Privacy Policy
Last Updated: May 15, 2026
Welcome to Lead-Lag Media®! Lead-Lag Media® is provided by Lead Lag Publishing, LLC (collectively referred to herein as “we,” “us,” “our,” or “Company”). We respect your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use our website, application, online, mobile and/or AI-enabled services (collectively the “Services”), how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. The Services, and any AI-generated content, insights, scores, segmentation, or other outputs, are provided for general business, marketing, and informational purposes only and do not constitute investment, legal, tax, accounting, regulatory, or other professional advice. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Service.
Please note that this Policy does not apply to your use of third-party sites, services, or applications you may access through the Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
NOTICE OF AI PROCESSING
Lead-Lag Media® is an AI-driven sales, marketing, and distribution firm serving the financial services industry. The Services are delivered in substantial part through automated and AI-enabled systems, including large language models, machine-learning models, generative AI tools, automated email and messaging engines, web crawling, scraping and enrichment tools, scheduling and routing engines, lead generation, scoring, segmentation, personalization, and analytics tools, and related supporting technologies (collectively, the “AI Engine”). When you use the Services, communicate with us, or appear in any data set we collect, license or process, your information may be processed by these automated and AI-enabled systems. The categories of automated and AI-enabled processing we perform include, without limitation:
Drafting, summarizing, classifying, translating, and routing written communications, including email and messaging;
Researching companies, professionals, and publicly available information about advisors, issuers, podcast guests, sponsors, and other counterparties;
Generating, editing, and publishing content, including articles, social media posts, podcast scripts, video clips, and design assets;
Scheduling, reminding, reconciling, and otherwise coordinating meetings, events, and recurring obligations;
Monitoring inboxes, calendars, and integrated platforms (with appropriate authorization) to detect and act on routine logistical requests;
Analyzing performance, attribution, deliverability, engagement and conversion signals, and generating profiles, scores, segments, and audiences, to target, prioritize, personalize, and otherwise optimize the Services;
Enriching contact records and removing or replacing invalid contact information; and evaluating, testing, tuning, fine-tuning (on internal or contracted instances), and otherwise improving the AI Engine and the Services, including on a de-identified or aggregated basis.
Where automated or AI-generated output is sent to a third party in our name, or materially affects a contractual deliverable, our personnel may review the output prior to delivery on a risk-based basis and to the extent required by the applicable customer agreement or by law. Outputs are generated probabilistically and may contain inaccuracies; we do not warrant that any output is error-free, complete, or fit for any particular purpose. The Services are not designed or intended to make, and we do not use the Services to make decisions producing legal effects or similarly significant effects about you (such as decisions regarding credit, employment, housing, insurance, education, healthcare, or government benefits). Where automated processing is used in a way that affects you in a manner contemplated by applicable law (for example, prioritizing the order in which advisors receive an outreach sequence), you may contact us at the address in “How to Contact Us” to request human review to the extent required by applicable law.
Third-Party AI Providers. We use third-party AI sub-processors and service providers to operate the AI Engine. These providers may include large-language-model providers, speech-to-text and transcription providers, image, audio and video generation providers, embedding and vector-database providers, search, scraping and enrichment APIs, marketing automation and CRM platforms, analytics providers, and infrastructure and hosting providers. We use commercially reasonable efforts to engage AI sub-processors that (i) do not use Personal Information we provide to train their publicly distributed foundation models, and (ii) maintain commercially reasonable security and privacy practices. Sub-processors and their practices may change from time to time. A current list of categories of AI sub-processors is available on request. Your information may be transmitted to, stored in, and processed in the United States and in other jurisdictions where our sub-processors operate, which may have different data protection laws than your jurisdiction of residence.
Inputs and Training. We will not use Personal Information that identifies you to train any publicly distributed foundation model. We may, however, use Personal Information, prompts, inputs, outputs, usage data, feedback, and other information generated through the Services (i) to provide, operate, secure, monitor, troubleshoot, and improve the Services and the AI Engine, (ii) to develop, test, evaluate, benchmark, fine-tune, and improve our own and contracted models and tooling on internal or private instances, and (iii) in de-identified, anonymized, aggregated, or derived form, for any lawful business purpose, including analytics, research, benchmarking, product development, and creation of insights and reports. We may retain such de-identified, anonymized, aggregated, or derived data indefinitely.
