Privacy Policy

Last updated: May 18, 2026

This Privacy Policy describes how Leads Up AI LLC ("Leads Up AI," "we," "us," or "our") collects, uses, shares, and protects personal information through the website located at leadsupai.com, the lead marketplace located at leadsupaileads.com, any related sub-domains, and any related products, services, software, or platforms (collectively, the "Services").

This Privacy Policy is incorporated into our Terms of Service. By accessing the Services, creating an Account, funding a balance, purchasing a Lead, or submitting a property or contact form through any of our consumer-facing landing pages, you acknowledge that you have read and understood this Privacy Policy.

Leads Up AI LLC

7401 Metro Blvd., Suite 500

Edina, MN 55439

Email: leadsadmin@leadsupai.com

Phone: (612) 662-5244

1. Scope and Who This Policy Applies To

Leads Up AI operates two distinct types of services, and this Privacy Policy applies to both:

(a) Lead Buyers and Agency Clients. Real estate investors, wholesalers, home services operators, lenders, and other businesses who register for an Account, purchase Leads through the marketplace, or engage Leads Up AI for digital marketing, PPC, SEO, CRM, or related services.

(b) Consumers Who Submit Information Through Our Lead-Generation Properties. Homeowners, prospective sellers, and other consumers who submit contact, property, or other information through landing pages, forms, surveys, or advertisements operated by Leads Up AI or its agency clients. Information submitted by these consumers is generated, packaged, and sold or transferred to Lead Buyers as part of our core business.

If you are a consumer who submitted information through one of our landing pages or forms, please pay particular attention to Sections 4, 6, 7, 11, and 12, which describe how your information is collected, shared, and sold, and how you can opt out.

This Privacy Policy does not cover the privacy practices of Lead Buyers after they receive a Lead from us. Once a Lead is delivered to a Lead Buyer, that Lead Buyer is the controller of that information and is responsible for its handling under their own privacy policy and applicable law.

2. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this policy reflects the most recent revision. Material changes will be communicated through a notice on the website or, where we have your email on file, by email. Your continued use of the Services after the updated policy is posted constitutes acceptance of the changes.

3. Categories of Personal Information We Collect

We collect the following categories of personal information, depending on how you interact with us:

(a) Identifiers. Name, postal address, email address, telephone number, mobile number, IP address, online identifiers, device identifiers, account name, and account credentials.

(b) Commercial Information. Records of products or services purchased, considered, or inquired about; transaction history; balance and bidding activity; payment method type and last four digits of payment card.

(c) Property and Inquiry Information (Consumers). Property address, property type, property condition, occupancy status, ownership status, mortgage status, reason for selling, timeline to sell, asking price, and similar information you provide on a seller-facing form or survey.

(d) Internet and Network Activity. Browsing history on our Services, search history, referring URL, pages viewed, time on page, mouse movements and clicks captured by session-recording or consent-verification technologies, interactions with our advertisements, and similar engagement data.

(e) Geolocation Data. Approximate location derived from IP address and, where you have provided consent, more precise location data from your device.

(f) Audio and Electronic Information. Recordings of telephone calls between you and Leads Up AI, where lawful and disclosed.

(g) Inferences. Inferences drawn from the categories above to create a profile reflecting preferences, characteristics, behavior, and propensity (for example, propensity to sell a property).

(h) Professional Information (Lead Buyers and Agency Clients). Business name, role or title, business address, business phone, business email, EIN or tax identification information where required, and similar business-related identifiers.

(i) Financial Information. Payment card information processed by our payment processor (we do not store full card numbers on our systems); ACH or bank account information where applicable; billing history; and related transaction data.

We do not knowingly collect Social Security numbers, driver's license numbers, government-issued IDs, precise location data without consent, biometric information, health information, or information about racial or ethnic origin, religious beliefs, sexual orientation, or union membership. If you submit any such information voluntarily, we will treat it with at least the same safeguards as other personal information.

4. How We Collect Personal Information

We collect personal information from the following sources:

(a) Directly From You. When you register an Account, fund a balance, place a bid, purchase a Lead, submit a contact form, request a demo, communicate with our support team, respond to a survey, or otherwise interact with the Services.

(b) From Consumer-Facing Landing Pages and Forms. When you submit information through a landing page, survey, click-to-call ad, or other form operated by Leads Up AI or by an agency client of Leads Up AI for the purpose of connecting you with a buyer for your property or with a service provider.

(d) From Our Payment Processor. Stripe and any successor or replacement processor provides us with limited transaction data necessary to confirm payments, manage chargebacks, and prevent fraud.

(e) From Advertising and Analytics Platforms. Including Meta (Facebook and Instagram), Google, LinkedIn, and other platforms where we run advertising. These platforms provide us with aggregated and, in some cases, individual-level engagement data subject to their own privacy policies.

(f) From Third-Party Data Providers. We may supplement information you provide with publicly available data, property records, county records, and licensed data from third-party providers to verify, enrich, or validate Lead information.

(g) From Lead Buyers. Feedback, lead status, conversion outcomes, and refund or replacement requests submitted by Lead Buyers may include limited information about the underlying consumer Lead.

5. How We Use Personal Information

We use personal information for the following purposes:

(a) To Operate the Services. Including registering Accounts, processing payments, applying Bid Deposits, delivering Leads, managing bids and territories, providing dashboards, and providing customer support.

(b) To Generate, Verify, and Deliver Leads. Information submitted by consumers through landing pages and forms is collected for the express purpose of being verified, packaged as a Lead, and sold or delivered to one or more Lead Buyers. Consumers who submit information through a landing page operated by Leads Up AI or its agency clients are advised at the point of collection that their information will be shared with one or more real estate investors, home buyers, or service providers who may contact them by phone, text, or email.

(c) To Document Consent and Comply With Telemarketing Law. We use consent-verification and session-recording technologies (such as TrustedForm, Jornaya LeadiD, or equivalent services) to independently document the time, place, and content of a consumer's consent to be contacted, in support of Telephone Consumer Protection Act (TCPA) and similar compliance.

(d) To Communicate With You. Including transactional emails, account notifications, support responses, marketing emails (where permitted), and SMS messages (where you have opted in).

(e) To Improve and Develop the Services. Including analytics, research and development, A/B testing, fraud detection, security monitoring, and improving Lead quality and matching.

(f) For Marketing and Advertising. Including targeted advertising on platforms like Meta and Google, lookalike audience building (using hashed identifiers), retargeting, and email marketing campaigns directed at Lead Buyers and prospective Lead Buyers. We do not use consumer Lead data submitted through seller-facing forms to build retargeting audiences for purposes unrelated to our lead-sale business.

(g) To Comply With Law and Enforce Our Terms. Including responding to legal process, complying with regulatory obligations, preventing fraud, investigating violations of our Terms of Service, and protecting our rights, property, and the safety of others.

6. How We Share Personal Information

We share personal information in the following ways:

(a) With Lead Buyers (Sale of Consumer Lead Information). Our core business involves selling consumer Lead information, including name, contact information, property information, and inquiry details, to one or more Lead Buyers who pay for access to that information through marketplace bidding or under Direct Lead arrangements. This activity constitutes a "sale" of personal information under several state privacy laws, including the California Consumer Privacy Act, as amended ("CCPA/CPRA"). See Section 12 for opt-out rights.

(b) With Service Providers and Processors. Including hosting providers, payment processors (such as Stripe), CRM and customer support providers, email and SMS delivery providers, analytics providers, consent-verification and session-recording providers, fraud-prevention providers, and similar vendors who process personal information on our behalf and are contractually limited to using it only to provide services to us.

(c) With Advertising Platforms. We share hashed or pseudonymized identifiers with platforms such as Meta and Google for the purposes of advertising delivery, conversion measurement, and audience building. This activity may constitute "sharing for cross-context behavioral advertising" under the CCPA/CPRA and "targeted advertising" under other state laws. See Section 12 for opt-out rights.

(d) With Agency Clients (For Their Own Lead Programs). When you submit information through a landing page operated by Leads Up AI on behalf of an agency client, that information is shared with the applicable agency client for whom the campaign is being run, in addition to being potentially packaged and sold to Lead Buyers.

(e) In Connection With Legal Process. We may disclose personal information in response to subpoenas, court orders, government investigations, regulatory inquiries, or other legal process; to enforce our Terms of Service; to investigate or prevent fraud or illegal activity; or to protect the rights, property, or safety of Leads Up AI, our users, or others.

(f) In Connection With a Business Transfer. In the event of a merger, acquisition, financing, reorganization, bankruptcy, dissolution, or sale of all or part of our assets, personal information may be transferred to the acquiring or surviving entity.

(g) With Your Direction or Consent. When you direct us to share information with a third party, or when you consent to such sharing.

We do not sell, share, or disclose personal information of known minors under the age of 16 without affirmative authorization where required by law.

7. Specific Disclosures Regarding Consumer Lead Generation

If you submitted your information through a landing page, form, advertisement, or survey operated by Leads Up AI or by an agency client of Leads Up AI in connection with selling your property or inquiring about a service, the following disclosures apply specifically to you:

(a) Your Information Will Be Shared and Sold. Your contact and property information will be shared with one or more real estate investors, home buyers, wholesalers, or service providers who have purchased the right to contact you. You may be contacted by more than one party.

(b) You May Be Contacted By Phone, SMS, and Email. By submitting your information, and depending on the consent language presented at the point of collection, you may have authorized contact by automated telephone dialing systems, prerecorded or artificial-voice messages, SMS text messages, and email, even if your number is on the National Do Not Call Registry or any state DNC list. The specific consent language presented at the point of submission governs.

(c) Consent Is Independently Documented. We use third-party consent-verification technologies to record the time, page, and content of your submission, including the consent language displayed to you.

(d) You Can Revoke Consent and Opt Out at Any Time. You can revoke consent to be contacted at any time by replying STOP to a text, asking a caller to add you to their internal do-not-call list, unsubscribing from emails, or contacting us at leadsadmin@leadsupai.com. Revoking consent with us does not automatically revoke consent with Lead Buyers who have already received your information; you should also notify them directly.

(e) You Have State Privacy Rights. See Section 12 for state-specific rights, including the right to opt out of the sale or sharing of your personal information.

8. SMS and Text Messaging

By providing your mobile telephone number and opting in (for example, by submitting a form, checking a consent box, or texting a keyword), you agree to receive recurring transactional and, where you have opted in, marketing SMS or MMS messages from Leads Up AI. Message frequency varies. Message and data rates may apply. Reply STOP to opt out and HELP for help. Carriers are not liable for delayed or undelivered messages. Consent to receive marketing text messages is not a condition of any purchase.

We do not share, sell, or transfer mobile telephone numbers or SMS opt-in data to third parties or affiliates for the purpose of those third parties sending their own marketing messages. This restriction does not apply to consumer Lead information collected for the express purpose of being sold to Lead Buyers as described in Sections 6(a) and 7, which is governed by the consent language presented at the point of submission.

9. Cookies and Tracking Technologies

We use cookies and similar technologies (web beacons, pixels, tags, session-recording scripts, and software development kits) to operate the Services, remember your preferences, measure performance, deliver advertising, and document consent.

Categories of cookies and similar technologies we use:

(a) Strictly Necessary. Required for the Services to function, including authentication, security, load balancing, and form submission. These cannot be disabled through our cookie controls.

(b) Performance and Analytics. Help us understand how users interact with the Services. These include Google Analytics, Meta Pixel (for conversion measurement), and similar tools.

