Privacy Policy

Last Update: 11/06/2024

1. Data Controller and Data Processor

At The Lead Partner, we act both as a controller and processor of personal data, depending on the context and the service being provided. Below, we clearly explain how and when we perform each role, with specific examples to better understand the handling of data.

Data Controller

When we act as a data controller, The Lead Partner is responsible for deciding the purposes and means of processing personal data. This occurs when:

Customer Relationship Management: We collect personal information from our customers to manage the relationship, such as communications, billing, and support.
- Example: If you register for our service and provide us with your contact information, we are responsible for how we use that data to manage the relationship.
Direct Marketing: We send promotional and marketing communications to users, based on their interests and preferences.
- Example: When you subscribe to our newsletter and receive updates about our services.
Service Optimization: We collect user behavior data on our website to improve our service offering, personalize the user experience, and perform market analysis.
- Example: We use cookies to understand how you navigate our site and optimize the content displayed.

As a data controller, we ensure that all personal data is processed in accordance with applicable data protection laws, such as the GDPR, CCPA, LGPD, among others.

Data Processor

The Lead Partner acts as a data processor when we process personal data on behalf of our clients, following their instructions and solely for the purpose of executing the contracted services. This occurs when:

Lead Generation: We manage lead data in campaigns conducted for our clients.
- Example: When we conduct a lead generation campaign for a client and process the obtained contact data, strictly following the client’s instructions.
Automated Marketing: We implement automated campaigns using third-party tools (e.g., Mailchimp) and process personal data on behalf of our clients.
- Example: When we use a client’s email list to send automated promotional messages to their contacts.

As a data processor, we follow the guidelines set by our clients and comply with the defined contractual obligations, ensuring the protection of personal data through data processing agreements that guarantee the security and confidentiality of the information.

2. Data Retention

The Lead Partner retains personal data only for the time necessary to fulfill the purposes for which it was collected, in compliance with our legal and contractual obligations. Below, we detail the retention periods by data type and the specific procedures to ensure the proper deletion of information.

a. Retention Periods by Data Type

Non-Qualified Leads: Data of non-qualified leads is retained for a maximum of 6 months from the collection date.
- Purpose: Evaluation of potential reuse of leads and analysis of previous campaigns.
Qualified Leads and Active Customer Data: Data of qualified leads is retained during the contractual relationship with the customer and is deleted 12 months after the end of the contractual relationship.
- Purpose: Long-term support, audit of results, and campaign analysis.
Billing and Payment Information: Information related to financial transactions is kept for 7 years to meet tax and accounting requirements.
- Purpose: Compliance with tax and accounting regulations, financial audits.
Website Analytical and Behavioral Data: Data collected automatically, such as IP addresses and browsing behavior, is retained for a maximum of 2 years.
- Purpose: Performance analysis, improving user experience, and optimizing the services offered.
Communication Records: We retain communication records with users for 3 years after the last interaction.
- Purpose: Ensuring proper follow-up on support requests and conducting internal audits.
Activity Logs (Audit and Compliance): We retain system activity logs for 5 years.
- Purpose: Responding to security audits and fulfilling data protection requirements.

b. Automated Data Deletion

To ensure that data is deleted promptly and securely at the end of the retention period, we have implemented automated deletion procedures:

Deletion Process: Personal data is deleted or anonymized automatically when the defined retention periods expire. We use software tools that periodically review stored data records to identify those that have reached the retention deadline.
Review Frequency: We conduct monthly reviews to ensure that all data whose retention period has expired is deleted securely. Deletion includes secure digital removal, which ensures that data cannot be recovered subsequently.
Data Anonymization: In some cases, data may be anonymized instead of completely deleted, so that it can be used for internal statistical analysis without compromising user privacy.

c. Retention Review

Retention Policy Review Frequency: We review our data retention policies annually to ensure that the retention periods are appropriate in accordance with changes in legal regulations and industry best practices.
User Notification: If retention periods are modified, we will notify affected users at least 30 days in advance and give them the opportunity to exercise their rights regarding their data.

Transparency in Retention and Deletion

We maintain a transparent approach regarding our practices for retaining and deleting personal data. For any inquiries about how personal data is handled or about data deletion, users can contact our Privacy Officer at privacy@theleadpartner.com.

3. International Data Transfers

At The Lead Partner, we transfer personal data to other countries only when necessary for the provision of our services and in strict compliance with international data protection regulations. Below, we detail the mechanisms and safeguards used to ensure the protection of the information being transferred.

International Data Transfers at The Lead Partner

International transfers of personal data are carried out in compliance with applicable data protection laws, such as the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant regulations. These are the details of how we handle data transfers:

a. Countries Involved in the Transfers

The Lead Partner may transfer personal data to the following countries:

United States: For the management of marketing campaigns, cloud storage, and data analysis.
Brazil: To provide support and manage local operations.
European Union (including the United Kingdom and Switzerland): To comply with the regulations of clients located in these territories.
Other Countries: Where our providers or subcontractors may have their facilities, provided they comply with international data protection standards.

b. Legal Mechanisms for Transfers

To ensure adequate protection of personal data during international transfers, we use one or more of the following legal mechanisms:

Standard Contractual Clauses (SCCs): We use Standard Contractual Clauses (SCCs) approved by the European Commission for the transfer of personal data outside the European Economic Area (EEA). These clauses ensure that the transferred data is afforded the same level of protection as within the EU.
EU-U.S. Data Privacy Framework: For transfers to the United States, we adhere to the EU-U.S. Data Privacy Framework. This framework ensures that service providers in the U.S. comply with the obligations established by EU data protection regulations, ensuring an adequate level of protection.
Transfer Impact Assessments (TIAs): When transferring data outside the EEA, we conduct a Transfer Impact Assessment (TIA). This assessment allows us to ensure that the destination countries have appropriate regulations in place to protect personal information.
International Data Processing Agreements: Additionally, when working with providers or subcontractors, we sign International Data Processing Agreements that ensure those providers comply with current data protection regulations.

c. Guarantees and Protective Measures

The Lead Partner adopts the following measures to ensure data security during international transfers:

Data Encryption: All personal data is encrypted during transfer to protect it from unauthorized access.
Restricted Access: Only authorized personnel and necessary subcontractors have access to the data, under strict confidentiality policies.
Compliance Monitoring: We periodically review our subcontractors and service providers to ensure they comply with the data protection commitments established in the agreements.

If your personal data is transferred outside your country of origin, you have the right to:

Request Information: You may request details about the international transfers we conduct, including the countries and implemented safeguards.
Object to the Transfer: In certain cases, you have the right to object to the transfer of your personal data to third countries.

Transparency and Accountability

We maintain a transparent approach regarding our international data transfer practices. If you wish to obtain more information or have questions about how we manage international transfers, you can contact us directly at privacy@theleadpartner.com.

4. User Rights by Region

At The Lead Partner, we recognize and respect the rights that users have regarding their personal data. These rights vary depending on the region in which the user is located and are granted to ensure transparency, access, and control over personal information. Below, we detail the user rights for each relevant region and how they can be exercised.

For users in the EU, United Kingdom, and Switzerland, the following rights apply under the General Data Protection Regulation (GDPR):

Right of Access
- Description: You have the right to request a copy of all personal data that we are processing about you.
- Exercise Example: You can request access by sending an email to privacy@theleadpartner.com. To verify your identity, we will request a copy of a valid identification document (e.g., passport or national ID). We will respond within 30 days of receiving the request and verifying your identity.
Right to Rectification
- Description: You can request the correction of any incorrect or incomplete personal data.
- Exercise Example: To request rectification, send an email to our privacy team. We will ask for specific information to verify the inaccuracy and the proper correction. The correction will be made within 30 days.
Right to Erasure (“Right to be Forgotten”)
- Description: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.
- Exercise Example: You can send a deletion request to privacy@theleadpartner.com. To process the request, we will verify your identity by requesting information such as your email address and other details to confirm your relationship with The Lead Partner. Deletion will be carried out within 30 days, unless there are legal exceptions.
Right to Data Portability
- Description: You can request a copy of your data in a structured and commonly used format for transfer to another provider.
- Exercise Example: Send your request by email, indicating which data you wish to receive and in what format. We will provide the data within 30 days.
Right to Restrict Processing
- Description: You can request that the processing of your data be limited in certain circumstances (e.g., if you dispute the accuracy of the data).
- Exercise Example: After receiving your request, we will temporarily limit the processing of your data until the issue is resolved. We will keep you informed of the status of the restriction.
Right to Object
- Description: You can object to the processing of your personal data for direct marketing purposes or when the processing is based on legitimate interests.
- Exercise Example: If you wish to object to direct marketing, simply click on the “Unsubscribe” link included in all of our promotional emails.

b. Brazil (LGPD)

Users in Brazil have the following rights under the General Data Protection Law (LGPD):

Right of Confirmation and Access
- Description: You can request information on whether we process your data and access that data.
- Exercise Example: Send us an email at privacy@theleadpartner.com, and we will confirm whether we process your data and provide access within 15 business days.
Right to Correct Inaccurate Data
- Description: You have the right to correct any inaccurate or outdated information.
- Exercise Example: Correction will be made after verifying your identity. This may involve sending an official document supporting the correction. Rectification will be done within 15 days.
Right to Delete Unnecessary Data
- Description: You can request the deletion of personal data that is unnecessary, excessive, or processed in violation of the LGPD.
- Exercise Example: Send us an email requesting deletion. We will evaluate it and respond if appropriate, confirming deletion within 30 days.

c. California, United States (CCPA)

Users in California have rights under the California Consumer Privacy Act (CCPA), including:

Right to Know
- Description: You can request information about the categories of data we collect and the purposes of processing.
- Exercise Example: Send us a request to privacy@theleadpartner.com. To ensure privacy, we will conduct a verification process that may include questions about previous interactions with our services. We will respond within 45 days.
Right to Delete
- Description: You can request the deletion of your personal data, except in certain circumstances (such as when necessary to comply with legal obligations).
- Exercise Example: If you want us to delete your data, we will ask you to confirm your request and provide information to verify your identity. Deletion will be processed within 45 days.
Right to Opt Out of Data Sales
- Description: You can opt out of the sale of your personal data.
- Exercise Example: You can click on “Do Not Sell My Information” on our website or contact us directly to exercise this right.
Right to Non-Discrimination
- Description: You will not be discriminated against for exercising any of your privacy rights.
- Exercise Example: If you feel you have been treated unfairly after exercising any of these rights, contact us so we can correct the situation.

d. Australia and Costa Rica

For users in Australia and Costa Rica, you have the following rights under local privacy laws:

Right of Access and Correction
- Description: You can access your personal data and request corrections at any time.
- Exercise Example: Send us an email providing the necessary data to verify your identity. We will grant access or make corrections within a reasonable period of 30 days.
Right to Deletion
- Description: You can request the deletion of your data when it is no longer necessary or when you have withdrawn your consent for processing.
- Exercise Example: Send a deletion request, and we will provide a response within 30 days after verifying your identity.

e. Mechanisms to Exercise Rights

Email: Send your requests to privacy@theleadpartner.com. All emails must include sufficient information to verify your identity.
Confirmation and Procedures: Upon receiving a request, we will send a confirmation of receipt and process the request within the stipulated time frame according to applicable regulations.
Web Form: We are developing automated forms that will be available to facilitate the management of specific requests in each jurisdiction.

Transparency and Facilitation

We are committed to facilitating the exercise of users’ rights, providing direct assistance through our privacy team, and responding promptly to all requests.

5. Cookies and Tracking Technologies at The Lead Partner

To provide you with an enhanced and personalized experience, The Lead Partner uses cookies and other tracking technologies such as pixels and web beacons. These technologies allow us to understand how you interact with our website, optimize campaign performance, and provide relevant advertising according to your interests.

a. What are Cookies?

Cookies are small text files that are stored on your device when you visit our website. They allow the site to “remember” your actions and preferences over time, so you don’t have to re-enter them each time you visit or navigate from one page to another.

b. Types of Cookies We Use

At The Lead Partner, we use the following types of cookies:

Essential Cookies
- Purpose: These cookies are necessary for the functioning of the website. Without them, the site cannot function properly.
- Examples:
  - Authentication Cookies: These cookies ensure that you can log in securely and keep your session active while browsing our site.
Performance and Analytics Cookies
- Purpose: We use these cookies to understand how users interact with our website and to improve its performance.
- Examples of Platforms Used:
  - Google Analytics: Collects information on how users navigate the site, including pages visited and time spent on each page.
  - Hotjar: Allows “session replay” to better understand how users interact with different parts of the site.
Functionality Cookies
- Purpose: These cookies allow us to remember your preferences and provide enhanced, personalized functionality.
- Examples:
  - Language Preferences: Stores the user’s language selection to display the site in the preferred language each time you visit.
Marketing and Advertising Cookies
- Purpose: These cookies are used to personalize the ads you see, ensuring that we show you relevant content according to your interests. They may be used for:
  - Retargeting: Showing you The Lead Partner ads on other websites you visit.
  - Measuring Efficiency: Determining the effectiveness of our advertising campaigns.
- Examples of Platforms Used:
  - Google AdSense: We use Google AdSense cookies to display ads relevant to your browsing behavior. These cookies collect information about your interests and browsing patterns, allowing us to present you with tailored advertising.
  - Audiencerun: These cookies allow the delivery of personalized ads based on user behavior and also enable performance analysis of such ads.
  - Meta (Facebook and Instagram Ads): We use cookies to track the effectiveness of our ads on Facebook and Instagram. These cookies allow tracking conversions and audience analysis.
Third-Party Advertising Cookies
- Purpose: In addition to our own cookies, we also use third-party cookies to provide an integrated advertising experience.
- Examples of Platforms Involved:
  - Google Ads: Google Ads cookies allow us to analyze the effectiveness of our advertising campaigns and adjust our marketing strategies to improve performance.
  - Pinterest Ads: We use cookies to display targeted advertising on Pinterest based on your interests and activity on our site.
  - Audiencerun: Provides interest-based advertising on third-party platforms. These cookies analyze user behavior to serve relevant ads.

c. Other Tracking Technologies Used

In addition to cookies, we use other technologies to track your interactions on our website:

Tracking Pixels
- Purpose: Tracking pixels (also known as web beacons) are pieces of code embedded in our pages that allow us to track activities such as email openings or user behavior on the site.
- Examples of Platforms Involved:
  - Meta Pixel (Facebook): Used to track user behavior and ad effectiveness on Facebook.
  - Google Ads Pixel: Measures conversions and identifies the effectiveness of advertising campaigns.
Web Beacons and Retargeting Scripts
- Purpose: We use web beacons and scripts that allow us to display personalized ads when you visit other websites that are part of the advertising networks in which we participate.
- Example: Audiencerun beacons are used to show specific ads based on user behavior on our site.

You can manage your cookie preferences at any time through our Cookie Preferences Center, available in the footer of our website.

Accept or Reject Cookies: You can choose to accept all cookies, only essential cookies, or configure which types of cookies you wish to allow.
Browser Settings: You can also control the use of cookies through your browser settings. You can choose to delete stored cookies or prevent new cookies from being stored.

Note: Disabling some essential cookies may affect website functionality, limiting the ability to use certain features.

For greater clarity and detail on the use of cookies, we have created a separate Cookie Policy, where the following are explained:

Specific Purposes of Each Cookie: Including the names of the cookies, their purposes, and storage durations.
How to Revoke Consent: Clear instructions on how to revoke previously given consent.

You can access our Cookie Policy at any time by clicking on the link located in the footer of our website or visiting [Cookie Policy URL].

Compliance with Regulations

The Lead Partner complies with the EU cookie and consent regulation (ePrivacy Directive) and ensures that all users, especially those in the European Union, have the option to grant or deny their consent before non-essential cookies are installed.

Updates to Cookies and Tracking Technologies

We periodically update our cookie policy and practices to reflect any changes in laws or tracking technologies. We will always notify users of any significant changes that may affect their privacy.

6. Information Security

At The Lead Partner, the security of personal data is a priority. We have implemented appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, and destruction. In addition, we have developed specific processes to limit access for providers or subcontractors and ensure that they comply with our security policies.

Information Security at The Lead Partner

The Lead Partner applies a comprehensive approach to protecting personal data, aligned with international information security standards such as ISO 27001 and industry best practice recommendations. The measures adopted cover both the technical and organizational areas.

a. Technical Security Measures

Data Encryption
- We use end-to-end encryption to protect personal information in transit and at rest. This means that any data transmitted between your device and our servers is protected by SSL/TLS encryption.
- Stored data is encrypted using AES-256, an advanced security standard, to protect information from unauthorized access.
Multi-Factor Authentication (MFA)
- We implement multi-factor authentication (MFA) for all administrative accounts that have access to personal data. This adds an additional layer of security, ensuring that only authorized personnel can access the information.
Role-Based Access Control (RBAC)
- We use a role-based access control system (RBAC) to ensure that only authorized personnel have access to personal data. Permissions are granted based on the responsibilities and functions of each employee, minimizing the risk of unnecessary access.
Monitoring and Intrusion Detection
- We employ security monitoring tools to supervise activity on our systems in real-time. These tools allow us to detect suspicious activities and respond quickly to threats.
- We use intrusion detection and prevention systems (IDS/IPS) to identify and block potential unauthorized access attempts.
Backups and Data Recovery
- We regularly perform backups of all personal data and store them securely. These backups are encrypted and maintained in multiple locations to ensure recovery capability in case of data loss or security incidents.
Firewalls and Network Segmentation
- Our servers are protected by advanced firewalls that prevent unauthorized access to our systems. We also use network segmentation to isolate sensitive data from other system elements, reducing the risk of internal attacks.

b. Organizational Security Measures

Information Security Policy
- We have an Information Security Policy that clearly defines the standards and procedures for handling personal data. All our personnel are required to follow this policy and sign a confidentiality commitment.
Ongoing Training
- We provide ongoing security training to all our employees, ensuring they are informed about cybersecurity best practices and risks. The training programs include:
  - Phishing Awareness: Identification and reporting of phishing attempts.
  - Personal Data Protection: Proper practices for handling and protecting sensitive information.
Supplier Evaluation and Auditing
- Third-Party Access Controls: All providers and subcontractors requiring access to personal data are subject to strict role-based access controls (RBAC). These controls ensure that access is limited only to the data necessary to perform the contracted tasks.
  - Example: A provider offering data analysis services will only have access to aggregated and anonymized information, not complete personal data.
- Confidentiality Agreements: All providers must sign a Confidentiality Agreement and a Data Processing Agreement (DPA) that detail their responsibilities and obligations regarding data security.
- Access Permission Review: We review our providers’ access permissions every six months to ensure that only authorized personnel have access to data and that unnecessary accesses are removed.
- Supplier Security Audits: We conduct regular security audits of our providers to ensure they comply with our policies and legal requirements. These audits are conducted at least once a year, and also when a new provider is introduced.
Penetration Testing and Security Audits
- We regularly conduct penetration testing to identify potential vulnerabilities in our systems and fix them before they can be exploited.
- We hire external auditors to perform security audits that review our systems, policies, and security procedures.
Incident Response Plan
- We have an Incident Response Plan that allows us to act quickly in the event of a security breach. This plan includes:
  - Identification and Containment: Procedures to identify and contain security incidents.
  - Notification: Affected users will be notified within 72 hours in case of a breach that could compromise their personal data, in accordance with GDPR regulations.

c. Compliance Monitoring and Continuous Improvement

Continuous Monitoring: We use automated security monitoring tools to identify anomalies and potential vulnerabilities in real-time, ensuring corrective actions are taken immediately.
Annual Security Evaluation: In addition to regular audits, we conduct an annual evaluation of our security policies and systems to ensure they are aligned with industry best practices and applicable regulations.

Security Guarantees and Shared Responsibility

The Lead Partner and our subcontractors work together to ensure the security of personal data. While we ensure the implementation of organizational and technical measures, our clients are also responsible for following best practices when interacting with our platforms.

Internal and Third-Party Controls: All accesses, whether by our internal staff or providers, are logged and monitored to prevent any misuse of data.
Periodic Access Review: The list of providers with access to personal data is reviewed every six months, and any unnecessary access is immediately revoked.

Security Updates

We regularly review and update our security measures to ensure they comply with technological advancements and industry best practices. Users will be notified in case of any significant changes affecting the security of their personal data.

7. Dispute Resolution and Arbitration

The Lead Partner is committed to resolving any dispute related to our privacy policy and the handling of personal data in a fair and efficient manner. To do this, we offer several dispute resolution mechanisms, including arbitration and mediation processes, depending on the user’s region of residence. Below, we detail the procedures and the organizations involved.

Dispute Resolution and Arbitration at The Lead Partner

At The Lead Partner, we strive to maintain transparency and user trust in the handling of their personal data. If you have a dispute related to this privacy policy, we offer different methods of resolution to address your concerns in a fair and efficient manner.

a. Initial Contact and Direct Resolution

If you have a dispute or complaint related to how we process your personal data, we encourage you to contact us directly through the Privacy Officer:

Email: privacy@theleadpartner.com
Response Time: We are committed to responding to your inquiry within 30 days of receipt.

b. Regional Dispute Resolution Mechanisms

If we are unable to resolve your concern satisfactorily through initial contact, we offer the following dispute resolution mechanisms depending on your region:

European Union, United Kingdom, and Switzerland
- Data Protection Authorities: Users in the EU, United Kingdom, and Switzerland have the right to lodge a complaint with the Data Protection Authority (DPA) of their country of residence if they believe their privacy has been violated.
- Alternative Dispute Resolution (ADR): You may also opt for Alternative Dispute Resolution (ADR) through a neutral mediator to reach an amicable agreement.
- JAMS Arbitration Mechanism: For users in these regions, we offer the possibility of participating in binding arbitration administered by JAMS, in accordance with the JAMS International Arbitration Rules.
  - How the Arbitration Process Works: Users wishing to opt for arbitration must submit a written request to privacy@theleadpartner.com. Once the request is accepted, JAMS will assign a neutral arbitrator who will review the dispute and make a binding decision. All initial arbitration costs will be covered by The Lead Partner, unless otherwise required by law.
United States (including California)
- JAMS or BBB (Better Business Bureau): Users in the United States have access to dispute resolution processes through JAMS or Better Business Bureau (BBB), depending on their preference. These services provide fair and efficient resolution without requiring formal judicial proceedings.
  - Arbitration in the U.S.: We offer an arbitration process with JAMS, which provides a quick and efficient alternative to the court system. Users can submit their complaint through JAMS’ online channels and follow the procedure indicated by the organization.
  - How to Opt for Arbitration: To opt for arbitration in the United States, you must submit a written request to privacy@theleadpartner.com within 60 days of the dispute. Once the request is received, we will contact you to initiate the formal process.
Brazil (LGPD)
- National Data Protection Authority (ANPD): Users in Brazil have the right to lodge a complaint with the ANPD if they believe their personal data has not been handled in accordance with the LGPD.
- Mediation with Local Providers: We offer the possibility of local mediation through accredited service providers, who can facilitate dialogue between the user and The Lead Partner to reach a fair resolution.
- Local Arbitration: Additionally, users may opt to participate in local arbitration, administered by recognized organizations in Brazil. The Lead Partner will cover the initial arbitration costs.
Australia and Costa Rica
- Local Data Protection Authorities: Users in Australia and Costa Rica may contact their respective data protection authorities if they feel their rights have been violated.
- Local Arbitration and Mediation: We also offer the possibility of local arbitration or mediation to resolve any dispute. This option will be provided in accordance with local laws, seeking the fastest and fairest solution.

c. Alternative Dispute Resolution (ADR) Process

If, after contacting The Lead Partner, you are not satisfied with the offered resolution, you may opt for Alternative Dispute Resolution (ADR), which allows the participation of an external mediator or arbitrator to help reach a solution.

Confidentiality: The ADR process is completely confidential and conducted in a neutral environment.
Costs: The Lead Partner will cover the initial mediation costs, but additional costs will be subject to agreement between the parties.

d. Opt-out of the Arbitration Process

Users have the right to opt out of the arbitration process:

Opt-out Deadline: You may exercise your right to opt out within 30 days of accepting the terms and conditions of this policy.
How to Opt-out: To exercise this right, send an email to privacy@theleadpartner.com with the subject “Opt-out of Arbitration.” You will receive a confirmation of your exclusion within 7 business days.

e. Subsequent Procedures

If none of the above options resolve the dispute, The Lead Partner will evaluate the possibility of proceeding with judicial actions in accordance with the applicable jurisdiction. We are committed to resolving all disputes in the most transparent and fair way possible.

f. Jurisdiction and Applicable Law

United States as Main Jurisdiction: Any dispute that cannot be resolved through the methods described above will be subject to the jurisdiction of the courts of the United States. The applicable law will be that of the United States, except in cases where local regulations grant additional rights that prevail.

Transparency and Commitment

The Lead Partner is committed to providing support at every stage of the dispute resolution process. Our privacy team is available to answer any questions and guide you through the process to ensure a fair resolution.

8. Change Notifications

The Lead Partner is committed to keeping you informed of any significant changes to our Privacy Policy. Below, we detail the methods we use to notify you of changes, the types of changes that may occur, and the effects these could have on our services.

Change Notifications at The Lead Partner

To ensure transparency in the handling of personal data, The Lead Partner will inform all users of any significant modifications to this Privacy Policy. These changes will be communicated through various channels and with sufficient advance notice to allow you to understand how they may affect you.

a. Notification Methods

To notify users of significant changes to the Privacy Policy, we will use the following methods:

Direct Email
- Registered Users: We will send an email to all registered users explaining the change in clear and simple terms. This email will include a link to the new version of the policy.
- Advance Notice: An advance notice will be provided at least 30 days before the changes take effect, allowing users to review the changes and ask questions.
Banner or Notice on the Website
- Notification Banner: We will place a visible banner on our website to notify all users of the privacy policy update. The banner will remain visible for at least 30 days after the changes take effect.
- Confirmation of Reading: Users will need to confirm that they have read the changes to continue using our website or services.
Notification in User Account
- Internal Notifications: Registered users will receive notifications through their user accounts, specifying the changes made and providing instructions on how to proceed if they disagree with them.

Changes to our Privacy Policy may range from minor modifications to significant changes that directly affect how we handle your personal data. The types of changes we will notify include:

b. Types of Changes Notified

Changes in How Personal Data Is Collected or Used
- Example: If we decide to start collecting a new type of personal data, such as biometric information, to personalize our services, users will be notified in advance so that they can give their consent or exercise their right to object.
New Purposes for Data Processing
- Example: If the personal data we collect will be used for a purpose different from the one initially established, such as using contact information to conduct third-party marketing campaigns, we will notify users and request their consent if required by applicable regulations.
Update of Providers or Third Parties
- Example: If we start sharing personal data with a new service provider (e.g., a new partner providing data analysis), we will notify users of this change, including details about the provider and the data protection safeguards that have been established.
Changes to User Rights
- Example: If new privacy rights are introduced in a specific region, such as the right to restrict processing under a new local regulation, we will notify users of these rights and how they can be exercised.
Regulatory and Legal Compliance Changes
- Example: If the policy is updated to comply with new international regulations, such as a new privacy law in a country where we operate, we will notify users about how this change affects the management of their data.
Changes to Contractual Clauses or Data Processing Terms
- Example: If the terms under which a third party processes personal data are updated (e.g., a change in a subcontractor’s contract terms involving greater access to personal data), we will notify users and provide instructions on how to proceed if they wish to exercise their rights.

c. Effects of Changes on Provided Services

Changes to the Privacy Policy may have various effects on our services, including:

Changes to User Experience
- Example: If our cookie collection practices are modified, this may affect the personalization of our website and the content you see.
Consent Options and Right to Withdraw Consent
- Example: If we start sharing data with a new advertising partner, users will have the option to give explicit consent or withdraw previously given consent.
Service Access Restrictions
- Example: If you do not accept the new terms of the policy, you may not be able to continue using certain features of our services that depend on the processing of personal data under those terms.

d. Notification Tracking

The Lead Partner keeps a record of notifications sent to users to ensure that every change to the policy has been communicated correctly and in a timely manner.

