Privacy Policy.

1. Who we are

Lead Gurus is a branded lead generation and paid media optimization platform serving the home improvement industry. We design, run, and optimize advertising campaigns — including the ads, creative, and landing pages behind them — on behalf of home improvement brands, and we deliver the resulting customer inquiries ("leads") to those brands.

In this policy, "Lead Gurus," "we," "us," and "our" refer to Guru Cultivation LLC, a Puerto Rico limited liability company doing business as Lead Gurus. "You" refers to any individual whose personal information we handle, whether you are a consumer, a business contact, or a visitor to one of our sites.

Lead Gurus is the controller of the personal information described in this policy, except where we act as a service provider or processor for a client brand, as described in Section 5.

2. Scope of this policy

This policy applies to personal information we collect through:

• Our corporate website at leadgurus.com, including our contact and application forms;
• Our client portal at clients.leadgurus.com;
• Campaign landing pages and lead forms we build and operate for our client brands, including instant forms hosted inside advertising platforms such as Meta, Google, and TikTok;
• Our advertising and marketing activity, including ads, pixels, conversion tracking, and measurement;
• Email, phone, SMS, and other direct communications with us.

We refer to all of these together as the "Services."

This policy does not cover how our client brands handle your information after we deliver a lead to them. Once a lead reaches the home improvement company you asked to hear from, that company handles your information under its own privacy policy, as an independent business. See Section 5.

3. Information we collect

3.1 Information you give us directly

Consumer and homeowner information. When you submit a form on one of our campaign landing pages or an in-platform lead form, we typically collect:

• Your name, email address, and phone number;
• Your street address, city, state, and ZIP code;
• Details about the project you are interested in — for example, the type of work (roofing, windows, siding, bath, HVAC, solar, and similar), the scope, approximate timing, and whether you own the home;
• Any other details you choose to type into a form field or share in a message;
• The consent you gave — including the exact disclosure language shown to you, the date and time, the page URL, and your IP address — so that we and our clients can demonstrate your consent to be contacted.

Business contact information. When you contact us, apply to work with us, or use our client portal, we collect your name, business email address, phone number, company name, role, service categories, market areas, and the contents of your message or application.

3.2 Information we collect automatically

When you visit our sites or a campaign landing page, we and our analytics and advertising providers automatically collect:

• Device and connection data — IP address, browser type and version, operating system, device type, screen size, and language settings;
• Usage data — the pages you view, the time and date of your visit, how long you stay, what you click, how far you scroll, and the referring page or ad that brought you to us;
• Advertising identifiers — cookie IDs and click identifiers appended to links by advertising platforms, such as Meta's fbclid, Google's gclid, and TikTok's ttclid, which let us attribute a visit or a lead to a specific ad;
• Anti-fraud and bot signals — data generated by Cloudflare Turnstile and similar tools that verify a form was submitted by a real person.

3.3 Information we receive from third parties

• Advertising platforms. When you submit a lead form hosted inside Meta, Google, or TikTok, that platform sends us the information you provided in the form, along with campaign and attribution data.
• Our client brands. Clients connect their CRM or sales systems to our platform and send us outcome data about the leads we delivered — for example, whether an appointment was set, held, or sat, and whether a sale closed. We use this to measure and optimize campaign performance.
• Verification and enrichment providers. We may use services that validate a phone number or email address, check line type, screen for duplicate or fraudulent submissions, or append publicly available business or property information.
• Publicly available sources. Business information from company websites, industry directories, and professional networks.

3.4 Sensitive information

We do not seek, and ask that you do not send us, sensitive personal information such as Social Security numbers, financial account numbers, payment card numbers, government ID numbers, precise geolocation, health information, biometric data, or information about race, religion, sexual orientation, or union membership. We do not use or disclose sensitive personal information for purposes beyond those permitted under applicable law.

4. How we use information

We use personal information for the following purposes:

We may create and use aggregated or de-identified information — such as benchmark cost-per-lead figures or category performance trends — that no longer identifies any individual. We do not attempt to re-identify this information.

5. How leads are shared with our clients

This is the most important section for consumers, so we will be direct about it.

When you complete a form on a campaign landing page, that page is branded for, and operated on behalf of, a specific home improvement company. By submitting the form, you are asking that company to contact you. We deliver your submission to that company — and to the service providers it uses, such as its CRM or call center — so it can do so.

In some engagements we act as a service provider or processor for the client brand rather than as an independent controller. In those cases we handle personal information only on that client's documented instructions and under a written contract that restricts our use of it, and the client's privacy policy governs.

We do not sell leads to the highest bidder, and we do not resell the same consumer inquiry to multiple unrelated companies. Our model is exclusive, branded lead generation for a single client brand per inquiry.

6. Cookies, pixels, and advertising

We and our providers use cookies, pixels, SDKs, local storage, and server-side APIs on our sites and campaign landing pages. We use them in these categories:

• Strictly necessary — required for a page to load, a form to submit, and bot protection to work. These cannot be turned off through our sites.
• Analytics — to understand how pages perform and where visitors drop off.
• Advertising and conversion measurement — to attribute a lead to the ad that produced it, to measure campaign performance, to build and exclude audiences, and to show you relevant ads on other sites and apps.

Some of this advertising activity constitutes "sharing" for cross-context behavioral advertising and a "sale" under certain U.S. state privacy laws, even though no money changes hands. You can opt out — see Section 10.

Browser controls. Most browsers let you block or delete cookies through their settings. Blocking strictly necessary cookies may break forms and other features.

Global Privacy Control. We treat a Global Privacy Control (GPC) signal sent by your browser as a valid request to opt out of sale and sharing for that browser and device.

7. Meta, Google, and TikTok platform data

We are an advertising partner on Meta, Google, and TikTok, and we use their business tools and APIs to run campaigns for our clients. This section explains specifically how we handle data in connection with those platforms.

7.1 What we receive from these platforms

• Lead form submissions. When you complete an instant form inside Facebook, Instagram, Google, or TikTok, we retrieve the information you entered in that form through the platform's lead access API.
• Advertising account data. Campaign, ad set, ad, creative, spend, and performance metrics for the ad accounts we are authorized to manage.
• Business account access. Where a client grants us access through Meta Business Manager, Google Ads, or TikTok Ads Manager, we access the assets — ad accounts, Pages, pixels, catalogs — that the client has explicitly assigned to us.
• Page and profile data. Basic public information about a client's business Page or profile needed to run and attribute ads.

7.2 How we use it

We use platform data only to operate, measure, and optimize advertising campaigns for the client that authorized us, and to deliver the resulting leads to that client. We do not use it to build profiles for unrelated purposes, and we do not combine one client's data with another client's for that client's benefit.

7.3 What we send to these platforms

To measure conversions accurately, we send conversion events back to advertising platforms — including through Meta's Conversions API, Google's enhanced conversions, and TikTok's Events API. Where these events include contact information such as an email address or phone number, it is hashed before transmission using SHA-256 so that the platform receives an irreversible identifier rather than the value itself.

7.4 Platform terms

Our use of data obtained from these platforms complies with their developer and advertising terms, including the Meta Platform Terms and Developer Policies, Google Ads policies, and TikTok's advertising terms. We do not transfer platform data to any data broker, and we do not sell it.

If you want to know how these platforms themselves handle your information, see the Meta Privacy Policy, the Google Privacy Policy, and the TikTok Privacy Policy.

8. Calls, texts, and recordings

When you submit a lead form, the disclosure shown above the submit button tells you who may contact you and how. That disclosure — typically your express written consent to receive calls and text messages, including messages sent using automated technology, at the number you provided — is part of the record we keep.

• Consent is not a condition of purchase. You do not have to agree to be contacted by automated means in order to buy anything.
• Message and data rates may apply to text messages you receive.
• To stop text messages, reply STOP to any message. Reply HELP for help.
• To stop calls, tell the caller to place you on its internal do-not-call list, or email us at info@leadgurus.com and we will pass the request to the relevant company and suppress your information on our side.
• Call recording. Calls with us or with our clients may be monitored or recorded for quality, training, and compliance. Where the law requires it, you will be notified at the start of the call and may decline.

9. Who we share data with

We disclose personal information to the following categories of recipients:

We require our service providers to use personal information only to perform services for us, and to protect it appropriately.

We do not sell personal information for monetary consideration. As explained in Section 6, our use of advertising cookies and pixels may qualify as a "sale" or "sharing" under certain state laws, and you may opt out.

10. Your choices

• Opt out of sale or sharing. Email info@leadgurus.com with the subject line "Do Not Sell or Share My Personal Information," or enable Global Privacy Control in your browser.
• Marketing emails. Click the unsubscribe link in any marketing email. We will still send transactional messages related to a request you made.
• Text messages. Reply STOP to any message.
• Cookies. Adjust your browser settings, or use the opt-out tools at the DAA WebChoices and NAI pages.
• Platform ad settings. Manage your ad preferences directly in your Meta ad preferences and Google ad settings.
• Access, correction, or deletion. See Section 11 and Section 12.

11. Data deletion requests

You may ask us to delete the personal information we hold about you at any time, regardless of where you live.

If you used Facebook or Instagram

If you submitted a form or connected to us through Facebook or Instagram and want the data we obtained through Meta deleted, email us at the address above and mention Facebook or Instagram. You can also remove our access at any time from your Facebook Apps and Websites settings. Removing access stops future data flow; email us to have information we already hold deleted.

What we may keep

We may retain a limited record after deletion where the law allows or requires it — for example, proof of the consent you gave and a suppression record containing your contact details, kept solely so that we do not contact you again or re-add you to a campaign. We also retain information needed for tax, accounting, fraud prevention, or the defense of legal claims.

Deleting your information with us does not delete it from a client brand that already received your lead. Contact that company directly, or ask us and we will pass your request along.

12. U.S. state privacy rights

Depending on where you live, you may have some or all of the following rights:

• Know and access — what personal information we collected about you, the categories of sources, our purposes, and the categories of recipients, and to receive a copy in a portable format.
• Delete — ask us to delete personal information we collected from you.
• Correct — ask us to fix inaccurate personal information.
• Opt out — of the sale or sharing of personal information and of targeted advertising.
• Limit — the use and disclosure of sensitive personal information.
• Non-discrimination — we will not deny you services, charge you a different price, or give you a lesser quality of service for exercising these rights.
• Appeal — if we deny your request, you may appeal by replying to our decision. If your appeal is denied, you may contact your state attorney general.

These rights are recognized under laws including the California Consumer Privacy Act as amended by the CPRA, and comparable laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states.

How to exercise them

Email info@leadgurus.com with the right you want to exercise. We will verify your identity by matching the information you give us against our records, and may ask for additional detail if we cannot confirm a match. An authorized agent may submit a request on your behalf with written proof of authorization.

California "Shine the Light"

California residents may request information about disclosures of personal information to third parties for their direct marketing purposes. Send requests to the address in Section 19.

13. Data retention

We keep personal information only as long as we need it for the purposes described in this policy:

• Consumer lead records — generally up to 5 years from submission, which reflects the statute of limitations under telemarketing and consumer protection laws for which we must be able to evidence consent.
• Business contact and client records — for the duration of the relationship and generally up to 7 years afterward for contractual, tax, and accounting purposes.
• Website analytics and advertising identifiers — generally up to 24 months, or the retention period set by the platform, whichever is shorter.
• Suppression and do-not-contact records — retained indefinitely, because deleting them would defeat their purpose.

When a retention period ends, we delete the information or de-identify it so it can no longer be linked to you.

14. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit using TLS, access controls and least-privilege permissions for our systems, bot and abuse protection on our forms, hashing of contact identifiers sent to advertising platforms, and contractual security obligations on our service providers.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you share information with us at your own risk. If we become aware of a breach affecting your personal information, we will notify you and the relevant authorities as required by law.

15. Children's privacy

Our Services are directed to homeowners and business professionals, and are not intended for children. We do not knowingly collect personal information from anyone under 18, and we do not knowingly sell or share the personal information of anyone under 16. If you believe a child has given us personal information, email info@leadgurus.com and we will delete it.

16. Third-party sites

Our Services link to sites we do not operate, including our client brands' websites, advertising platforms, and our client portal provider. We are not responsible for the privacy practices or content of those sites. Read their privacy policies before providing information to them.

17. International visitors

Lead Gurus is based in the United States and our Services are intended for users in the United States. If you access the Services from outside the U.S., your information will be transferred to, stored in, and processed in the United States, where privacy laws may differ from those in your country. By using the Services, you consent to that transfer.

18. Changes to this policy

We may update this policy as our practices, technology, or the law changes. When we do, we will revise the "Last updated" date at the top of this page. If the changes are material, we will provide additional notice — for example, a banner on our site or an email where we have your address. Your continued use of the Services after an update means you accept the revised policy.

19. Contact us

For any privacy question, or to exercise any right described in this policy, contact us: