Privacy Policy

This Privacy Policy describes how CFC Partners LLC d/b/a Lead OS ("Lead OS," "we," "us," or "our") collects, uses, shares, and protects information when you visit our website, use our software-as-a-service platform, or otherwise interact with us (collectively, the "Service"). It applies to information about visitors, prospects, customers, and the end-recipients whose data customers process through our platform.

By using the Service, you agree to this Privacy Policy and our Terms of Service. If you do not agree, do not use the Service.

1. Roles & Responsibilities

The Service is offered to business customers (typically real estate operators) who use it to manage their own leads and contacts.

• For data about our customers and website visitors, we act as the data controller.
• For data customers upload, import, or generate within their account about their own leads and contacts, we act as a data processor on behalf of the customer. The customer is the controller of that data and is responsible for the legal basis on which they collected it.

2. Information We Collect

2.1 Information You Provide

• Account information: name, business name, email, phone number, billing address, login credentials.
• Payment information: processed by our payment provider, Stripe. We receive transaction confirmations, the last four digits of the card or payment method, and billing-address fields. We do not store full payment card numbers on our systems.
• Communications with us: support tickets, demo bookings, email correspondence, and any information you choose to share when you reach out.

2.2 Information Customers Process Through the Service ("Customer Data")

Customers may upload, import, or generate information about their own contacts and leads within the Service, including names, phone numbers, email addresses, property data, call recordings, call transcripts, SMS message content, email content, ringless voicemail audio, AI chat transcripts, pipeline stage, notes, and similar records. Customers are responsible for the lawful collection and processing of this Customer Data.

2.3 Information Collected Automatically

• Usage and device data: IP address, browser type, operating system, referrer URL, pages viewed, features used, timestamps, clicks, session duration, and error logs.
• Cookies and similar technologies: see Section 7.
• Call and message metadata: for features that route calls or messages through our infrastructure or sub-processors, we and our sub-processors process telephony metadata such as from/to numbers, duration, message size, and delivery status.

3. How We Use Information

We use information to:

• Provide, operate, maintain, and improve the Service;
• Process payments, manage subscriptions, and send billing notices;
• Provide customer support and respond to inquiries;
• Send service updates, security notices, and other transactional messages;
• Send marketing communications about Lead OS (you can opt out at any time);
• Monitor and prevent fraud, abuse, security incidents, and violations of our Terms of Service;
• Generate aggregated, de-identified statistics about how the Service is used (these statistics do not identify you);
• Comply with legal obligations, court orders, lawful requests, and applicable regulations.

4. How We Share Information

We share information only in the limited circumstances described below. We do not sell personal information.

4.1 Service Providers and Sub-processors

We engage trusted third-party service providers ("sub-processors") to help us operate, secure, and improve the Service. We disclose the categories of these providers rather than identifying each by name. These categories include:

• Cloud hosting and platform infrastructure providers — hosting, storage, and the underlying CRM platform;
• Communications infrastructure providers — telephony (voice calls), SMS/text delivery, ringless voicemail, and AI voice services;
• Payment processors — processing of subscription and usage-based payments;
• Email delivery providers — transactional and marketing email delivery and inbound forwarding;
• Analytics providers — aggregated usage analytics for the website and product.

Each provider is contractually bound to use information only as necessary to perform services for us and in accordance with applicable law. A current list of our specific sub-processors is available to active customers upon written request to support@crmleados.com.

4.2 Legal Compliance & Protection of Rights

We may disclose information when we believe in good faith that disclosure is required to (a) comply with a subpoena, court order, regulatory request, or other legal process; (b) enforce our Terms of Service; (c) protect the rights, property, or safety of Lead OS, our customers, or others; or (d) investigate suspected fraud or violation of law.

4.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of all or a portion of our assets, information may be transferred as part of that transaction, subject to standard confidentiality obligations.

4.4 With Your Consent

We may share information for any other purpose disclosed to you and with your consent.

5. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect information against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit (TLS), access controls, the security measures of our underlying infrastructure providers, and operational practices designed to limit access on a need-to-know basis.

No system is perfectly secure. We cannot guarantee that information will always remain secure during transmission or storage. You are responsible for keeping your account credentials confidential and notifying us promptly of any suspected compromise.

6. Data Retention

We retain information for as long as your account is active and for a reasonable period thereafter to fulfill the purposes described in this Policy, resolve disputes, enforce our agreements, and comply with legal obligations.

• Account and contact information is retained while your account is active and for up to twelve (12) months after account closure, unless a longer period is required by law.
• Customer Data is retained per the customer's configuration; on account termination, customers may request export within thirty (30) days, after which the data may be deleted in the ordinary course.
• Billing and transaction records are retained for as long as required by tax, accounting, and audit obligations (typically up to seven (7) years).
• Call recordings and message logs are retained per the customer's account settings and applicable telecom retention requirements.

7. Cookies & Similar Technologies

We use cookies and similar technologies to operate and improve the Service. Cookie categories include:

• Strictly necessary: required for the Service to function (e.g., session, authentication, security).
• Functional: remember preferences and settings.
• Analytics: understand how visitors use the website and product to inform improvements.

You can manage or disable cookies through your browser settings. Disabling strictly necessary cookies may prevent the Service from working properly.

8. Your Privacy Rights

Depending on where you live, you may have the following rights regarding personal information we hold about you as a controller:

• Access — request a copy of the personal information we hold about you;
• Correction — request that we correct inaccurate or incomplete information;
• Deletion — request that we delete your personal information, subject to legal retention obligations;
• Portability — receive a copy of your information in a structured, commonly used format;
• Objection / Restriction — object to or restrict certain processing;
• Withdraw consent — where processing is based on consent, withdraw it at any time;
• Opt out of marketing — unsubscribe from marketing emails using the link in the message footer.

To exercise any of these rights, email us at support@crmleados.com. We will verify your identity before fulfilling the request and will respond within the timeframe required by applicable law.

8.1 California Residents (CCPA / CPRA)

California residents have the rights described above. Additionally, California residents have the right to know what categories of personal information we have collected, sold, or shared, and to opt out of any "sale" or "sharing" as those terms are defined under California law. We do not sell or share personal information for cross-context behavioral advertising. California residents may also designate an authorized agent to make requests on their behalf.

8.2 European Economic Area, United Kingdom, & Switzerland (GDPR / UK GDPR)

If you are in the EEA, UK, or Switzerland, we process personal information based on one or more of the following legal bases: (a) performance of a contract with you; (b) compliance with a legal obligation; (c) our legitimate interests in operating, securing, and improving the Service; or (d) your consent (which you may withdraw). You have the right to lodge a complaint with your local data-protection supervisory authority.

8.3 Requests Regarding Customer Data

If you are an end-recipient (e.g., a lead being contacted through a customer's Lead OS instance) and want to exercise rights over your personal information, please contact the Lead OS customer who collected that information. They are the controller of that data. We will assist our customers in responding to verified requests.

9. International Data Transfers

We are based in the United States, and our infrastructure providers operate primarily from the United States. If you access the Service from outside the United States, information will be transferred to and processed in the United States, where data-protection laws may differ from those in your jurisdiction. Where required by law, we rely on appropriate safeguards (such as Standard Contractual Clauses) for such transfers.

10. Children's Privacy

The Service is not directed to children under 18, and we do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us at support@crmleados.com and we will take appropriate action.

11. Call Recording, AI Voice, & Two-Party Consent

The Service includes features that record calls, transcribe conversations, and operate AI voice agents. Many U.S. states and foreign jurisdictions require the consent of all parties before recording a call. If you are a customer using these features, you are solely responsible for providing any required disclosures and obtaining any required consents from call recipients. See our Terms of Service, Sections 7 and 8, for more detail on customer obligations.

12. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The most current version will always be posted at this URL with an updated "Effective Date" at the top. For material changes, we will provide reasonable advance notice by email or in-product notice. Your continued use of the Service after the effective date constitutes acceptance.

14. Contact Us

For questions about this Privacy Policy or to exercise your rights, contact:

CFC Partners LLC d/b/a Lead OS
Attn: Privacy
30 N Gould St, Ste R, Sheridan, WY 82801
Email: support@crmleados.com

This Privacy Policy was last updated on June 7, 2026.