Confirmation of Email Reading: A confirmation of reading will be requested for notifications sent by email. Users who do not respond will receive an additional reminder.
Handling Questions or Concerns: We will provide a specific channel to respond to any questions regarding the changes. Users can contact our Privacy Officer at privacy@theleadpartner.com to clarify any doubts.

e. Period for User Review and Action

Prior Notice: We will notify users of any important changes to the policy at least 30 days before the changes take effect.
Right to Cancel Account: Users will have the option to cancel their account if they do not agree with the changes to the policy. The Lead Partner will not impose any charges for account cancellation for this reason.

Transparency and Accountability

The Lead Partner is committed to being transparent in all its communications and ensuring that users are fully informed about changes in the handling of their data. Notification of significant changes is made to foster trust and ensure compliance with regulatory obligations.

9. Use of Collected Information

The Lead Partner collects personal information from its users for multiple purposes related to the provision and improvement of our services. Below, we detail how this data is used, including internal studies and the development of improvements to our offerings.

Use of Collected Information at The Lead Partner

We collect personal data to ensure a quality experience and to continuously improve our services. This data is used for various purposes, detailed below, with specific examples for each use.

a. Service Provision

We use personal data to provide the services requested by users, such as:

Lead Generation and Automated Marketing
- Example: We use contact and preference data to manage lead generation and automated marketing campaigns, ensuring that qualified leads are connected with the clients who require these services.
Customer Support
- Example: We store and use contact information to respond to support questions, resolve technical issues, and provide assistance related to the contracted service.

b. Service Improvement and Personalization

Personalization of User Experience
- Example: We use interaction data to display relevant and personalized content, such as ads and offers that match the user’s preferences.
Content Adaptation and Navigation Experience
- Example: If a user frequently visits a specific service page, we use that information to offer faster navigation to that content on future visits.

c. Data Analysis and Internal Audits

Service Performance Analysis
- Example: We collect data on the frequency and duration of service use to analyze its effectiveness and improve overall quality. This data is also used to identify bottlenecks in system use and areas needing performance improvement.
User Satisfaction Evaluation
- Example: We send surveys and collect data on user satisfaction. The results are analyzed internally to identify areas where users feel our services need improvement or adjustment.

d. Internal Studies and Development of New Features

Internal Studies on User Behavior
- We use collected data to conduct internal studies on user behavior. These studies allow us to:
  - Identify Usage Patterns: For example, if we notice a significant number of users abandoning a process at a specific stage, we take action to improve the experience at that particular stage.
  - Example of Use: If internal studies reveal that many users are interested in the same type of advertising campaigns, we can enhance those specific areas to make them more effective and attractive.
Service Optimization and Development of New Features
- Example: From the analysis of user behavior on our platform, we identify the need to include a new module for customized reports. These internal studies provide the foundation for developing new features that better align with customer expectations.

e. Beta Testing and Validation of New Features

Testing New Features
- We use the data collected during beta tests of new features to evaluate the effectiveness of these features before launching them widely.
- Example: When introducing a new tool for generating automated reports, we invite some users to test the tool in a beta phase and collect their feedback. We use this feedback to adjust the tool before the general launch.
Product Impact Evaluation
- We analyze data during testing phases to identify any issues or areas for improvement that can help deliver a better version of the service to the end user.
- Example: If we discover during beta testing that users are having difficulties using a new feature, we collect usage data to identify the cause and apply improvements before its full release.

f. Security and Fraud Prevention

Identification and Prevention of Fraudulent Activities
- Example: We use browsing data, IP addresses, and behavior patterns to identify and prevent fraud attempts or unauthorized access. This includes automatic alerts when suspicious activities are detected.
Identity Verification
- Example: We use personal information, such as email addresses and phone numbers, to conduct identity verification to ensure that users accessing certain services are who they claim to be.

g. Communications and Marketing

Sending Newsletters and Offers
- Example: We use email addresses to send information about our products, services, and special offers, always with the user’s explicit consent.
Personalized Advertising
- Example: Based on the user’s browsing history and preferences, we may display personalized ads within our platform or on third-party websites.

h. Research and Development for Service Improvement

Optimization of Lead Matching Algorithm
- Example: We use the results of previous campaigns and the performance of generated leads to adjust and optimize our matching algorithms, with the aim of improving the quality of leads provided to our clients.
Development of New Tools for Users
- Example: We analyze how users interact with current features, and from these analyses, we develop new tools that may be useful for improving customer productivity and satisfaction.

i. Compliance with Legal and Contractual Obligations

We use personal data to comply with our legal and contractual obligations, such as internal audits and compliance requirements.

