Privacy Policy

# Privacy Policy


Last updated: October 9, 2025


This Privacy Policy explains the policies and procedures of SYNERGY FACTOR INC ("Company," "We," "Us," or "Our") regarding the collection, use, and disclosure of your personal information when you access or use any of our websites, services, applications, tools, or other related offerings (collectively, the "Service"). This policy also informs you of your rights under applicable privacy laws and outlines how we work to protect your privacy.


By using the Service, you agree to the collection and use of information as outlined in this Privacy Policy.


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## Table of Contents


1. [Company and Contact Information](#1-company-and-contact-information)

2. [Types of Information We Collect and How We Use It](#2-types-of-information-we-collect-and-how-we-use-it)

3. [Data Sharing and Disclosure](#3-data-sharing-and-disclosure)

4. [Cookies and Tracking Technologies](#4-cookies-and-tracking-technologies)

5. [User Rights](#5-user-rights)

6. [Data Retention](#6-data-retention)

7. [Security Measures](#7-security-measures)

8. [International Data Transfer](#8-international-data-transfer)

9. [Minors' Data](#9-minors-data)

10. [Marketing and Communication Preferences](#10-marketing-and-communication-preferences)

11. [Policy Updates and Notifications](#11-policy-updates-and-notifications)

12. [Automated Telephone Calls and TCPA Compliance](#12-automated-telephone-calls-and-tcpa-compliance)

13. [Phone Number Verification and Caller ID](#13-phone-number-verification-and-caller-id)

14. [Third-Party Platform Integrations](#14-third-party-platform-integrations)

15. [Communications and Contact Information](#15-communications-and-contact-information)

16. [Multi-Platform Service](#16-multi-platform-service)

17. [AI-Generated Content and Data Processing](#17-ai-generated-content-and-data-processing)

18. [Contact Us](#18-contact-us)


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## 1. Company and Contact Information


Company Name: SYNERGY FACTOR INC

Mailing Address: 407 E AYRE ST, UNIT 1399, WILMINGTON, DE 19804 USA

Website: https://leadwinner.ai and https://app.leadwinner.ai

Contact Email: info@leadwinner.ai


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## 2. Types of Information We Collect and How We Use It


We collect various categories of data from users, which may include:


### 2.1 Personal Data

This includes information that users provide directly through contact forms, registration processes, or any other interaction with our Service. It may include but is not limited to:

- Full name and username

- Email addresses

- Phone numbers (for caller ID verification and business contact)

- Business information (business name, address, services offered)

- Payment information (processed securely through Stripe)

- Account credentials and authentication data

- Profile information and preferences

- Any other information you provide to us through the Service


### 2.2 Lead and Customer Data

Through integrations with third-party platforms, we collect and permanently store:

- Customer inquiries and lead information from Yelp, Thumbtack, and other platforms

- Customer names, phone numbers, email addresses, and physical addresses

- Project details and service requests

- Complete message history and conversation threads between you and your customers

- All communications sent and received through the Service

- Customer availability and scheduling information

- Survey answers and questionnaire responses

- Customer interaction patterns and engagement data

- Any other data related to leads and customers obtained through the Service


### 2.3 Business and Interaction Data from Third-Party APIs

Through integrations like the Yelp API and Thumbtack API, we collect:

- Publicly available business-related data

- Information on user interactions with these businesses

- Business reviews and ratings

- Business operating hours and location data

- Service categories and offerings


### 2.4 Technical and Device Information

We collect data such as:

- IP addresses (IPv4, IPv6, and Cloudflare IP addresses)

- Browser types and versions

- Operating system versions

- Device identifiers and device types

- Screen resolution and device capabilities

- Referring URLs and navigation paths


### 2.5 Behavioral and Usage Data

We may track interactions with our Service, such as:

- Pages visited and features used

- Time spent on each page

- Click patterns and navigation flow

- Search queries within the Service

- Lead response times and engagement metrics

- Feature adoption and usage patterns


### 2.6 Analytics and Advertising Data

Collected through providers such as Google Analytics and other third-party tools:

- User behavior patterns and trends

- Conversion tracking and funnel analysis

- A/B test participation and results

- Campaign performance metrics

- Audience demographics and interests


### 2.7 Marketing and CRM Data

Data collected via integrations with CRM systems, advertising networks, and other marketing tools:

- Email campaign engagement (opens, clicks)

- Marketing attribution data

- Customer lifecycle stage

- Lead source and referral information


### 2.8 Call and Communication Data

When using our automated calling features, we collect and store:

- Call logs (timestamps, duration, status, participants)

- Call recordings of all automated calls (for quality assurance, compliance, training, and business purposes)