Output Accuracy; No Advice; No Reliance. Outputs generated by the AI Engine (“AI Outputs”) are produced probabilistically and may be incomplete, inaccurate, out-of-date, biased, or otherwise unsuitable for a particular purpose. AI Outputs are provided for general business, marketing, and informational purposes only and do not constitute, and should not be relied upon as, investment, financial, securities, legal, tax, accounting, compliance, regulatory, suitability, fiduciary, or other professional advice, and are not a recommendation, solicitation, or offer to buy, sell, or hold any security, product, or service. AI Outputs are not a substitute for independent judgment, qualified professional advice, or applicable regulatory, supervisory, compliance, or due-diligence processes. You are solely responsible for reviewing, validating, and determining the suitability of any AI Output before relying on or acting upon it, particularly in connection with any regulated activity. Unless separately agreed in writing with us, the Services are not to be used as the sole basis for any regulated decision, including any investment, lending, underwriting, eligibility, or compliance decision. If you discover an inaccuracy about you in any AI Output we publish or transmit, please contact us using the information in “How to Contact Us” so we can review, and where appropriate, correct or remove it.
INFORMATION WE MAY COLLECT
Information You Provide to Us
We collect information you provide directly to us when using the Services. For example, we collect information when you complete a form, participate in any interactive features of the Services, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address, professional and firm information, and any other information you choose to provide. For purposes of registering and using the Services, we collect certain information that can identify you, such as your name and contact information (email, address and phone number) and professional affiliation (“Personal Information”). We will never sell, rent, or trade Personal Information in exchange for monetary consideration as “sale” is defined under applicable U.S. state privacy laws, and will only use it, as needed, to provide the Services requested by you. Company discloses Personal Information only to those of its employees, contractors, vendors, sub-processors and affiliated organizations that (i) need to know the information in order to process it on yours, our, or our clients’ behalf, and (ii) are subject to, or that have agreed in writing to non-disclosure restrictions at least as strong as those herein. We also may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account. Depending on the nature of your inquiry or activities on the Services, we may also ask for other information relevant to your use of the Services.
Information We Collect Automatically When You Use the Services
When you access or use the Services, we automatically collect information about you, which may include the following:
Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services. Publicly available tools can sometimes provide the approximate location for IP addresses.
Device Information: We collect information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored in device memory that help us to improve the Services and your experience, see which areas and features of the Services are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.
We also may collect other types of information in the following ways when you use the Services:
Details of how you used and interacted with the Services, such as your search queries and how you responded to certain questions.
Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track your movements around the Services and understand trends.
Analytics Services and other Information We Collect From Other Sources
We may allow others to provide analytics service in connection with the Services, such as Google Analytics. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the user experience, and better understand your activity.
To learn more about Google Analytics, please visit https://policies.google.com/privacy.
We may also obtain information about you and your firm from other sources and combine that with information we collect through the Services. These sources may include, without limitation, data enrichment, contact intelligence, and lead-generation providers; publicly available sources (including websites, regulatory filings (such as SEC, FINRA, and state filings), press releases, social media, podcasts, and similar publications); business directories and registries; analytics, advertising, and marketing technology providers; payment processors; event and webinar platforms; our clients (with respect to their prospects, customers, guests, and counterparties); and the third parties with whom you interact through the Services. We use such information for sales, marketing, distribution, research, analytics, fraud prevention, security, and other purposes described in this Policy.
USE OF INFORMATION
We may use information about you for various purposes, including the following:
Provide, maintain, improve and deliver the Services you request, process transactions, and send you related information;
Verify your identity and, if applicable, authorization for you to use the Services;
Facilitate use of the Services;
Provide personalized recommendations and maintain general and personalized content;
Manage your preferences;
To prevent or address service, security, technical issues at your request in connection with customer support matters
Respond to your comments, questions, and requests;
Send you technical notices and other administrative messages;
Communicate with you about Services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage, and activities in connection with the Services;
Conduct research, analysis, and surveys;
Personalize and improve the Services and provide content or features that match user profiles or interests;
Enforce our Terms;
Link or combine with information we get from others in connection with the Services; and
YOUR RESPONSIBILITIES.