(d) Advertising and Targeting. Used to deliver advertising relevant to you, measure ad performance, and build audiences. These include Meta Pixel, Google Ads tags, LinkedIn Insight Tag, and similar tools.

(e) Consent Verification and Session Recording. Used to document the time, page, and content of consumer submissions for TCPA and similar compliance, including services such as TrustedForm and Jornaya LeadiD.

Managing cookies. Most browsers allow you to refuse or delete cookies through browser settings. If you delete or block cookies, parts of the Services may not function properly.

Do Not Track. Some browsers transmit a "Do Not Track" or "Global Privacy Control" signal. We honor Global Privacy Control signals as a valid opt-out of the sale or sharing of personal information where required by applicable state law. We do not currently respond to other Do Not Track signals.

10. Data Retention

We retain personal information for as long as needed to provide the Services and for the following additional periods:

Account information: For the life of your Account, plus a period of up to seven (7) years after closure to comply with tax, accounting, audit, and legal obligations.

Consumer Lead information: For the period necessary to deliver the Lead to applicable Lead Buyers, plus a retention period of up to seven (7) years to support consent documentation, TCPA defense, refund and replacement administration, and legal-process responses.

Transaction and billing records: For at least seven (7) years to comply with tax and accounting requirements.

Consent records (TrustedForm, Jornaya, or equivalent): For the period required by applicable law and industry guidance, typically up to ten (10) years.

Marketing communications and analytics data: For up to three (3) years after your last interaction, or as required by applicable law.

We may retain information for longer periods where required by law, court order, regulatory requirement, or legitimate business purpose (including defense of legal claims and enforcement of our Terms of Service).

11. Data Security

We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized access, and unauthorized disclosure. These safeguards include encryption in transit, restricted access controls, vendor due diligence, and monitoring.

No system of safeguards is perfect, and we cannot guarantee the absolute security of any information transmitted to or stored by us. You use the Services and submit information to us at your own risk.

In the event of a breach of security that affects your personal information, we will notify you in accordance with applicable law.

12. State Privacy Rights

Depending on the state in which you reside, you may have specific rights regarding your personal information. These rights generally include some or all of the following, subject to exceptions and verification:

Right to Know / Access. The right to confirm whether we process your personal information and to obtain a copy of that information and details about how it is processed.

Right to Delete. The right to request deletion of your personal information.

Right to Correct. The right to request correction of inaccurate personal information.

Right to Data Portability. The right to obtain a copy of your personal information in a portable format.

Right to Opt Out of Sale. The right to opt out of the sale of your personal information.

Right to Opt Out of Sharing for Targeted Advertising. The right to opt out of the use of your personal information for cross-context behavioral or targeted advertising.

Right to Opt Out of Profiling. The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Right to Limit Use of Sensitive Personal Information. Where applicable.

Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising these rights.

Right to Appeal. The right to appeal a decision we make in response to a privacy rights request.

How to exercise your rights. You may exercise your rights by emailing us at leadsadmin@leadsupai.com with the subject line "Privacy Rights Request"; calling us at (612) 662-5244; or submitting a request through the "Your Privacy Choices" link in the footer of our website.

We will respond to verifiable requests within the timeframe required by applicable law (generally 45 days, with one 45-day extension available where reasonably necessary). We may need to verify your identity before fulfilling your request. An authorized agent may submit a request on your behalf with appropriate documentation.

Specifically with respect to the "sale" and "sharing" of personal information: Because our business model involves selling consumer Lead information to Lead Buyers, residents of states with applicable opt-out rights may exercise the right to opt out of sale or sharing. We will honor verified opt-out requests, including via Global Privacy Control signals where required. Opting out of the sale of your information will prevent us from delivering your Lead to additional Lead Buyers; it will not retroactively recall information already delivered to Lead Buyers prior to the opt-out.

State-Specific Notices.

