LeadFunl

LeadFunl Subscriber Privacy Policy

Effective Date: September 24, 2026
Last Updated: September 24, 2026

Applies to: Subscribers and prospective subscribers of LeadFunl, LLC's services, including users of LeadFunl's mobile applications. This policy does NOT apply to consumer prospects or leads delivered through LeadFunl; consumer-facing privacy practices are governed by the separate Privacy Policy located at https://privacy.leadfunl.com/.


1. Who We Are

LeadFunl, LLC ("LeadFunl," "Company," "we," "us," or "our") is a California limited liability company. LeadFunl operates a subscriber-facing platform that connects licensed financial professionals — including financial advisors, investment adviser representatives, and licensed insurance and annuity professionals — with exclusive, qualified consumer leads and appointments related to retirement planning and Roth conversion strategies, and provides ancillary subscription services described in the Subscriber Agreement. LeadFunl also offers, or may offer, native mobile applications for iOS (Apple App Store) and Android (Google Play Store) that provide subscribers and authorized users with lead performance metrics, AI conversation transcripts, voice memo to-do management, and related features (the "Mobile Apps").

This Subscriber Privacy Policy describes how we collect, use, disclose, retain, and protect information about Subscribers, prospective Subscribers, Mobile App users, and visitors to the subscriber-facing portions of our website and services (collectively, "Subscriber Data" or "Your Information").

2. Scope and Acknowledgment

By creating an account, accessing the Service, installing or using the Mobile Apps, granting any device-level permission to the Mobile Apps, or providing information to LeadFunl as a Subscriber or prospective Subscriber, you acknowledge and agree to this Subscriber Privacy Policy in its entirety. If you do not agree, you must not access or use the Service or the Mobile Apps.

This policy is governed by the laws of the State of California, without regard to conflict-of-laws principles. To the maximum extent permitted by law, you waive any conflict-of-laws argument that another jurisdiction's privacy law applies to LeadFunl's processing of your information, except where such waiver is prohibited by the law of your domicile.

3. Information We Collect

We collect, generate, and process the following categories of information about you:

3.1 Information You Provide Directly

3.2 Information We Collect Automatically

3.3 Information We Collect From Third Parties

3.4 Information From Third-Party Social Media Services

LeadFunl allows you to create an account and log in to use the Service through the following Third-Party Social Media Services:

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal Data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities, or your contact list associated with that account.

You may also have the option of sharing additional information with LeadFunl through your Third-Party Social Media Service's account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving LeadFunl permission to use, share, and store it in a manner consistent with this Privacy Policy.

You acknowledge that whether LeadFunl uses these Third-Party Social Media Services on your behalf, or whether you yourself use these services in connection with your account, the privacy policies, terms of service, and data practices of those Third-Party Social Media Services continue to apply to information processed through them. LeadFunl has no control over, and assumes no responsibility for, the privacy practices of any Third-Party Social Media Service. Links to the relevant policies are provided in Section 7.

3.5 Information We Collect Through the Mobile Apps

If you install and use LeadFunl's iOS or Android Mobile Apps and grant the corresponding device-level permissions, we collect the following additional categories of information:

(a) Voice audio recordings. When you use the Mobile Apps' voice memo feature, we capture and store the raw audio file you record, along with associated metadata (timestamp, device identifier, app version). Voice recordings are processed by third-party speech-to-text providers (which may include OpenAI Whisper, AssemblyAI, Deepgram, Anthropic, or device-native speech recognition APIs) to generate transcriptions. Both the original audio recording and the resulting transcription are retained per the retention schedule in Section 12.

(b) Voice transcriptions. Text transcriptions generated from voice recordings, including any structured data extracted from those transcriptions (e.g., to-do items, dates, locations mentioned).

(c) Geolocation data. When you grant location permissions, we collect the device's latitude and longitude coordinates at the time of voice memo creation or other location-tagged actions, along with derived information such as city, state, and country. We use this for location-tagging of voice memos, location-aware to-do scheduling, and analytics. You may revoke location permissions at any time via your device's operating system settings.

(d) Microphone access. Required for voice memo recording. We do not record audio passively or in the background; recordings are initiated only by your active interaction with the voice memo feature.

(e) Calendar data. When you grant calendar permissions, we read your existing calendar events (to detect free slots for to-do scheduling and avoid conflicts) and create calendar events on your device-native calendar (Apple Calendar, Google Calendar, or other supported calendar providers). The Mobile Apps create a single rolling "Daily To-Do" calendar entry that expands to display the full transcribed list of voice memo items. We do not transmit calendar data outside your device unless you explicitly enable cloud sync.

(f) Push notification data. Push notification tokens, delivery status, open rates, and notification preferences. We use push notifications for to-do reminders, lead activity alerts, and operational notifications.

(g) Device identifiers and diagnostic data. Device model, operating system version, app version, network connection type, IP address, time zone, language, advertising identifier (where applicable and not blocked by user), crash reports, and performance diagnostic data.

(h) Photos and camera access. If you grant photo or camera permissions, we may collect photos you attach to voice memos, document scans, or profile pictures.

(i) App interaction data. Screens viewed, features used, time spent in each section, taps and swipes, search queries within the app, and similar usage analytics.

(j) Cross-device sync data. If you enable cross-device sync, your voice memos, transcriptions, and to-do items may be transmitted to and stored on LeadFunl's servers and synchronized across your authenticated devices.

You may revoke any of the device-level permissions described above through your device's operating system settings at any time. Revocation will disable the corresponding feature; for example, revoking microphone access will disable voice memo recording. LeadFunl is not liable for reduced functionality resulting from permission revocation.

3.6 Information About Your Use of AI Features

Where you interact with AI-powered features of the Service, we collect your inputs (text, voice, file uploads), the AI's outputs returned to you, contextual metadata, and any feedback or corrections you provide. This information is used to operate the AI features, improve our services, monitor compliance, and as further described in Section 6.

4. How We Use Your Information

We use Subscriber Data for any lawful purpose, including but not limited to:

5. Legal Bases for Processing (For EU/UK/EEA Subscribers)

If the General Data Protection Regulation (GDPR), the UK GDPR, or equivalent data protection law applies to our processing of your information, we rely on one or more of the following legal bases:

Where we rely on legitimate interests, you may object to that processing. We may continue processing if we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if processing is necessary for the establishment, exercise, or defense of legal claims.

6. Use of Your Data in AI and Machine Learning Systems

You expressly acknowledge and agree that LeadFunl may use Subscriber Data, including the contents of your communications with us, your interactions with the Service, voice recordings and transcriptions made through the Mobile Apps, and metadata associated with Mobile App usage, in the following AI-related ways:

(a) Operation of AI features. Routing your inputs through and storing outputs from third-party AI providers (such as Anthropic, OpenAI, Vapi, Bland.ai, AssemblyAI, Deepgram, Google, or other model providers) for the purpose of delivering AI features within the Service and Mobile Apps, including AI voice calling, live-transfer briefings, voice transcription, intent detection, and natural-language to-do parsing.

(b) Compliance and quality review. Analyzing your account activity, communications, and platform usage using automated AI-assisted compliance and quality review systems (the "Review System") to detect violations of the Subscriber Agreement, identify quality issues, monitor for fraud or abuse, and generate findings, recommendations, and audit records.

(c) Training and improvement. Training, fine-tuning, evaluating, and improving LeadFunl's proprietary AI and machine learning models using Subscriber Data, including but not limited to: account configuration patterns, communication patterns with our team, support interactions, platform usage patterns, conversion outcomes you self-report, voice memo recordings (in aggregated and de-identified form), voice transcriptions, calendar interaction patterns, and aggregated metrics. We will not use your raw consumer-prospect lead data (the names, contact information, and qualification data of leads delivered to you) to train general-purpose models, but we reserve the right to use de-identified, aggregated, and anonymized data derived from that activity. For voice recordings specifically, we will request affirmative opt-in consent before using individually-identifiable voice samples for model training.

(d) Third-party AI processor restrictions. Where we use third-party AI providers, we contractually require those providers not to retain your data for training their general-purpose models beyond ephemeral processing windows necessary to deliver responses, except where you have separately consented to such retention.

(e) No promise of human review. Decisions made by the Review System or other automated systems may not be subject to human review unless required by applicable law (such as GDPR Article 22 or California automated decision-making regulations). Where required by law, you may request human review of specific automated decisions affecting you by using our privacy rights request form.

(f) AI is provided as-is. AI-powered features may produce inaccurate, incomplete, or outdated information, including incorrect voice transcriptions, missed calendar events, or imprecise location detection. LeadFunl makes no representation or warranty regarding the accuracy of AI outputs and disclaims all liability arising from your reliance on them, except as required by applicable law.

7. Third-Party Services and Their Privacy Policies

LeadFunl uses the following third-party service providers in the operation of the Service. Each provider has its own privacy policy that governs its handling of information, and you acknowledge that those policies apply in addition to this one. LeadFunl is not responsible for the privacy practices of these third parties; we encourage you to review their policies.

Provider Purpose Privacy Policy
GoHighLevel / LeadConnector CRM, automation, communication infrastructure https://www.leadconnectorhq.com/privacy-policy
Twilio SMS, voice, OTP verification https://www.twilio.com/en-us/legal/privacy
Stripe Payment processing, subscription billing https://stripe.com/privacy
Supabase Database, authentication infrastructure https://supabase.com/privacy
Anthropic AI language model services https://www.anthropic.com/legal/privacy
Vapi AI voice agent infrastructure https://vapi.ai/privacy
Bland.ai AI outbound voice calling and live-transfer infrastructure https://www.bland.ai/privacy-policy
n8n Workflow automation https://n8n.io/legal/privacy/
Amazon Web Services (including Amazon SES) Email delivery, cloud infrastructure https://aws.amazon.com/privacy/
Cloudflare Hosting, network security, access control https://www.cloudflare.com/privacypolicy/
LeadsHook Lead qualification surveys https://leadshook.com/privacy-policy/
NeverBounce Email verification https://neverbounce.com/privacy
RealPhoneValidation / Trestle Phone verification https://realphonevalidation.com/privacy-policy/ and https://trestleiq.com/privacy-policy/
Meta (Facebook, Instagram) Lead generation advertising, social login https://www.facebook.com/privacy/policy/
Google (Workspace, Analytics, Login, Calendar API, Cloud Speech-to-Text) Email, analytics, social login, calendar integration, voice transcription https://policies.google.com/privacy
LinkedIn Social login, professional data https://www.linkedin.com/legal/privacy-policy
X (Twitter) Social login, social media presence https://x.com/en/privacy
Apple (App Store, Apple Sign In, EventKit, Speech Framework) Mobile app distribution, authentication, calendar integration, voice recognition https://www.apple.com/legal/privacy/en-ww/
OpenAI (Whisper API) Voice transcription https://openai.com/policies/privacy-policy
AssemblyAI Voice transcription https://www.assemblyai.com/legal/privacy-policy
Deepgram Voice transcription https://deepgram.com/privacy
Push notification provider (e.g., Firebase Cloud Messaging, Apple Push Notification Service) Push notification delivery Provider-specific policies linked in app settings

This list may be updated from time to time as LeadFunl changes service providers. The current list will always be accessible at https://subscriberprivacy.leadfunl.com/. LeadFunl is not obligated to provide individual notice when adding or changing service providers, except where required by applicable law.

8. Mobile Application Platform Privacy Disclosures

8.1 Apple App Tracking Transparency (ATT)

For iOS users, the Mobile Apps may display App Tracking Transparency prompts as required by Apple's App Store Review Guidelines. If you decline tracking, certain features (such as cross-app advertising attribution) will be disabled. You may review your tracking permissions at any time in iOS Settings → Privacy & Security → Tracking.

8.2 Google Play Data Safety

For Android users, the Mobile Apps' data collection and sharing practices are summarized on the Google Play Store listing's Data Safety section. The categories disclosed there are derived from Section 3.5 of this Privacy Policy. The Google Play listing is the canonical reference for data safety disclosures required by Google Play Developer Program Policies.

8.3 Children's Privacy in Mobile Apps

The Mobile Apps are not intended for use by children under thirteen (13) years of age in the United States or under sixteen (16) years of age in the European Union/EEA. If we become aware that we have collected personal information from a child without parental consent, we will delete that information.

8.4 In-App Purchases

The Mobile Apps may include in-app purchases for subscription tiers, premium features, or additional capacity. In-app purchases are processed by Apple or Google according to their respective in-app purchase policies, and your payment information for in-app purchases is governed by their privacy practices, not LeadFunl's.

8.5 Mobile App Permissions

The Mobile Apps request the following operating system permissions:

Permission Purpose Required?
Microphone Voice memo recording Required for voice memo feature
Location Location-tagging of voice memos, location-aware suggestions Optional
Camera Photo attachments to memos, document scans Optional
Photo Library Access to existing photos for attachments Optional
Calendar Read calendar events for conflict detection; create to-do entries Optional but recommended
Push Notifications To-do reminders, alerts Optional but recommended
Speech Recognition Device-native voice transcription (faster, lower-cost alternative to cloud transcription) Optional
Background App Refresh Keep voice transcriptions current and sync data Optional

You may grant or revoke any permission at any time through your device's operating system settings.

9. Disclosure of Information

We may disclose Subscriber Data to:

10. Sale or Sharing of Personal Information

LeadFunl does not sell Subscriber Data in exchange for monetary consideration. LeadFunl reserves the right to share Subscriber Data with third parties for cross-context behavioral advertising, business operations, and service improvement purposes, which may constitute "sharing" or "sale" under certain state privacy laws (including the California Consumer Privacy Act as amended by the California Privacy Rights Act). Where such sharing applies to you and your jurisdiction grants opt-out rights, you may exercise those rights as described in Section 13.

11. Cookies and Tracking Technologies

LeadFunl and our service providers use cookies, web beacons, pixels, local storage, and similar tracking technologies to operate the Service, remember your preferences, analyze usage, and deliver advertising. You can manage cookie preferences through your browser settings, but disabling cookies may impair the functionality of the Service.

For California residents, our Cookie Notice and Do Not Track signal handling are described separately at https://subscriberprivacy.leadfunl.com/cookies/.

12. Data Retention

We retain Subscriber Data for as long as necessary to provide the Service, comply with our legal obligations, resolve disputes, enforce our agreements, defend against legal claims, and operate our business. Specific retention periods vary by data category and may include:

Where you exercise a right of erasure under applicable law, we will delete or de-identify your personal data within the timeframe required by that law, subject to legal exceptions permitting continued retention.

13. Your Privacy Rights

The rights available to you depend on your jurisdiction. LeadFunl is committed to honoring privacy rights as required by applicable law. To exercise any of the rights below, use our privacy rights request form.

13.1 California Residents (CCPA, CPRA, CalOPPA)

You have the right to:

To submit a request, use our online form at https://subscriberprivacy.leadfunl.com/request/. You may designate an authorized agent to submit requests on your behalf, with appropriate verification.

For purposes of CalOPPA, LeadFunl does not honor browser-based "Do Not Track" signals at this time, except where Global Privacy Control (GPC) signals are received in compliance with CCPA regulations.

13.2 California "Shine the Light" (Cal. Civ. Code § 1798.83)

California residents may request, once per calendar year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for their own direct marketing purposes during the preceding calendar year, and the names and addresses of those third parties. To make such a request, use our privacy rights request form and select the "Shine the Light" request.

13.3 Virginia, Colorado, Connecticut, Utah, and Other US State Privacy Laws

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas, Oregon, Montana, Iowa, Tennessee, Indiana, Delaware, New Jersey, New Hampshire, Maryland, Minnesota, Rhode Island, and other US states with comprehensive privacy laws have rights generally including:

To exercise any of these rights, use our privacy rights request form.

13.4 Nevada Residents

Nevada residents have the right under NRS Chapter 603A to opt out of the sale of certain "covered information" (as defined in the statute). To exercise this right, use our privacy rights request form and select the Nevada sale opt-out.

13.5 EU/UK/EEA Residents (GDPR, UK GDPR)

If you are located in the European Union, the United Kingdom, or the European Economic Area, you have the rights granted to data subjects under the GDPR or UK GDPR, including:

LeadFunl does not currently offer services targeted to EU residents but may do so in the future for additional lead products. Where LeadFunl processes personal data of EU/UK/EEA residents, the relevant rights under GDPR or UK GDPR will apply.

EU/UK/EEA Representative: [TO BE APPOINTED PRIOR TO ANY EU OPERATIONS]

EU/UK/EEA Data Protection Officer (where required): [TO BE APPOINTED PRIOR TO ANY EU OPERATIONS]

13.6 Other Jurisdictions

For residents of jurisdictions not enumerated above (including Canada, Brazil, Australia, and others), LeadFunl will honor privacy rights as required by applicable law upon receipt of a verified request. Use our privacy rights request form.

13.7 Mobile App Data Subject Rights

For data collected through the Mobile Apps specifically, you may exercise your privacy rights through:

13.8 Verification of Requests

Before we fulfill any rights request, we will verify your identity to a degree of certainty appropriate to the request and the sensitivity of the data involved. We may decline requests we cannot verify, requests that are unfounded or excessive, requests that would adversely affect the rights of others, or requests subject to other legal exceptions.

13.9 Response Timeframes

We will respond to verified privacy rights requests within the timeframes required by applicable law (generally 30-45 days, with extensions permitted for complex requests). If we decline a request in whole or in part, we will explain our basis for declining and inform you of any appeal rights.

14. International Data Transfers

LeadFunl is based in the United States. Information you provide will be transferred to and processed in the United States and any other country in which LeadFunl or its service providers operate. By using the Service or the Mobile Apps, you consent to such transfers.

Where required by law (including for transfers from the EU/UK/EEA to the United States), LeadFunl relies on Standard Contractual Clauses, the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, or other lawful transfer mechanisms.

15. Security

LeadFunl implements commercially reasonable administrative, technical, and physical safeguards designed to protect Subscriber Data from unauthorized access, use, disclosure, alteration, and destruction. This includes encryption of voice recordings in transit and at rest, secure key management for Mobile App authentication, and isolation of Mobile App data from non-app data through database-level access controls. However, no system is completely secure, and LeadFunl cannot guarantee the absolute security of any information. You are responsible for safeguarding your own credentials and devices used to access the Service and the Mobile Apps.

In the event of a confirmed data security incident affecting your personal information, LeadFunl will provide notice as required by applicable law, including Cal. Civ. Code § 1798.82 where applicable.

16. Wiretap and Recording Law Compliance

You acknowledge and agree that the voice memo feature in the Mobile Apps is intended for your own personal to-do, reminder, and operational purposes. You are solely responsible for ensuring that your use of the voice memo feature complies with all applicable federal and state wiretap, eavesdropping, and recording laws, including but not limited to the federal Wiretap Act, 18 U.S.C. § 2510 et seq., and state laws in California (Cal. Penal Code §§ 632 and 637.2), Florida (Fla. Stat. § 934.03), Massachusetts (Mass. Gen. Laws ch. 272 § 99), Pennsylvania, Washington, and other "all-party consent" jurisdictions. You will not use the voice memo feature to record private conversations of third parties without those parties' knowing and informed consent. LeadFunl disclaims all liability arising from your unlawful use of the voice memo feature and reserves the right to suspend or terminate your account upon detection of suspected unlawful recording activity.

17. Confidentiality of Subscriber Communications

Information you communicate to LeadFunl support, sales, or other personnel may be retained, reviewed, and used by LeadFunl for any business purpose described in this policy, including training of personnel and AI systems. Communications with LeadFunl are not subject to attorney-client privilege, accountant-client privilege, or other professional confidentiality unless explicitly established by separate written engagement with a licensed professional.

18. Right to Update This Policy

LeadFunl reserves the unilateral right to update, modify, replace, or discontinue this Subscriber Privacy Policy at any time, in its sole discretion, without prior notice except where notice is required by applicable law. The effective date and last-updated date at the top of this policy will reflect the most recent revision.

It is YOUR responsibility, as a Subscriber or prospective Subscriber, to review this Subscriber Privacy Policy periodically for changes. Your continued access to or use of the Service or the Mobile Apps following the posting of an updated policy constitutes your binding acceptance of the updated terms.

LeadFunl is not obligated to provide individualized notice of changes to this policy, except where required by applicable law. We may, in our discretion, provide notice through email, in-platform notification, in-app notification within the Mobile Apps, posting at https://subscriberprivacy.leadfunl.com/, or other reasonable means.

If you do not agree to an updated policy, your sole remedy is to discontinue use of the Service and the Mobile Apps and terminate your subscription in accordance with the Subscriber Agreement. Termination does not entitle you to a refund except as provided in the Subscriber Agreement, and amounts owed to LeadFunl remain payable.

19. Severability and Conflict

If any provision of this Subscriber Privacy Policy is held to be invalid, illegal, or unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions will not be affected. To the extent permitted by law, any invalid provision will be reformed to the minimum extent necessary to make it valid and enforceable while preserving the parties' intent.

In the event of a conflict between this Subscriber Privacy Policy and the Subscriber Agreement, the Subscriber Agreement controls except with respect to specific privacy rights granted under applicable law that cannot be contractually waived.

20. Contact

For privacy questions, requests, or complaints, use our privacy rights request form.