If you are a client, customer, user, or other party providing information to us or instructing us to perform Services, you represent and warrant that: (i) you have all rights, consents, permissions, and authorities necessary to provide such information to us and to authorize our processing of such information (including through the AI Engine and AI sub-processors) for the purposes described in this Policy and any applicable agreement; (ii) your provision of such information and our processing of it will not violate any contract, privacy notice, consent, law, rule, or regulation, including U.S. federal and state privacy laws, the TCPA, CAN-SPAM, anti-spam, telemarketing, and electronic communications laws, and applicable financial services laws, rules, and regulations (including, where applicable, those administered by the SEC, FINRA, state securities regulators, the CFTC, the NFA, banking regulators, and state insurance regulators); (iii) you are solely responsible for any regulated use case in which you employ the Services or AI Outputs, including for ensuring required disclosures, suitability, supervision, recordkeeping, review, retention, and compliance (including, where applicable, advertising, marketing, and communications rules such as SEC Rule 206(4)-1, FINRA Rules 2210 and 3110, and similar rules); and (iv) you will review, validate, and exercise independent professional judgment before relying on or acting upon any AI Output. You agree to indemnify, defend, and hold harmless Lead-Lag Media and its affiliates from and against any claims, losses, and liabilities arising out of or related to your breach of the foregoing, to the extent permitted by applicable law and any separate written agreement between us.
This Policy is not intended to place any limits on what we do with data that is aggregated, anonymized, de-identified, synthetic, or otherwise no longer reasonably linkable to an identifiable user or device (“De-Identified Data”). We may create, retain, use, disclose, and commercialize De-Identified Data for any lawful purpose, including to develop, train, evaluate, and improve the AI Engine and the Services, to generate benchmarks, insights, and reports, and to provide products and services to our clients, in each case without further obligation to you. We commit to maintain De-Identified Data in a manner that does not reasonably permit re-identification, will not attempt to re-identify such data except as permitted by law, and will require recipients to abide by equivalent obligations..
CONSENT OF SMS COMMUNICATIONS
If you provide consent to receive SMS communications from us, your phone number and SMS opt-in consent will not be shared with third parties or affiliates for their own independent marketing purposes. We may share your phone number with our service providers, vendors, and sub-processors solely to deliver, support, and measure communications sent by or on behalf of Lead-Lag Media and otherwise as described in this Policy.
Types of SMS Communications
After you consent, we will send messages regarding appointments, cases, or deliveries you have requested. Examples of these messages include:
Customers and Guests: Updates on orders, deliveries, and other relevant information.
Job Applicants: Information about the status of your application.
Standard Messaging Disclosures
Messaging frequency may vary.
Message and data rates may apply.
To opt-out at any time, text STOP.
For assistance, text HELP or visit our website at www.leadlagmedia.com.
Visit https://leadlagmedia.com/privacy-policy/ for the privacy policy and https://leadlagmedia.com/terms-conditions/ for the Terms of Service.
SHARING OF INFORMATION
We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:
With third party affiliates, contractors, vendors, service providers, sub-processors, and AI providers (including hosting, infrastructure, analytics, marketing technology, CRM, email and messaging, transcription, content generation, data enrichment, advertising, and similar providers) in connection with providing the Services and conducting sales, marketing, and distribution activities by or on behalf of us and our clients;
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
If we believe your actions are inconsistent with the spirit or language of our Terms of Service or policies, or to protect the rights, property, and safety of you, us, or others;
In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;
With our clients (including asset managers, advisers, issuers, sponsors, and other financial services participants) for sales, marketing, distribution, lead generation, introduction, and related purposes, and with your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.
SMS opt-in consent and phone numbers will not be shared with third parties or affiliates for their own independent marketing purposes.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
AI Sub-Processors. As described in the “Notice of AI Processing” above, we share information with third-party AI service providers and other sub-processors to operate the AI Engine. Categories of such sub-processors include large-language-model providers, generative AI providers, automated email and messaging platforms, transcription providers, contact-enrichment and data providers, scheduling and calendaring platforms, content-publishing and advertising platforms, CRM and marketing automation platforms, and analytics and infrastructure providers. We use commercially reasonable efforts to engage AI sub-processors that do not use Personal Information we provide to train their publicly distributed foundation models. A current list of categories of AI sub-processors is available on request to the contact address provided below.
OTHER WEBSITES
This Privacy Policy applies only to information we collect at and through our website. The website may contain links to or embedded content from third party websites. A link to or embedded content from a third-party website does not mean that we endorse that third party website, the quality or accuracy of information presented on the third-party website or the persons or entities associated with the third-party website. If you decide to visit a third-party website, you are subject to the privacy policy of the third-party website as applicable and we are not responsible for the policies and practices of the third-party website. We encourage you to ask questions before you disclose your information to others.
SECURITY
We work hard to protect your information and maintain commercially reasonable administrative, physical, electronic, and other security measures designed to help safeguard Personal Information from loss, misuse, unauthorized access, alteration, or disclosure. Our security practices include: encrypting many of our services using SSL; verification for account access; and periodic review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. However, and unfortunately, no internet, e-mail or electronic transmission or storage system is fully secure or error free and we cannot and do not guarantee the security of information data transmitted to or from us. Any transmission of information is at your own risk and you are responsible for safeguarding any credentials used to access the Services. To the fullest extent permitted by applicable law, we disclaim liability for unauthorized access to or use of Personal Information that occurs despite our commercially reasonable security measures.
CHILDREN UNDER THE AGE OF 18
The Services are intended for users who are eighteen (18) years of age and older. If you are under the age of 18, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 18, please contact us at michaelgayed@leadlagmedia.com.
RETENTION
We will retain your Personal Information for the period of time that is necessary to fulfil the original purposes for which it has been collected, to operate and improve the Services and the AI Engine, and to satisfy legitimate business needs. In certain cases, a longer retention period may be required or permitted by law or appropriate to allow us to pursue our business interests, conduct audits, comply with our legal, regulatory, contractual, or financial-services-related obligations, enforce our agreements, investigate or defend against claims, prevent fraud, or otherwise as permitted by applicable law. We may retain De-Identified Data indefinitely.
The criteria used to determine our retention periods include:
Time needed to provide you with our Services or to operate our business.
Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.
Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the website or Services.
AI Logs. We retain logs of AI Engine activity (prompts, outputs, errors, and metadata) for operational, security, audit, and quality-assurance purposes. AI logs are retained for the period reasonably necessary to operate, monitor, troubleshoot, and tune the AI Engine and to satisfy applicable legal, regulatory, and contractual obligations, after which they are deleted or anonymized in accordance with our internal retention schedule.
TRANSFER OF PERSONAL INFORMATION; INTERNATIONAL VISITORS
The Services are provided from the United States. If you are located outside of the United States, any information you provide to us may be transferred stored in, and processed in the United States and in other jurisdictions in which we, our affiliates, our clients, or our service providers or sub-processors (including AI sub-processors) operate. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities. You understand that data stored in the United States and such other jurisdictions may be subject to lawful requests by courts, regulators, or law enforcement authorities. Where required by applicable law, we will implement appropriate safeguards for international transfers, which may include standard contractual clauses, supplementary measures, or other lawful transfer mechanisms. By using the Services or providing information to us, you acknowledge and agree to such international transfers and processing.
If you are an international visitor, you acknowledge that by providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (b) permitting the use of your Personal Information in accordance with this Privacy Policy.
OPTIONS
Your Information
We use reasonable processes to ensure compliance with this privacy policy and periodically verify that the policy is accurate. We encourage you to raise any concerns by contacting us at michaelgayed@leadlagmedia.com, and we will investigate and attempt to resolve any complaints regarding our use or disclosure of information. Unless legal restrictions apply, you have the right to access the information we hold about you free of charge. You may update, correct or delete your information at any time by contacting us at michaelgayed@leadlagmedia.com. You can help us maintain the accuracy of your information by notifying us of any changes. To avoid delays in obtaining your information, please provide sufficient detail to permit us to identify you and the specific information that you are requesting. We will respond to your request within 30 days of receipt, unless we inform you that it will take longer, as permitted by law under certain circumstances. Please note that there may be instances where access may be restricted as permitted or required by law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations. In addition, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period. Please note that we are not responsible for storing any information that you provide to us or a third party or for any content or information that we or a third party provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.
Communications Including SMS/Text Messages
Our communications with you via the Services use electronic means, whether you visit the Services or send us an email, or whether we post notices on the Services or communicate with you via email or text. By providing Personal Information to us, you expressly consent to receive messaging and information from us and you agree that all terms and conditions, agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if it were in writing. You acknowledge that when you sign up for our Services or provide any Personal information, including an email address or phone number in connection with that activity, or service, regardless of whether you do so in person, verbally, digitally or in writing via email or text or through any other medium, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about our products or Services using the Personal Information you provided to us. You also attest that you have the legal authority over any Personal Information that you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving. Messaging frequency may vary; and message and data rates may apply.
For the purpose of clarity, we do not share or sell your information obtained as part of this consent with any third parties or affiliates. By providing your Personal Information, you are specifically opting in to communicating with us via SMS/Text.
You may opt out of receiving promotional communications from us by following the instructions in those communications, by texting “STOP,” or by emailing us at michaelgayed@leadlagmedia.com. Opting out may prevent you from receiving messages regarding updates, improvements, or offers. If you opt out, we may still send you non-promotional communications, such as messages about your subscription or our ongoing business relations.
Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our Services unless you directly provide it to us and we provide it to them with your consent. Please note that we do not respond to or honor ‘do not track’ (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. If you have consented to have your Personal Information shared with any third party and you no longer wish to have your Personal Information shared with such parties, then you may opt-out of such disclosures by sending an email to michaelgayed@leadlagmedia.com. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this privacy policy or your separate consent.
Please note that there might be a brief delay between when you submit your request to ‘opt-out’ and when it is processed and reflected in our systems; accordingly, you may continue to receive communications from us for a limited time after you unsubscribe. We appreciate your patience.
Non-Discrimination
We will not discriminate against you because you elect to exercise any of the rights related to your Personal Information, including but not limited to
Denying you Products or Services;
Charging you different prices or rates, including through the use of discounts or other benefits or imposing penalties on you;
Providing a different level or quality of Services to you; or
Suggesting that you will receive a different price or rate for Services or a different level or quality of Services.
PRIVACY POLICY CHANGES
Company reserves the right to change, modify, add, or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of the Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to review this Policy regularly.
HOW TO CONTACT US
If you have any questions about this Policy, or our information practices, please contact us by email at michaelgayed@leadlagmedia.com.
STATE ADDENDUM TO THE COMPANY PRIVACY POLICY
ADDENDUM DATE: April 26, 2026
This State Addendum to the Company Privacy Policy (“Addendum”) supplements the terms of Company’s Privacy Policy and applies to individuals who are residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Virginia, and Utah, as specified below. It describes the rights you may have, depending on the state of your residence, with regard to your personal information, which apply when new or updated laws take effect in these states. This Addendum does not apply to any employees, owners, directors, officers, or contractors of Company or its affiliates.
California Privacy Policy
The section relates solely to residents of the State of California, and for purposes of this section, “you” means residents of the State of California. This section will provide you with information about our information practices and your privacy rights under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA) and applicable regulations (collectively referred to as “CPRA”). Any terms defined in the CPRA have the same meaning when used in this section.
1) Personal Information we collect
Company collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“CPRA Covered Personal Information” or “personal information”). CPRA Covered Personal Information does not include personal information that has been de-identified or aggregated, or that is publicly available information from government records.
In particular, we have collected the following categories of CPRA Covered Personal Information from consumers (as that term is defined in the CPRA) within the last twelve (12) months:
Category
Examples
Collected
A. Personal Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Yes
B. Personal and financial information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Yes
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
No
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
No
F. Internet or other similar network activity.
Browsing history, search history, information on your interaction with a Site, application, or advertisement.
Yes
G. Geolocation data.
Physical location or movements.
No
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
No
I. Professional or employment related information
Occupation, title, employer information, current or past job history or performance evaluations.
No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
No
J. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No
L. Sensitive Personal Information
Social security, driver’s license, state identification or passport numbers; Account log-in, financial account, debit or credit card number in combination with any required security or access code, password or credentials allowing access to an Account; precise geolocation data; racial or ethnic origin, religious or philosophical beliefs or union membership, content of mail, email and text messages unless business is the intended recipient; genetic data; processing of biometric information for the purposes of uniquely identifying a consumer; personal information collected and analyzed concerning your health.
No
2) Categories of sources from which we collect personal information
You have the right to know the categories of sources from which we collect your personal information. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
3) Our processing of your personal information
You have the right to know how we process and use your personal information. We make this information available to you in the USE OF INFORMATION section of our Privacy Policy.
4) Disclosure of Personal Information
You have the right to know if we share your personal information with any third parties and the categories of those third parties. We make this information available to you in the SHARING OF INFORMATION section of our Privacy Notice.
5) No Sales or Sharing of Personal Information
We do not sell personal information for monetary or other consideration, and we do not share your personal information for cross-context behavioral advertising (as defined in the CPRA). We have also not sold or shared the personal information of consumers under 16 years of age.
6) Use of Sensitive Personal Information
We do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m) of the CPRA regulations and we do not collect or process sensitive personal information for purposes of inferring characteristics about you.