California. California residents have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), including the rights listed above. We have sold or shared the categories of personal information described in Section 3 in the preceding 12 months as described in Section 6. To exercise the "Do Not Sell or Share My Personal Information" right, use the link in our website footer or contact us as described above. California residents may also request information under California's Shine the Light Law, Cal. Civ. Code § 1798.83.

Colorado. Colorado residents have rights under the Colorado Privacy Act, including the rights listed above and the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Connecticut. Connecticut residents have rights under the Connecticut Data Privacy Act, including the rights listed above.

Virginia. Virginia residents have rights under the Virginia Consumer Data Protection Act, including the rights listed above.

Minnesota. Minnesota residents have rights under the Minnesota Consumer Data Privacy Act, effective July 31, 2025, including the rights listed above, the right to question the result of profiling decisions, and the right to a list of specific third parties to whom we have disclosed personal data.

Nevada. Nevada residents have the right under NRS Chapter 603A to submit opt-out requests instructing us not to sell certain covered information to a third party data broker. To exercise this right, email leadsadmin@leadsupai.com with the subject line "Nevada Opt-Out Request."

Other states. Residents of Texas, Utah, Oregon, Montana, Iowa, Tennessee, Delaware, New Jersey, New Hampshire, Maryland, and other states with comprehensive consumer privacy laws have rights similar to those described above, subject to each state's specific requirements and exceptions. Residents of any U.S. state may submit a privacy rights request as described in this Section.

13. Financial Information

Where applicable, our handling of financial information collected from Lead Buyers in connection with payment processing is governed by the Gramm-Leach-Bliley Act and applicable state financial privacy laws. We do not store full payment card numbers on our systems. Payment processing is performed by Stripe (or any successor or replacement processor), which is independently certified to applicable PCI-DSS standards.

14. Children's Privacy

The Services are not directed to children, and we do not knowingly collect personal information from children under the age of 13 in violation of the Children's Online Privacy Protection Act (COPPA). The Services are intended for use by businesses and individuals at least 18 years old. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly. If you believe a child under 13 has provided personal information to us, contact us at leadsadmin@leadsupai.com.

15. Third-Party Links and Services

The Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of those third parties. Once you leave the Services, this Privacy Policy no longer applies. We encourage you to review the privacy policies of any third-party site or service you visit.

16. United States Only

Leads Up AI is headquartered in the United States, and the Services are intended for use by individuals and businesses located in the United States. We make no representation that the Services are appropriate or available for use in any other jurisdiction. If you access the Services from outside the United States, you do so at your own risk and consent to the transfer, storage, and processing of your information in the United States, which may have data protection laws different from those of your country of residence.

17. Your Choices

In addition to the state-specific rights described in Section 12, you have the following general choices:

(a) Marketing emails. You may opt out of marketing emails by clicking the "unsubscribe" link in any marketing email or by emailing leadsadmin@leadsupai.com. You cannot opt out of transactional emails necessary to provide the Services.

(b) SMS messages. Reply STOP to any text message from us to opt out of further SMS messages.

(c) Cookies and tracking. Manage cookies through your browser settings as described in Section 9, or use the "Your Privacy Choices" link in our website footer.

(d) Account information. Update or correct your Account information at any time through your dashboard, or contact us for assistance.

18. Notification Procedures

We may provide notices to you by email, by posting on the Services, by SMS where you have consented, or by such other means as we reasonably determine. You are responsible for keeping your contact information current.

19. Contact Us

For questions or concerns about this Privacy Policy, to exercise your privacy rights, or to report a suspected privacy or security issue, contact us:

Leads Up AI LLC

Attn: Privacy

7401 Metro Blvd., Suite 500

Edina, MN 55439

Email: leadsadmin@leadsupai.com

Phone: (612) 662-5244

For privacy rights requests, please use the subject line "Privacy Rights Request" so we can route your request to the appropriate team.

Leads Up AI

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