Privacy Policy

1. Introduction

SmartLeads LLC ("SmartLeads," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered lead qualification platform, including our SMS outreach and automation features.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with these practices, do not use the Service.

2. Information We Collect

2.1 Information You Provide

• Account information (name, email address, company name, phone number)
• Payment information (processed securely through third-party payment processors; we do not store raw card numbers)
• Lead and contact data you upload, import, or input into the platform
• SMS message content, conversation transcripts, and campaign data
• Consent records and opt-out logs you maintain through the platform
• Profile and preference settings

2.2 Information Automatically Collected

• Usage data and analytics (features used, time spent, actions taken)
• Device information (browser type, operating system, IP address)
• Log data (access times, pages viewed, API calls, errors encountered)
• Cookies and similar tracking technologies

2.3 Information From Third Parties

We may receive information about you from our SMS carrier partners (such as delivery receipts and opt-out signals), payment processors, and analytics providers. We use this data solely to operate and improve the Service.

3. SMS Messaging & TCPA Compliance

3.1 TCPA and Applicable Law

SmartLeads facilitates the sending of SMS messages on your behalf. As the business initiating those messages, you are the party responsible for compliance with the Telephone Consumer Protection Act (TCPA), any applicable state telemarketing laws, and regulations issued by the Federal Communications Commission (FCC). SmartLeads provides tools to help you comply but does not assume legal responsibility for the messages you send.

3.2 10DLC Registration

Effective commercial SMS messaging in the United States requires registration under The Campaign Registry (TCR) 10-digit long code (10DLC) framework. When you provision a phone number through SmartLeads:

• We collect your business information (legal name, EIN/Tax ID, address, website) to complete brand registration with TCR on your behalf.
• We register your messaging use-case ("campaign") with TCR and your carrier, including campaign type, message samples, and opt-in/opt-out language.
• This registration data is shared with TCR and participating wireless carriers as required by industry standards.
• You are responsible for ensuring that the use-case you register accurately reflects how you will use the platform.

3.3 Consent & Opt-In

You must obtain prior express written consent from any individual before sending them marketing SMS messages through SmartLeads. SmartLeads records opt-in timestamps and source information when provided. It is your responsibility to collect, document, and honor consent in accordance with the TCPA and any applicable state laws.

3.4 Opt-Out Processing

SmartLeads automatically processes standard opt-out keywords (STOP, QUIT, CANCEL, UNSUBSCRIBE, END, HELP) and removes contacts from active campaigns immediately upon receipt of such a message. We retain opt-out records for compliance purposes. You may not re-message a contact who has opted out without obtaining fresh explicit consent.

3.5 Message Content

All outbound messages sent through our platform must comply with carrier guidelines and applicable law. You agree not to send messages that contain prohibited content (adult content, illegal substances, illegal activities, hate speech, or anything that violates carrier policies). SmartLeads reserves the right to suspend accounts that send non-compliant messages.

3.6 Data Associated With SMS

SMS conversation data — including inbound replies, delivery receipts, and AI-generated responses — is stored and processed to provide the Service. This data may be reviewed by our team for quality assurance, compliance investigation, or product improvement, subject to appropriate confidentiality protections.

4. How We Use Your Information

• Providing, maintaining, and improving our lead qualification and SMS outreach services
• Processing and analyzing SMS conversations using AI and natural language processing
• Generating lead scores, engagement insights, and campaign analytics
• Registering your brand and messaging campaigns with TCR and carriers (10DLC)
• Processing payments and managing your subscription
• Sending service-related notifications, billing alerts, and product updates
• Improving our platform, AI models, and carrier delivery rates
• Detecting and preventing fraud, spam, abuse, and security incidents
• Complying with legal obligations and enforcing our Terms of Service

5. Data Sharing and Disclosure

We do not sell your personal information to third parties for marketing purposes. We may share your information only in the following circumstances:

• SMS Carriers & Telnyx: Our SMS infrastructure provider (Telnyx) and the wireless carriers they connect to receive message content, phone numbers, and delivery metadata as necessary to route messages.
• The Campaign Registry (TCR): Your brand and campaign registration data is shared with TCR and carriers as required for 10DLC compliance.
• Payment Processors: Billing information is shared with our payment processor (e.g., Stripe) to process transactions. We do not store your raw payment card data.
• Cloud Infrastructure: We use cloud hosting providers (including Supabase/PostgreSQL for data storage) that process data on our behalf under appropriate data processing agreements.
• AI Services: Conversation data may be processed by third-party AI model providers to generate responses and lead scores. Data is handled under confidentiality agreements and is not used to train third-party public models.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
• Legal Requirements: We may disclose information when required by law, court order, or government authority, or to protect our rights, property, or safety.

6. Data Security

We implement industry-standard security measures to protect your information:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Authentication controls including JWT-based session management
• Row-level security and tenant isolation in our database layer
• Regular security assessments and dependency audits
• Restricted access to production systems on a need-to-know basis

No method of transmission over the Internet or electronic storage is 100% secure. While we implement strong protections, we cannot guarantee absolute security. In the event of a data breach that affects your rights, we will notify affected users in accordance with applicable law.

7. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this Privacy Policy:

• Account information: Duration of your active account plus 24 months after closure
• SMS conversation and lead data: 24 months from creation, or as required by law
• Opt-out records: Indefinitely, to prevent re-messaging opted-out contacts
• 10DLC registration data: Retained for as long as required by TCR and carrier agreements
• Transaction records: 7 years for tax and accounting purposes
• Log data: 90 days for operational purposes

You may request deletion of your data at any time by contacting us at privacy@smrtleads.org. Deletion requests are subject to legal retention requirements and will not affect opt-out records.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Portability: Request a copy of your data in a machine-readable format
• Restriction: Request that we limit how we process your data in certain circumstances
• Objection: Object to processing based on our legitimate interests
• Opt-out of marketing: Unsubscribe from marketing emails at any time via the link in each email
• Cookies: Manage cookie preferences through your browser settings

To exercise these rights, please contact us at info@smrtleads.org.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to maintain your session, remember your preferences, and analyze how the platform is used. Types of cookies we use:

• Essential cookies: Required for authentication and core platform functionality
• Analytics cookies: Help us understand usage patterns and improve the product
• Preference cookies: Remember your settings across sessions

You can control cookies through your browser settings. Disabling essential cookies will prevent you from logging in and using the platform.

10. Children's Privacy

Our services are intended for business users and are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a child under 18, we will delete it promptly. Contact us at privacy@smrtleads.org if you believe we have inadvertently collected such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated policy on our website and updating the "Last Updated" date at the top of this page. For significant changes, we may also send an email notification to your registered address. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: