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Privacy Policy for LevelUp Leads

Privacy Policy

Last updated: July 9th, 2026

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service, and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Scope and Our Role

This Privacy Policy covers personal data that LevelUp Leads LLC handles in two distinct capacities.

Where we act as a controller. 

We decide why and how personal data is processed, and this Policy governs that processing. This applies to:

  • visitors to and users of our Website;
  • business contacts we identify, enrich and contact as prospects for our own services;
  • our own employees, contractors and applicants.

Where we act as a processor.

We process personal data on behalf of our clients, under their instructions and under a written data processing agreement. This applies to prospect and contact data supplied or designated by a client, and to call recordings, transcripts and meeting records generated in the course of delivering services to that client. For that data, the client is the controller. If you wish to exercise your rights over data we hold on a client’s behalf, contact that client directly, or contact us at admin@levelupleads.io and we will route your request to them.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to LevelUp Leads LLC, 1760 Palm Drive, Laguna Beach, CA 92651.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: the United States. LevelUp Leads LLC is headquartered in Laguna Beach, California.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable natural person.
  • Service refers to the Website and to the lead generation, outreach and related services provided by the Company.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to LevelUp Leads, accessible from https://www.levelupleads.io/
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected
Personal Data

While using Our Service, We may collect or ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Telephone number
  • Job title
  • Employer or company name
  • LinkedIn profile URL and other professional profile identifiers
  • Call recordings and transcripts of calls in which You participate
  • Meeting records, including scheduling details, attendance and meeting notes
  • Usage Data
Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Personal Data We Obtain From Sources Other Than You

Not all of the personal data we hold is provided to us by the person it describes. Where we build or enrich business contact records for our own outreach, or on behalf of a client, we obtain personal data from other sources. This section explains that practice.

Categories of personal data obtained. Business contact details and professional information, specifically: name, business email address, business telephone number, job title, employer, employer location and industry, professional profile URLs such as LinkedIn, and publicly reported company information such as headcount and revenue range.

Sources. Third-party business data and enrichment providers, publicly accessible professional networking profiles, company websites, and public business registers. We do not knowingly obtain special category data, and we do not seek personal or non-business contact details for outreach.

Purpose and lawful basis. We process this data for direct business-to-business marketing, on the basis of our legitimate interests in identifying and contacting business contacts in roles relevant to the services we offer. We have assessed that this processing is proportionate, is limited to a business context, and does not override the rights and freedoms of the individuals concerned.

Notification. Where we obtain personal data from another source and intend to contact you, we will identify ourselves and the purpose of contact in our first communication with you, and in any event will provide this information within one month of obtaining the data.

Your right to object. You may object to this processing at any time and we will stop, with no need to give a reason. Email admin@levelupleads.io, or use the unsubscribe or opt-out mechanism in any message you receive from us. On request we will also tell you the specific source from which we obtained your details.

Tracking Technologies and Cookies

We use tracking technologies consistent with GDPR, CCPA and other privacy regulations. When required by law, we obtain consent for the use of cookies and tracking tools. Users may withdraw consent at any time.

You can instruct Your browser to refuse all Cookies, to delete Cookies already set, or to indicate when a Cookie is being sent. If You do not accept Cookies, You may not be able to use some parts of our Service.

Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies.

Type: Session Cookies.

Administered by: Us. Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies.

Type: Persistent Cookies. Administered by:

Us. Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies.

Type: Persistent Cookies. Administered by: Us. Purpose:

These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy.

How We Use Your Personal Data, and Our Lawful Bases

The Company uses Personal Data for the purposes set out below. For individuals in the EEA and the UK, the lawful basis for each purpose is stated alongside it. Where we rely on legitimate interests, the interest is identified.

Purpose

Lawful basis

To provide and maintain our Service, including monitoring its usage, and to manage Your Account and registration as a user.

Performance of a contract. Legitimate interests in operating, securing and improving the Service.

To perform a contract with You, including the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased, or of any other contract with Us through the Service.

Performance of a contract.

To contact You by email, telephone, SMS or equivalent electronic communication regarding updates, security notices or informative communications related to the functionality, products or contracted services.

Performance of a contract. Legal obligation where the notice is required by law. Legitimate interests in service administration.

To provide you with news, special offers and general information about goods, services and events similar to those you have already purchased or enquired about, unless you have opted not to receive them.

Legitimate interests in marketing our own similar services to existing customers, subject to an opt-out in every message. Consent where required by local law.

To identify and contact business contacts in roles relevant to our services, including where their details were obtained from third-party data providers or public sources.

Legitimate interests in direct business-to-business marketing to business contacts in roles relevant to our services. Subject to the right to object at any time.

To record, transcribe and analyse calls and meetings for service delivery, quality assurance and training.

Performance of a contract. Legitimate interests in quality assurance and service improvement. Consent where required by applicable recording law.

To manage Your requests to Us, including privacy rights requests.

Legal obligation. Legitimate interests in responding to enquiries.

For data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, and evaluating and improving our Service, products, marketing and your experience.

Legitimate interests in understanding and improving our Service. Consent where the processing relies on non-essential cookies or similar technologies.

For business transfers, including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Our assets.

Legitimate interests in the conduct of corporate transactions.

To comply with legal and regulatory obligations, to resolve disputes, and to establish, exercise or defend legal claims.

Legal obligation. Legitimate interests in protecting our legal position.

How We Share Your Personal Data

We may share your personal data with third parties in compliance with applicable laws and on the lawful bases set out above. Where we engage service providers to process personal data on our behalf, we do so under written data processing agreements requiring equal or stronger privacy standards.

We may share Your personal information in the following situations:

With Service Providers. To monitor and analyze the use of our Service, to deliver our services, and to contact You.

With our clients. Where we generate or process contact records, call recordings, transcripts or meeting records in the course of delivering services to a client, that data is provided to the client, who acts as controller for it.

For business transfers. In connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

With Affiliates. In which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With business partners. To offer You certain products, services or promotions.

With other users. When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

With supervisory authorities and law enforcement. Where legally mandated, or in response to valid requests by public authorities such as a court or a government agency.

With Your consent. For any other purpose with Your consent.

We may also disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of Users of the Service or the public, or protect against legal liability.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

The following retention schedule applies to the main categories of Personal Data we process. Retention periods are reviewed at least annually:

Category of data

Retention period

Account and client contact data

For the duration of the engagement, then removed 30 days after the engagement ends.

Prospect and marketing contact data

Until consent is withdrawn or an objection is received, or after 24 months of inactivity, whichever is sooner.

Usage and analytics data

Up to 14 months from collection.

Call recordings, transcripts and meeting records

For the duration of the engagement, then removed 30 days after the engagement ends.

Financial and transaction records

7 years, to meet tax, accounting and legal obligations.

Employee and contractor records

For the duration of the engagement, then up to 6 years.

Where a longer retention period is required by law, for example under tax or employment law, that longer period applies. When Personal Data is no longer required, it is securely deleted or anonymised.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. We may transfer your data outside the EEA or UK only when appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), adequacy decisions, or explicit user consent.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We maintain a Record of Processing Activities (RoPA) and conduct Data Protection Impact Assessments (DPIAs) where required.

Security measures implemented. To safeguard personal data against unauthorized access, loss, alteration or misuse, LevelUp Leads LLC employs the following:

  • Encryption. We use industry-standard encryption protocols to protect personal data both in transit and at rest, ensuring that sensitive information remains secure.
  • Access controls. Access to personal data is restricted to authorized personnel only, based on role and need-to-know principles, and is regularly reviewed to prevent unauthorized access.
  • Regular audits and assessments. We conduct periodic security audits and assessments to evaluate the effectiveness of our security measures and identify potential vulnerabilities.
  • Data minimization and retention policies. We collect only the data necessary for the purposes outlined in this Privacy Policy and retain it only for as long as required by law or as necessary for our business operations.
  • Incident response plans. In the event of a data breach or security incident, we have established protocols to respond promptly, mitigate impacts, and notify affected individuals in accordance with legal requirements.
  • Training and awareness. Our staff undergo regular training on data privacy and security best practices to ensure compliance with applicable regulations and to maintain a high standard of data protection.

Your Privacy Rights

LevelUp Leads LLC recognizes the fundamental importance of privacy rights in protecting the personal information of our clients and users. Privacy rights empower individuals by giving them control over how their personal data is collected, used, shared and protected. The rights available to you depend on where you live. The sections below set out the rights that apply under United States state privacy laws and under the GDPR and UK GDPR.

How to Exercise Your Rights

To exercise any right described below, email us at admin@levelupleads.io. We may need to verify your identity before processing your request, to protect your privacy and ensure the security of your personal data. We respond within the timeframes established by the applicable law, typically within 45 days for United States state law requests and within one month for GDPR and UK GDPR requests.

Non-Discrimination

LevelUp Leads LLC does not discriminate against individuals who exercise their privacy rights. You will not be denied goods or services, charged different prices, or subjected to a different quality of service because you chose to exercise your privacy rights.

United States: rights common to several states

Residents of California, Colorado, Connecticut, Texas, Utah and Virginia have rights under their respective state privacy laws: the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Texas Data Privacy and Security Act (TDPSA), the Utah Consumer Privacy Act (UCPA) and the Virginia Consumer Data Protection Act (VCDPA). In general these laws give you:

  1. Right to access. Request access to the personal data we hold about you, including the categories of personal data we collect, the sources of the data, the purposes for processing, and the categories of third parties with whom we share it.
  2. Right to correct. Request correction of inaccuracies in your personal data.
  3. Right to delete. Request deletion of your personal data, subject to legal exceptions such as completing a transaction, complying with a legal obligation, or protecting against fraud.
  4. Right to opt out of sale and targeted advertising. Opt out of the sale of your personal data or its use for targeted advertising.
  5. Right to limit the use of sensitive personal data. In some states, limit the use and disclosure of sensitive personal information, which may include race, ethnicity, precise geolocation and health information.