7) Your CPRA Consumer Rights
a) Where we are acting as a business (as opposed to a service provider as those terms are defined in the CPRA), you have the following rights:
Right to Access. You have the right to request that we disclose the categories of personal information we collected about you, the categories of sources for the personal information we collected about you, our business or commercial purpose for collecting your personal information, the categories of third parties with whom we share your personal information; and the specific pieces of personal information we collected about you.
Right to data portability. You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.
Right to delete. You may have the right to request that we delete your personal information where we act as a business. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;
Detect bugs or errors in our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.
Right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.
Right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights under the CCPA, including we will not deny you goods or services, charge you different prices for goods or services, provide you a different level or quality of goods or services, or suggest that you will receive a different price for goods or services or a different level of quality of goods and services.
b) Exercising Your Rights
You may exercise your rights to know, delete and correct as described above by submitting a verifiable request to us by email at michaelgayed@leadlagmedia.com.
c) Verification Process
We are only required to fulfill verifiable requests. Only you, you as a parent or a legal guardian on behalf of a minor child, or your authorized agent may make a verifiable request related to personal information. If you submit your request through an authorized agent, we may require you to provide your agent with written permission to do so and verify your identity. We may deny any request by an authorized agent that does not submit proof that the agent has been authorized by you to act on your behalf.
For requests for access to categories of personal information, we will verify your request to a “reasonable degree of certainty.” This may include matching at least two data points that you would need to provide with data points we maintain about you and that we have determined to be reliable for the purposes of
For requests for specific pieces of personal information (portability request), we will verify your request to a “reasonably high degree of certainty.” This may include matching at least three data points that you would need to provide with the data points we maintain about you and that we have determined to be reliable for the purposes of verification. We will also require you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
For requests to delete, we will verify your request to a “reasonable degree” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to the consumer posed by unauthorized deletion.
We will use the personal information you provide in a request only for purposes of verifying your identity or authority to make the request.
d) Response Timing and Format
We will respond to a verifiable request within forty-five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time. If you have an Account with us, we will deliver our written response to that Account. If you do not have an Account with us, we will deliver our written response by mail or electronically, at your option. (Note that the law prohibits us from disclosing at any time a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an Account password, security questions and answers, or any unique biometric data.) If we cannot comply with a request or a portion of the request, we will include the reasons in our response. If we deny your request on the basis that it is impossible or would involve a disproportionate effort, we will explain our reasons, such as the data is not in a searchable or readily accessible format, is maintained for only legal or compliance purposes, or is not sold or used for any commercial purpose and our inability to disclose it, delete or correct it would not impact you in any material manner.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
*Please note that in certain cases we may collect your personal information as a service provider (as opposed to a business, as those terms are defined in the CPRA) pursuant to a contract we have with a commercial client (the CPRA business) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the business. Should you direct your requests to exercise your rights to us, we may be required to share your request with the business, who is the party responsible under the CPRA for receiving, verifying and responding to your requests, or we may direct you to make your request directly to the business.
8) CPRA exemptions
This section (California Privacy Policy) does not apply to the following data which is exempt from the CPRA, including but not limited to: medical information governed by the California Confidentiality of Medical Information Act (CMIA); protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
9) Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to affiliates and other third parties for their direct marketing purposes. To make such a request, please send an email to michaelgayed@leadlagmedia.com.
Notice of Colorado, Connecticut, Virginia and Utah Privacy Rights
The section relates solely to residents of the States of Colorado, Connecticut, Virginia and Utah, and provides you with information about your privacy rights under the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CDPA), the Montana Consumer Data Privacy Act (MCDPA), the Oregon Consumer Privacy Act (OCPA), the Texas Data Privacy and Security Act (TDPSA), the Virginia Consumer Data Protection Act (VCDPA) and the Utah Consumer Privacy Act (UCPA).
For purposes of this section, “residents”, “consumers” or “you” means individuals of those states who are acting in their individual or household context. This section does not apply to individuals acting in their commercial or employment context.
1) Personal Information we collect
You have a right to know the categories and types of personal information we collect about you. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
2) Categories of sources from which we collect personal information
You have the right to know the categories of sources from which we collect your personal information. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
3) Our processing of your personal information
You have the right to know how we process and use your personal information. We make this information available to you in the USE OF INFORMATION section of our Privacy Policy.
