-context behavioral advertising, or state that none are used.]
Legal and business transfers. We may disclose information to comply with law, respond to lawful requests, protect rights and safety, or as part of a merger, acquisition or sale of assets.
6. Calls, texts and emails
If you submit a campaign form, the business or businesses that receive your information may contact you using the methods you agreed to on that form. We do not treat a form submission as permission for every type of call, text or email. You can revoke consent or ask not to be contacted at any time by telling the business that contacted you, and by contacting us using the details below. You may also register your number on the National Do Not Call Registry at donotcall.gov.
7. Cookies, analytics and privacy signals
See our Cookie Notice for the technologies used on this website. We treat a Global Privacy Control (GPC) signal as a valid request to opt out of the sale or sharing of personal information associated with that browser, where required by law.
8. Retention
We keep personal information only as long as needed for the purposes described above, including keeping consent and transaction records for [retention period] to meet legal, dispute and audit requirements. [Add retention periods or criteria for each category.]
9. Security
We use administrative, technical and physical safeguards designed to protect personal information, including access controls and encryption in transit. No method of transmission or storage is completely secure.
10. Your privacy rights
Depending on where you live, you may have the right to:
- know or access the personal information we hold about you;
- delete or correct your personal information;
- obtain a portable copy of your information;
- opt out of the sale or sharing of your personal information, targeted advertising, or certain profiling; and
- appeal our decision on your request.
To make a request, visit Your Privacy Choices or call [toll-free number]. We will verify your request using information we already hold. You may use an authorized agent where permitted by law. We will not discriminate against you for exercising your rights.
11. Additional disclosures for California residents
[If the California Consumer Privacy Act applies, include: categories of personal information collected, sold, shared and disclosed for a business purpose in the past 12 months; categories of sources and recipients; purposes; retention; the right to limit use of sensitive personal information if applicable; whether we have actual knowledge of selling or sharing information of consumers under 16; and request metrics if required.]
You can opt out of the sale or sharing of your personal information at Do Not Sell or Share My Personal Information.
[Add any state data broker registration disclosures that apply after legal review.]
12. Children
Our website and campaigns are intended for adults. We do not knowingly collect personal information from children under 13, and we do not knowingly sell or share personal information of consumers under 16. [Confirm age thresholds with counsel.]
13. Changes to this policy
We will update this policy when our practices change and revise the "last updated" date above. Material changes will be highlighted on this page.
14. Contact us
Email: [business email]
Phone: [toll-free number]
Mail: [registered business address]