Example: We retain financial data for 7 years to comply with our tax and accounting obligations.

j. Examples of How Internal Studies Contribute to Service Improvement

Improvements Based on Customer Feedback
- Based on internal surveys and satisfaction studies, we have improved the user interface to facilitate access to performance reports.
Optimization of Automated Campaigns
- By analyzing user behavior in automated marketing campaigns, we adjusted the sending times and email content to improve open and conversion rates.

Transparency and Limited Purpose

We use the data collected solely for the purposes described above and not for other purposes without the user’s explicit consent. We are committed to ensuring transparency regarding how personal information is used, and we offer users the option to opt out of certain types of use.

10. General Overview and Consolidation of the Privacy Policy

At The Lead Partner, we are committed to protecting our users’ privacy by applying the highest standards of security and transparency. We have developed a robust privacy policy that details all aspects related to the processing of personal data, from collection to deletion, including international transfers and users’ rights in each region.

The Lead Partner Privacy Policy

At The Lead Partner, the privacy and security of your data are fundamental to us. This Privacy Policy describes how we collect, use, share, and protect the personal information we obtain from you. It also explains the rights you have over your information and how you can exercise them.

1. Data Controller vs. Data Processor

The Lead Partner acts both as a data controller and a data processor, depending on the service you are using. As a controller, we decide the purpose and means of data processing, for example, when managing our marketing campaigns. As a processor, we follow the instructions of our clients to handle lead generation data. In both cases, we ensure the protection of the data by implementing strict security measures and complying with applicable regulations.

2. Data Retention

We retain personal data only for the time necessary to fulfill the purposes for which it was collected:

Non-qualified leads are retained for a maximum of 6 months.
Qualified leads and customer data are kept for the duration of the contractual relationship and an additional 12 months.
Financial data is retained for 7 years to comply with tax and accounting regulations.

At the end of the retention period, data will be deleted or anonymized securely.

3. International Data Transfers

We may transfer personal data to other countries, including the United States and countries within the EEA. We use protection mechanisms such as Standard Contractual Clauses (SCCs) and the EU-U.S. Data Privacy Framework to ensure that the data is protected during the transfer. Additionally, we conduct Transfer Impact Assessments (TIAs) to evaluate the risks and ensure an adequate level of protection.

4. User Rights by Region

Users have different rights depending on the region where they reside:

Users in the EU, United Kingdom, and Switzerland have rights such as access, rectification, deletion, and data portability, in accordance with the GDPR.
Users in Brazil can access, correct, delete, or request the anonymization of data under the LGPD.
Users in California have specific rights under the CCPA, such as knowing what data we collect and opting out of the sale of personal data.

We provide a contact channel at privacy@theleadpartner.com to enable users to exercise their rights easily.

5. Cookies and Tracking Technologies

We use cookies and tracking technologies to improve the user experience and provide personalized services. These include:

Essential Cookies, necessary for the website’s operation.
Performance and Advertising Cookies, to personalize content and measure the impact of our campaigns.

We provide a Cookie Preferences Center where you can manage the use of these technologies, and a separate Cookie Policy for greater clarity.

6. Information Security

We have implemented technical and organizational measures to protect personal information:

SSL/TLS Encryption to protect data in transit.
Multi-Factor Authentication (MFA) and Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to the data.
Penetration Testing and Security Audits are regularly conducted to identify and address potential vulnerabilities.

We have an Incident Response Plan to ensure a quick response in the event of a security breach.

7. Dispute Resolution and Arbitration

In case of a dispute regarding privacy or data processing, we recommend contacting us directly at privacy@theleadpartner.com. We offer different resolution mechanisms depending on the region, including arbitration with JAMS for users in the EU and U.S., and the possibility of lodging complaints with local data protection authorities.

We also provide the option to opt out of the arbitration process, which can be exercised within 30 days of accepting this policy.

8. Change Notifications

We will notify you of any significant changes to this Privacy Policy at least 30 days in advance. We will use:

Direct email for registered users.
Website banners to indicate updates and request user confirmation of having read the changes.

If you do not accept the changes, you can cancel your account without additional cost.

9. Use of Collected Information

We use the collected information for a variety of purposes, including:

Service Provision and Lead Generation.
Service Personalization, to show you relevant content and recommendations.
Analysis and Auditing, to improve our products and services.
Security and Fraud Prevention, ensuring the integrity of our services and compliance with international privacy regulations.