*For residents of the State of Virginia, to the extent that we maintain de-identified data, we take reasonable measures to ensure that de-identified data cannot be associated with a natural person, we publicly commit to maintaining and using de-identified data without attempting to re-identify the data, and we contractually obligate any recipient of the data to comply with the same obligations.
4) Disclosure of Personal Information
You have the right to know if we share your personal information with any third parties. We make this information available to you in the SHARING OF INFORMATION section of our Privacy Policy.
5) No Sale of Data or Use of Data for Targeted Advertising
We do not sell your personal information and we do not use your data for targeted advertising (as that term is defined by your applicable state law). We may send you advertising in response to your request for information or feedback or based on your activities with our Services, including your search queries and visits to our Services. However, we will not send you targeted advertising based on your activities across non-affiliated websites, applications or platforms to predict your preferences or interests.
6) Your Rights
a) Where we act as the Controller of your personal information (as opposed to a Processor as those terms are defined in your applicable State law), you have the right to submit a request to us for the following:
Right to access. You have the right to know if we process your personal information and have access to such information and certain details of how we use it.
Right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.
Right to delete. You may have the right to request that we delete your personal information where we act as a controller. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our processors to:
Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;
Detect bugs or errors in our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.
Right to restriction of processing (opt-out). You have the right to opt-out of processing your personal information for purposes of profiling in furtherance of any automated processing of your data that produce legal or similarly significant effects concerning you. (This right only applies to residents of the States of Colorado, Connecticut and Virginia.)
Right to data portability. You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.
Right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights, including but not limited to, by denying you goods or services, charging you different prices for goods or services, or providing you a different level or quality of goods or services.
Right to restrict the processing of sensitive informationUnless we are processing your sensitive information pursuant to any of the legal exemptions listed in Section 8 (Exemptions) below or as otherwise allowed by law:
For residents of the States of Connecticut, Virginia and Colorado, we will not process your sensitive information without first obtaining your consent; and
For residents of the State of Utah, we will not process your sensitive personal information without providing you with notice and an opportunity to opt out.
b) Exercising Your Rights
You may exercise your rights to know, delete and correct as described above by submitting a verifiable request to us by email at michaelgayed@leadlagmedia.com.
c) Authentication Process
We will only fulfill request when we can verify your identify and confirm that you are authority to make such a request. Only you, you as the parent or legal guardian on behalf of your minor child, or your authorized agent, guardian or conservator may make a request related to personal information. If an authorized agent, legal guardian or conservator submits the request, we may require your written permission to do so and may require additional information to authenticate your identity. We may deny a request by an authorized agent, legal guardian or conservator who does not submit proof of authorization to act on your behalf. We will only use the personal information you provide in a request to verify your identity or authority to make the request.
d) Response Timing and Format
We will respond to an authenticated request within forty- five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time. If you have an Account with us, we will deliver our written response to that Account. If you do not have an Account with us, we will deliver our written response by mail or electronically, at your option. If we cannot comply with a request or a portion of the request, we will include the reasons in our response.
*For residents of the States of Colorado, Connecticut and Utah, you may make one request within a twelve-month period at no charge.
*For residents of the State of Virginia, you may make a request up to two (2) times within a twelve (12) month period at no charge. We reserve the right to charge a fee to process or respond to any request that we consider excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7) Right to Appeal
You have the right to appeal our decision within a reasonable period of time after receipt of our response. You may appeal our decision by sending us an email at michaelgayed@leadlagmedia.com. We will respond to your appeal within 60 days of receipt (45 days of receipt for residents of Colorado) and will inform you of any decisions and the reasons for such decisions.
* Please note that in certain cases we may collect your personal information as a processor (as opposed to a controller, as those terms are defined in your applicable state privacy law) pursuant to a contract we have with a commercial client (the controller) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the controller. Should you direct your requests to exercise your rights to us, we may be required to share your request with the controller, who is the party responsible under your applicable state privacy law for receiving, authenticating and responding to your requests.
8) Exemptions
This section (Notice of Colorado, Connecticut, Montana, Oregon, Texas, Virginia and Utah Privacy Rights) does not apply to certain entities and data that are exempt from your applicable state privacy law, including but not limited to the following: covered entities, business associates and protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH); financial institutions and personal information subject to the Gramm-Leach-Bliley Act (GLBA); and personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Family Educational Rights and Privacy Act, the Farm Credit Act and the Driver’s Privacy Protection Act of 1994 (DPPA).