The state-specific sections below set out additional or differing rights.

California (CCPA / CPRA)

We do not sell personal data. If this changes, a “Do Not Sell My Personal Information” link will be prominently displayed on our website. As a California resident you have the following rights:

  • Right to know. Request information about the categories of personal information we collect, the sources of that information, the purposes for collection, and the third parties with whom your information is shared. You can also request specific pieces of personal information that we have collected about you.
  • Right to delete. Request that we delete any personal information we have collected from you, subject to certain exceptions, such as when the information is required to complete a transaction or comply with legal obligations.
  • Right to opt out of sale. Opt out of the sale of your personal information.
  • Right to correct. Request that we correct any inaccurate personal information we maintain about you.
  • Right to limit use of sensitive personal information. Request limitations on the use and disclosure of your sensitive personal information.
  • Right to non-discrimination. Not be discriminated against for exercising any of your privacy rights.
  • Right to data portability. Request that your data be transferred to another entity in a structured, commonly used format.

California residents may designate an authorized agent to act on their behalf. To exercise these rights, contact us at admin@levelupleads.io.

Virginia (VCDPA)
  1. Right to access. Confirm whether we process your personal data and access such data.
  2. Right to correct. Request that we correct inaccuracies in your personal data, taking into account the nature of the data and the purposes of the processing.
  3. Right to delete. Request that we delete personal data provided by or obtained about you.
  4. Right to opt out. Opt out of the processing of your personal data for targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects.
  5. Right to appeal. If we deny your request, you have the right to appeal our decision.

To exercise these rights, contact us at admin@levelupleads.io.

Colorado (CPA), Utah (UCPA) and Connecticut (CTDPA)
  1. Right to access. Access personal data that we collect and process about you.
  2. Right to correct. Correct any inaccuracies in your personal data.
  3. Right to delete. Request the deletion of your personal data, subject to exceptions allowed by law.
  4. Right to opt out. Opt out of the sale of your personal data, targeted advertising and profiling.

To exercise these rights, contact us at admin@levelupleads.io.

Texas (TDPSA)
  1. Right to access. Know whether we are processing your personal data and access such data.
  2. Right to correct. Request corrections to your personal data if it is inaccurate.
    Right to delete. Request that we delete personal data collected about you, with certain exceptions.
  3. Right to opt out. Opt out of data processing activities, including targeted advertising, the sale of data, and certain profiling activities.

To exercise these rights, contact us at admin@levelupleads.io.

Nevada
  1. Right to opt out of sale. Opt out of the sale of your personal information, even though we do not currently sell personal data.

To exercise this right, contact us at admin@levelupleads.io.

EEA and United Kingdom (GDPR and UK GDPR)

If you are in the European Economic Area or the United Kingdom, you have the following rights:

  1. Right of access. Request a copy of your personal data.
  2. Right to rectification. Correct inaccurate or incomplete data.
  3. Right to erasure. Request deletion of your data when it is no longer necessary. This includes the right to be forgotten.
  4. Right to restrict processing. Limit how we use your data under certain conditions.
  5. Right to data portability. Receive your data in a structured, commonly used, machine-readable format.
  6. Right to object. Object to processing for direct marketing at any time, with no need to give a reason, and object to processing based on legitimate interests.
  7. Right not to be subject to automated decision-making. Request human review of any decision produced solely by automated means that has legal or similarly significant effects.
  8. Right to withdraw consent. Where processing is based on consent, withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, email admin@levelupleads.io.

Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority. If you are in the EEA, you may complain to the data protection authority in the member state of your habitual residence, your place of work, or the place of the alleged infringement. If you are in the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO). We would appreciate the chance to address your concerns directly before you do so.

How We Ensure Compliance

LevelUp Leads LLC complies with applicable privacy laws by implementing data protection measures, including:

  • Detailed privacy notices. We provide clear and accessible privacy notices that outline the categories of personal data collected, purposes of processing, and your rights under applicable laws.
  • Data security measures. We use industry-standard security protocols, including encryption and access controls, to protect your personal data.
  • Consumer request management. We have established processes for verifying, processing and responding to requests in accordance with the applicable legal requirements.

For further information or to exercise your rights, contact us at admin@levelupleads.io.

Children's Privacy

Our Service is directed to businesses and business professionals. It does not address children.
We do not knowingly collect personally identifiable information from anyone under the age of 13 in the United States, or under the age of 16 in the European Economic Area and the United Kingdom, where a lower age between 13 and 16 has not been set by the relevant member state.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from a child below the applicable age without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective, and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or would like to exercise your data rights, you can contact:

Data Controller

LevelUp Leads LLC
1760 Palm Drive, Laguna Beach, CA 92651, United States

Privacy requests and rights requests

admin@levelupleads.io

Data Protection Officer / Privacy Contact

Timothy Dahlstrom, VP of Operations
tim@levelupleads.io