- Complete SMS message content and delivery status

- Complete email content and notification engagement

- Consent and opt-out records

- All communications between you, your customers, and through our system

- Call quality metrics and analytics

- Voice data and recordings


### 2.9 Authentication and Security Data

For account security and audit purposes:

- Login timestamps and locations

- Failed authentication attempts

- Password reset requests

- Two-factor authentication data

- Session tokens and cookies

- Security event logs

- Access patterns and anomaly detection data


### 2.10 Additional Data Collection

We may also collect additional types of data including but not limited to:

- Any data generated through your use of the Service

- Metadata associated with your activities

- Aggregated and anonymized usage data

- Performance and diagnostic data

- Error logs and crash reports

- Feature usage statistics

- A/B testing and experimental data

- Any other data necessary for Service operation, improvement, security, legal compliance, or legitimate business purposes


Scope of Collection:

We reserve the right to collect any and all data that is:

- Provided by you directly or indirectly

- Generated through your use of the Service

- Obtained from third-party integrations

- Necessary or useful for Service functionality

- Required for legal compliance or business operations

- Helpful for Service improvement or analytics


### Purpose of Data Collection


Data collected is used to:

- Provide, operate, and maintain the Service

- Process and manage leads from multiple platforms

- Enable automated messaging and calling features

- Facilitate AI-powered customer communication

- Enhance, personalize, and improve user experiences within the Service

- Communicate with users to send notifications, updates, promotional offers, and news

- Analyze usage trends and perform general Service-related analytics

- Manage our marketing and advertising efforts through targeted messaging

- Ensure security, prevent fraud, and enforce our Terms of Service

- Comply with legal obligations and resolve disputes

- Provide customer support and technical assistance

- Train and improve AI models and algorithms

- Develop new features and products

- Conduct research and analysis

- Any other legitimate business purpose

- Any purpose disclosed at the time of collection

- Any purpose consistent with these uses


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## 3. Data Sharing and Disclosure


We may share user data with:


### 3.1 Service Providers and Processors

We may share your data with service providers and processors including but not limited to:

- Telephony providers: For SMS messaging and voice calling services

- AI providers: For AI-powered content generation

- Payment processors: For payment processing

- Analytics providers: For usage tracking and behavior analysis

- Email service providers: For transactional and marketing emails

- Cloud hosting providers: For infrastructure and storage

- CRM systems: For customer relationship management

- Monitoring and logging services: For system performance and security

- Data analytics firms: For business intelligence and insights

- Marketing platforms: For advertising and customer engagement

- Any other third parties necessary for Service operation or business purposes


Broad Sharing Rights:

We reserve the right to share data with any third party when:

- Necessary for Service functionality

- Useful for Service improvement

- Required for legal compliance

- Beneficial for legitimate business purposes

- At our discretion for operational needs


### 3.2 Third-Party API Integrations

Through API integrations like Yelp's, Thumbtack's, OpenAI's, and others, we may:

- Access business data and limited user interaction data

- Support lead response services and improve user experience

- Sync data bidirectionally between platforms

- Share automated responses generated by our Service


### 3.3 Legal and Compliance Sharing

We may disclose data when required by law or to:

- Comply with legal processes, subpoenas, or court orders

- Enforce our Terms of Service or investigate violations

- Protect the rights, property, or safety of our company, users, or public

- Respond to government requests or regulatory inquiries

- Defend against legal claims or litigation


### 3.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets:

- User data may be transferred to the acquiring entity

- You will be notified via email and/or prominent notice on our website

- Your data will remain subject to this Privacy Policy unless you consent to a new policy


### 3.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably identify individual users:

- For research and analytics purposes

- To improve AI models and Service functionality

- For marketing and business development

- With partners, investors, and the public

- For sale or licensing to third parties

- For any commercial or business purpose


What Constitutes Anonymous Data:

- Data is considered anonymous if it cannot reasonably identify you

- We determine what constitutes "anonymous" at our discretion

- Once anonymized, data is no longer subject to this Privacy Policy

- We may use and share anonymous data without restriction


### 3.6 Business Analytics and Intelligence

We may use and share your data (including personal data) for:

- Internal business analytics and reporting

- Market research and competitive analysis

- Product development and feature planning

- Training our staff and AI systems

- Demonstrating product capabilities to prospective customers (may include actual data in anonymized form)

- Creating case studies or success stories (with anonymization)

- Benchmarking and industry analysis

- Any other internal or external business purpose


### 3.7 With Your Consent or As Permitted by Law

We may share data with third parties:

- When you explicitly consent to such sharing

- As otherwise permitted or required by applicable law

- In any manner consistent with this Privacy Policy

- For any purpose disclosed at the time of collection

- For any legitimate business interest


### 3.8 Unrestricted Use Rights

By using the Service, you grant us broad rights to use and share your data:


We may:

- Use your data for any lawful business purpose

- Share data as described in this Privacy Policy or as otherwise permitted by law

- Modify how we use or share data by updating this Privacy Policy at any time

- Make business decisions about data usage at our sole discretion

- Combine data from multiple sources about you

- Create derivative works or analyses from your data

- Use data to develop new products or services


Data Usage Flexibility:

We reserve maximum flexibility in how we use data, limited only by:

- Applicable legal requirements

- This Privacy Policy (which we may update at any time)

- Our legitimate business interests


Important Note: Our Service does not process payment card data directly; all payment transactions are managed by secure third-party payment processors like Stripe. If users choose to authenticate through platforms such as Google or Facebook, we collect information made available by those platforms, which may include names, email addresses, profile pictures, and other data you authorize.


INTELLECTUAL PROPERTY PROTECTION:

- ALL data processing methods, algorithms, and techniques remain our exclusive intellectual property

- NO rights to our proprietary data processing methods are transferred to users

- ANY reverse engineering or analysis of our data handling constitutes infringement

- Our intellectual property rights extend to all aspects of data collection and processing


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## 4. Cookies and Tracking Technologies


We use cookies, pixels, and similar tracking technologies to improve user experiences and the effectiveness of our Service.


### 4.1 Types of Cookies Used


Session Cookies:

- Store temporary information during individual user sessions

- Deleted when you close your browser

- Essential for Service functionality


Persistent Cookies:

- Save user preferences, such as language settings and login state

- Remain on your device for a set period or until manually deleted

- Enhance future visits and user experience


Third-Party Cookies and Pixels:

- Used for analytics, advertising, fraud prevention, and tracking interactions

- Placed by services like Google Analytics, Facebook Pixel

- May track you across multiple websites


### 4.2 How We Use Tracking Technologies


Tracking technologies help us:

- Authenticate users and maintain sessions

- Remember user preferences and settings

- Analyze traffic and usage patterns

- Improve Service performance and features

- Detect and prevent fraud

- Deliver targeted advertising

- Measure marketing campaign effectiveness


### 4.3 Your Cookie Choices


Users can adjust their browser settings to:

- Block all cookies

- Accept only first-party cookies

- Receive notifications when cookies are set

- Delete existing cookies


Note: Blocking cookies may limit Service functionality and prevent access to certain features.


### 4.4 Do Not Track Signals


Some browsers transmit "Do Not Track" signals. Currently, we do not respond to these signals, as there is no industry standard for how to interpret them.


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## 5. User Rights


Depending on applicable law (such as GDPR, CCPA), users may have the following rights concerning their data:


### 5.1 Access and Deletion


Right to Access: You can request access to your personal data by contacting us at info@leadwinner.ai


Right to Deletion (with Important Limitations):

You can request deletion of your personal data, HOWEVER:

- We are NOT REQUIRED to delete data if:

- Needed for legal compliance, regulatory requirements, or legal proceedings

- Necessary for fraud prevention or security purposes

- Required for enforcing our Terms of Service or resolving disputes

- Part of backups or disaster recovery systems (may persist for extended periods)

- Needed for legitimate business purposes

- Already anonymized or aggregated (no longer personal data)

- Subject to legal holds or preservation obligations

- Some data is permanently retained (consent logs, verification logs, security logs, financial records)

- Deletion requests are processed at our discretion within legal requirements

- We may refuse deletion if legally permitted


Data Portability:

- You may request an electronic copy of your data in a structured format

- We will provide data at our discretion and may charge reasonable fees

- Some data may be excluded for technical, security, or legal reasons

- Format and completeness at our discretion


### 5.2 Restriction of Processing and Right to Object

- You may have the right to limit or object to certain processing activities

- Particularly concerning direct marketing or advertising

- You can opt out of marketing communications at any time


### 5.3 Correction and Update

- You can update your personal information through your account settings

- You can request corrections to inaccurate data


### 5.4 Withdrawal of Consent

- Where processing is based on consent, you may withdraw consent at any time

- Withdrawal does not affect the lawfulness of processing prior to withdrawal


### 5.5 Complaint to Supervisory Authority

- You have the right to lodge a complaint with a data protection authority

- Particularly in the EU member state of your residence or workplace


### 5.6 Automated Decision-Making

- You may object to decisions based solely on automated processing, including profiling

- This includes AI-generated responses that significantly affect you


How to Exercise Your Rights:

- Email: info@leadwinner.ai

- Subject Line: "Data Privacy Request"

- Include: Your account email, specific request, and any relevant details

- Response Time: We will respond within 30 days (or as required by applicable law)

- We may require identity verification before processing requests

- We may charge reasonable fees for excessive, repetitive, or unfounded requests


IMPORTANT: For ALL privacy-related issues, requests, or concerns, you MUST contact us at info@leadwinner.ai. We are NOT RESPONSIBLE for privacy issues not reported through official channels. Failure to contact us through the proper channel may result in denial of your request.


NO GUARANTEE OF RESPONSE:

- We have NO OBLIGATION to respond to all inquiries

- Response times are NOT GUARANTEED beyond legal requirements

- We may NOT RESPOND to repetitive, abusive, or unclear requests

- We are NOT LIABLE for:

- Delayed responses or no response

- Emails lost in transmission or blocked by spam filters

- Failure to respond due to technical issues

- Missed inquiries or communications

- Any consequences of delayed or no response


Important Limitations:

These rights may vary based on jurisdiction and applicable data protection laws. Certain requests may be denied or limited if:

- Not required by applicable law in your jurisdiction

- Prohibited or restricted by law

- Would compromise others' privacy or security

- Would reveal trade secrets or proprietary information

- Conflict with legal obligations or legitimate business interests

- Are technically infeasible or excessively burdensome

- Data has already been anonymized or deleted


We reserve the right to:

- Determine which data is subject to deletion

- Refuse requests that don't comply with applicable law

- Charge fees for processing requests

- Extend response times if legally permitted

- Request additional information to verify your identity

- IGNORE requests sent through unauthorized channels

- REFUSE to respond to repetitive or abusive communications

- NOT RESPOND to every inquiry (at our discretion)


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## 6. Data Retention


We retain user data only for as long as necessary to fulfill the purposes described in this Privacy Policy or as otherwise required by law.


### 6.1 Retention Periods by Data Type


Account Data:

- Retained while your account is active

- May be retained up to 90 days after account closure or longer as needed for business operations


Lead and Customer Data:

- Retained as long as necessary for business purposes, legal compliance, or legitimate interests

- May be retained longer if required for legal or contractual obligations


Call and Communication Logs:

- Retained for as long as necessary for legal compliance, regulatory requirements, or business purposes

- Call recordings retained for up to 2 years or longer if needed


Consent and Opt-Out Records:

- Retained indefinitely or for as long as required for TCPA compliance, legal protection, and business purposes

- Required to demonstrate compliance with telecommunications laws and regulations


Phone Verification Logs:

- Retained indefinitely or for as long as necessary for fraud prevention, ownership verification, legal compliance, and security purposes

- Critical for security, dispute resolution, and regulatory compliance


Security and Audit Logs:

- Retained for as long as necessary for security, compliance, fraud prevention, and business purposes

- May be retained indefinitely if involved in legal proceedings or regulatory matters


Financial and Payment Data:

- Retained for as long as necessary to comply with tax, accounting, and financial regulations

- Payment card data is NOT stored by us (securely handled by Stripe)


### 6.2 Extended Retention


Data may be stored for extended periods as needed for:

- Compliance with legal, tax, and accounting requirements

- Fraud prevention and detection

- Legal obligations and preservation for litigation

- Legitimate business purposes (backups, disaster recovery)

- Resolving disputes and enforcing agreements


### 6.3 Data Deletion


Upon request or at the end of retention periods:

- Data is securely deleted or anonymized

- Backups may retain data for up to 90 additional days

- Some data may be retained in anonymized form indefinitely


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## 7. Security Measures


We implement commercially reasonable physical, technical, and administrative measures to protect user data.


### 7.1 Technical Security Measures


We implement commercially reasonable security measures, which may include:


Encryption:

- Data in transit may be encrypted using TLS/SSL

- Some sensitive data may be encrypted at rest

- Database encryption for certain critical information


Access Controls:

- Role-based access control (RBAC) where feasible

- Authentication systems for access management

- Access logging and monitoring


Network Security:

- Firewalls and security systems

- DDoS protection measures

- Security monitoring where implemented


IMPORTANT LIMITATIONS:

- Security measures are NOT GUARANTEED to prevent all breaches

- We implement measures at our discretion and may modify them at any time

- No security system is completely secure

- We make no warranties about the effectiveness of security measures


### 7.2 Operational Security Measures


Regular Security Practices (at our discretion):

- Data backups as deemed necessary

- Security patch management when feasible

- Security assessments when appropriate

- Incident response procedures


Employee and Contractor Policies:

- Security awareness for staff (at our discretion)

- Confidentiality agreements where appropriate

- Access controls for personnel


IMPORTANT: These are general practices, not guarantees. We may modify, suspend, or discontinue any security practice at any time.


### 7.3 Third-Party Security


We require service providers to:

- Implement appropriate security measures

- Sign data processing agreements

- Comply with applicable privacy laws

- Notify us of security incidents


### 7.4 Limitations and Disclaimers


CRITICAL SECURITY DISCLAIMERS:


No Security Guarantees:

- We DO NOT GUARANTEE data security

- Security measures are provided "AS-IS" without warranties

- We CANNOT prevent all security incidents

- Data breaches, hacks, and unauthorized access MAY OCCUR


Your Acceptance of Risk:

By using the Service, you acknowledge and accept that:

- Data transmission over the internet has inherent and unavoidable risks

- Security incidents may result in data loss, theft, or exposure

- We have LIMITED LIABILITY for security failures

- YOU ASSUME ALL RISK of data security issues


User Responsibilities:

Users are SOLELY RESPONSIBLE for:

- Maintaining account security and password confidentiality

- Using strong passwords and security practices

- Monitoring account for unauthorized activity

- Immediately reporting suspected security issues

- Backing up all critical data (we are not a backup service)


In Case of Breach:

- We will notify affected users only as required by applicable law

- We will take commercially reasonable steps to mitigate harm (no guarantee of success)

- We may cooperate with law enforcement at our discretion

- We have NO OBLIGATION to:

- Investigate the breach beyond legal requirements

- Compensate affected users

- Provide credit monitoring or identity theft protection

- Restore lost or compromised data


Liability Limitation:

Our maximum liability for any security incident is limited as set forth in our Terms of Service (Section 23: lesser of $500 or 12-month payments).


Data Loss from Security Incidents:

- We have NO LIABILITY for data loss due to security breaches

- We have NO OBLIGATION to recover compromised data

- YOU WAIVE ALL CLAIMS against us arising from security incidents (subject to applicable law)


Contact Requirements for Security Issues:

- ALL security concerns MUST be reported to info@leadwinner.ai

- We are NOT RESPONSIBLE for unreported security issues

- NO OTHER REPORTING CHANNELS are authorized or monitored

- We may NOT RESPOND to security reports through unauthorized channels


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## 8. International Data Transfer


Our primary servers are located in California, USA, but user data may be processed, transferred, and stored in jurisdictions outside the United States as necessary for our operations.


### 8.1 Data Transfer Mechanisms


When transferring data internationally, we apply:

- Standard Contractual Clauses (SCCs) approved by the EU Commission

- Data processing agreements with service providers

- Compliance with the EU General Data Protection Regulation (GDPR) where applicable

- Privacy Shield principles (where applicable and valid)

- Other lawful transfer mechanisms as available


### 8.2 Countries Where Data May Be Processed


Data may be transferred to and processed in:

- United States (primary location)

- Countries where our service providers operate

- Countries where third-party platforms (Yelp, Thumbtack, Twilio, etc.) have infrastructure


### 8.3 Your Rights Regarding International Transfers


If you are located in the European Economic Area (EEA), UK, or Switzerland:

- You have the right to obtain information about safeguards we use for international transfers

- You may request copies of relevant data transfer agreements

- You may object to transfers in certain circumstances


### 8.4 Data Protection Standards


Regardless of where data is processed:

- We maintain consistent data protection standards

- We require service providers to protect data adequately

- We comply with applicable local data protection laws


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## 9. Minors' Data


Our Service is designed for users aged 18 and older and is not intended for minors.


### 9.1 Age Restriction


- We do not knowingly collect information from children under 18

- Users must be at least 18 years old to create an account

- We do not market to or target minors


### 9.2 Parental Notice


If we become aware that a minor has provided us with personal information:

- We will take immediate steps to delete such information

- We will terminate the associated account

- We will not use or share the information


### 9.3 Parental Rights


Parents or guardians who believe their child may have provided us with personal information should:

- Contact us immediately at info@leadwinner.ai

- Provide proof of guardianship

- Specify what information should be removed


We will respond promptly to ensure removal of such data.


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## 10. Marketing and Communication Preferences


We may send users marketing and promotional communications as permitted by applicable law.


### 10.1 Types of Marketing Communications


Promotional Emails:

- New feature announcements

- Special offers and discounts

- Product updates and enhancements

- Educational content and best practices

- Newsletters and industry insights


SMS Marketing:

- Time-sensitive promotions

- Feature updates

- Service notifications


### 10.2 Opt-Out Options


Users can opt out of marketing communications at any time by:

- Clicking "unsubscribe" in email communications

- Replying "STOP" to SMS messages

- Adjusting email preferences in account settings

- Contacting us directly at info@leadwinner.ai


### 10.3 Transactional Communications


You cannot opt out of essential communications related to:

- Account security and authentication

- Service status and system notifications

- Billing and payment confirmations

- Lead alerts and customer inquiries (while service is active)

- Terms of Service or Privacy Policy updates

- Legal notices and compliance requirements


These communications are necessary for Service operation and your account management.


### 10.4 Communication Preferences


You may customize:

- Email notification frequency

- Types of notifications received

- Notification methods (email, SMS, in-app)

- Marketing communication preferences


Access these settings in your account dashboard.


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## 11. Policy Updates and Notifications


We may periodically update this Privacy Policy to reflect changes in our practices, legal requirements, or other operational needs.


### 11.1 How We Notify You of Changes


Material Changes:

- Posted on our website with updated "Last updated" date

- Email notification to registered users

- In-app notification upon next login

- Prominent banner on the Service for 30 days


Non-Material Changes:

- Updated "Last updated" date on this page

- No direct notification (users should review periodically)


### 11.2 Your Acceptance of Changes


- Continued use of the Service after notice constitutes acceptance of updated terms

- If you do not agree with changes, you should discontinue use and close your account

- For material changes, we may require explicit consent before they take effect


### 11.3 Version History


We maintain a version history of this Privacy Policy. You may request:

- Previous versions of this policy

- Summary of changes between versions

- Explanation of significant modifications


Contact info@leadwinner.ai for version history requests.


### 11.4 Email Delivery and Communication Disclaimers


CRITICAL: WE ARE NOT LIABLE FOR EMAIL OR COMMUNICATION DELIVERY FAILURES.


You acknowledge and agree that:

- We are NOT RESPONSIBLE for:

- Emails blocked by spam filters or firewalls

- Emails not delivered due to incorrect email addresses

- Emails lost in transmission

- Delays in email delivery

- Technical issues with email providers

- Your failure to check email or notifications

- Your failure to maintain current contact information

- Sending an email or notification constitutes delivery regardless of whether you receive or read it

- Posting to your account dashboard constitutes notice regardless of whether you log in

- We have NO OBLIGATION to confirm receipt of our communications

- We have NO OBLIGATION to resend communications that fail to deliver

- You assume all risk of not receiving our communications


Your Responsibility:

- YOU MUST keep your email address and contact information current

- YOU MUST check your email regularly (including spam/junk folders)

- YOU MUST check your account dashboard for notices

- YOU MUST whitelist our email addresses to ensure delivery

- Failure to receive communications does NOT excuse you from complying with our policies


Contact Us for Delivery Issues:

- If you believe you are not receiving communications, contact info@leadwinner.ai immediately

- We are NOT LIABLE for issues you don't report

- Reporting does NOT create an obligation on our part to resolve the issue

- We may NOT RESPOND to every communication issue reported


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## 12. Automated Telephone Calls and TCPA Compliance


Our Service includes an automated telephone dialing and calling system. This section explains your rights and our practices regarding automated calls.


### 12.1 Automated Calling System


Our Service provides functionality that:

- Places automated calls to businesses on behalf of potential customers

- Uses artificial intelligence (AI) to generate call scripts and messages

- Connects businesses with customers through conference calling

- Records and logs all call activities, including consent events

- Enables caller ID verification for outbound calls


### 12.2 Consent Requirements and Opt-Out Rights


Prior Express Written Consent:

By enabling the automated calling feature and providing a phone number in your business settings, you provide your prior express written consent to receive automated calls from our system at the phone number you provide.


Scope of Consent:

Your consent:

- Applies globally to the specific phone number provided (not limited to one business account)

- Is not a condition of purchase or use of other Service features

- Covers calls made using automated telephone dialing systems and/or artificial or prerecorded voice messages

- Applies regardless of which business account in our system the number is associated with

- Includes receiving SMS/text messages related to leads and Service functionality


What You're Consenting To:

You will receive automated calls when:

- A new lead inquiry is received from a connected platform

- The automated calling feature is enabled for your business

- A potential customer requests to speak with your business


Opt-Out Methods:

You may revoke consent and opt-out at any time by:


1. During a call: Press 9 during any automated call to immediately opt-out globally

2. Web interface: Disable auto-calling in your business settings at app.leadwinner.ai/dashboard

3. Email: Contact info@leadwinner.ai with subject "TCPA OPT-OUT" including your phone number

4. Support: Contact our support team through available channels


Effect of Opt-Out:

- Opt-out is IMMEDIATE and takes effect within minutes

- Opt-out applies GLOBALLY to the phone number across our entire system

- The phone number will be permanently blocked from receiving automated calls

- Opt-out applies regardless of which user account registered the number

- You may opt back in at any time through the web interface

- Opt-out does not affect your ability to use other Service features


Consent Records and Audit Trail:

We maintain comprehensive logs of all consent and opt-out events, including:

- Timestamp of consent/opt-out action

- Method of consent/opt-out (web settings, DTMF keypress "9", manual admin)

- IP address (IPv4, IPv6, Cloudflare IP) and user agent for web-based actions

- Call SID and related call metadata for phone-based actions

- Terms of Service version accepted at time of consent

- User and business associated with the action

- Complete audit trail for regulatory compliance


These records are retained indefinitely to demonstrate TCPA compliance.


### 12.3 Call Recording and Monitoring


We may record and monitor automated calls for:

- Quality assurance and service improvement

- Training AI models and improving automation

- Legal compliance and TCPA documentation

- Dispute resolution and customer service

- Fraud prevention and security


By using the automated calling feature:

- You consent to such recording

- You acknowledge that all parties on calls will be recorded

- You understand recordings may be retained for up to 2 years


Access to Recordings:

- You may request copies of call recordings involving your number

- Requests should be sent to info@leadwinner.ai

- We may charge reasonable fees for extensive retrieval requests


### 12.4 Your Responsibilities Regarding TCPA


Important: While we provide tools for managing YOUR consent to receive calls from OUR system, YOU are independently responsible for:

- Obtaining proper consent from YOUR customers before contacting them

- Maintaining YOUR own Do-Not-Call compliance

- Following TCPA regulations when YOU initiate calls to customers

- Using our Service in compliance with all telecommunications laws


We are NOT responsible for YOUR TCPA violations when YOU contact YOUR customers.


### 12.5 Frequency and Timing of Calls


Call Frequency:

- You will receive one automated call per new lead inquiry (if auto-calling is enabled)

- Frequency depends on how many leads you receive

- No predetermined limit on number of calls per day/week


Call Timing:

- Calls are typically made immediately upon lead receipt

- Calls are generally made during business hours (8 AM - 9 PM local time)

- No calls will be made to your number if you have opted out


Standard Carrier Rates:

- Standard voice call rates from your carrier may apply

- We are not responsible for carrier charges

- Contact your mobile carrier for rate information


### 12.6 Contact Information for TCPA Requests


For any TCPA-related inquiries, opt-out requests, or to obtain records of your consent:


Email: info@leadwinner.ai

Subject Line: "TCPA Request" or "TCPA OPT-OUT"

Mailing Address: SYNERGY FACTOR INC, 407 E AYRE ST, UNIT 1399, WILMINGTON, DE 19804 USA


Include in your request:

- Your full name and account email

- Phone number(s) you want to opt out

- Specific request (opt-out, consent records, call history, etc.)


Response Time: We will respond to TCPA opt-out requests within two (2) business days. Other TCPA-related requests will be processed within ten (10) business days. Business days exclude weekends and federal holidays.


---


## 13. Phone Number Verification and Caller ID


To use certain features (such as automated calling with your caller ID displayed to customers), you must verify ownership of phone numbers.


### 13.1 Verification Process


How Verification Works:

- You initiate verification through the Service interface

- Our telecommunications provider (Twilio) calls the phone number

- You answer and enter a validation code spoken during the call

- Verification is confirmed in real-time


Requirements:

- Only US and Canada phone numbers (+1 country code) are supported

- You must have physical access to the phone to receive the verification call

- The phone number must not already be verified by another user


### 13.2 Verification Data Collection


During phone verification, we collect and permanently log:

- Phone number being verified (in E.164 international format)

- IP address (IPv4 and/or IPv6) of the device initiating verification

- Cloudflare IP address (if applicable for routing)

- User agent string and browser information

- Timestamp of verification attempt

- Twilio verification SID and call SID

- Success or failure status of verification

- Terms of Service version accepted at time of verification

- Geographic location (based on IP address)

- Device fingerprint data (where available)


Critical Requirement: Verification logs MUST include IP address and user agent. Verification will NOT be completed if this data is unavailable.


### 13.3 Purpose of Verification Logging


We maintain these detailed logs indefinitely to:

- Prevent phone number fraud and unauthorized use

- Prove ownership in disputes between users

- Comply with telecommunications regulations (TCPA, TSR)

- Provide evidence in legal proceedings if necessary

- Prevent abuse of our calling systems

- Detect patterns of fraudulent activity

- Support law enforcement investigations when legally required


### 13.4 Phone Number Ownership and Security


Ownership Rules:

- Once verified, a phone number is tied exclusively to your user account

- You cannot verify a phone number already verified by another user

- Only the verifying user can use that caller ID for automated calls

- Phone numbers cannot be transferred between accounts without contacting support

- Attempting to verify another user's number is prohibited and may result in account termination


If Ownership Dispute Occurs:

- Contact info@leadwinner.ai with subject "Phone Verification Dispute"

- Provide proof of phone ownership (carrier bill, account screenshot)

- Include verification logs and relevant account information

- We will investigate using IP logs and verification history

- Resolution may take 5-10 business days


Security Measures:

- Rate limits prevent verification abuse (max 3 attempts per minute, 20 per day)

- Multiple failed attempts from same IP are flagged

- Suspicious patterns trigger manual review

- Compromised accounts are immediately suspended


### 13.5 Data Retention for Verification Logs


Extended Retention:

Phone verification logs are retained for as long as necessary for legal compliance, fraud prevention, security, and business purposes, and may NOT be deleted even after:

- Account closure or termination

- Phone number removal from account

- User data deletion requests

- Account inactivity


Why Extended Retention:

- Required for legal compliance and regulatory defense

- Essential for fraud prevention and security investigations

- Necessary to resolve future disputes about phone ownership

- Critical for TCPA compliance documentation and evidence

- May be required in litigation, legal proceedings, or regulatory investigations

- Needed for business operations and risk management


Retention Period:

We retain verification logs indefinitely or for as long as permitted or required by applicable law, whichever is longer.


Data Minimization:

While we retain verification logs indefinitely, we:

- Only collect data necessary for verification and fraud prevention

- Do not share logs except as legally required

- Encrypt sensitive verification data at rest

- Restrict access to authorized personnel only


---


## 14. Third-Party Platform Integrations


Our Service integrates with multiple third-party platforms to provide comprehensive lead management and communication features.


### 14.1 Platforms We Integrate With


Lead Source Platforms:

- Yelp: Business information, customer inquiries, messages, reviews, business profile data

- Thumbtack: Customer requests, project details, phone numbers, negotiations, quotes


Communication and Telephony:

- Twilio: SMS messaging, voice calls, phone verification, call logs, call recordings


AI and Content Generation:

- OpenAI (GPT models): AI message generation, call script creation, conversation automation

- Google Gemini: Alternative AI content generation and response optimization


Productivity and Data:

- Google Services:

- Google Authentication (login/signup)

- Google Calendar (availability checking)

- Google Sheets (dynamic data integration)


Payment Processing:

- Stripe: Payment processing, subscription management, billing


Analytics and Monitoring:

- Google Analytics: Usage tracking, behavior analysis, conversion tracking

- Other analytics providers for performance monitoring


### 14.2 Data Collected from Integrations


Through these integrations, we may access and store:


From Yelp:

- Business profile (name, address, phone, hours, categories)

- Customer inquiry messages and conversation threads

- Lead details (customer name, project description)

- Message timestamps and read status

- Business reviews and ratings (public data)


From Thumbtack:

- Customer project requests and details

- Customer contact information (name, phone, email, location)

- Project quotes and negotiations

- Message history and communication threads

- Service categories and customer preferences


From Twilio:

- SMS message delivery status and timestamps

- Call logs (duration, status, participants)

- Call recordings and transcripts

- Phone number verification status

- Carrier information and routing details


From OpenAI/Google:

- AI-generated message content

- Prompt engineering data and instructions

- Model usage statistics

- API call logs and costs


From Google Services:

- Calendar availability and event summaries (not full event details)

- Spreadsheet data you explicitly connect

- Account email and profile picture (for authentication)


From Stripe:

- Payment transaction records

- Subscription status and plan details

- Billing history and invoices

- Payment method type (NOT full card numbers)


### 14.3 How We Use Integrated Data


Integrated data is used to:

- Display leads in unified dashboard

- Enable AI-powered automated responses

- Facilitate automated calling to your business

- Sync calendar availability for customer scheduling

- Process payments and manage subscriptions

- Send notifications about new leads

- Generate analytics and usage reports

- Improve Service functionality and AI models


### 14.4 Data Sharing with Integrated Platforms


We may share data back to integrated platforms:

- Yelp/Thumbtack: AI-generated responses to customer inquiries

- Twilio: Phone numbers and message content for delivery

- OpenAI/Google: Message context and business prompts for AI generation

- Stripe: Payment information for transaction processing


We do NOT share:

- Your data with platforms you haven't connected

- Customer data across different lead source platforms

- Sensitive data beyond what's necessary for Service operation


### 14.5 Your Responsibilities


By connecting third-party platforms, you:

- Grant us permission to access data from those platforms on your behalf

- Represent that you have legal authority to share customer data collected through those platforms

- Agree to comply with each platform's terms of service

- Acknowledge that you've obtained necessary consents from customers

- Understand that platform policies may restrict certain data uses


You are responsible for:

- Maintaining active accounts with integrated platforms

- Keeping integrations connected and authorized

- Complying with platform-specific data policies

- Revoking access if you no longer want us to access platform data


### 14.6 Platform Policy Changes and Risks


Important Disclaimers:


Third-party platforms may change their policies at any time, which may affect:

- What data we can access

- How we can use that data

- Service functionality and features

- Our ability to provide certain features


We are NOT responsible for:

- Loss of functionality due to platform API changes

- Data access restrictions imposed by platforms

- Service interruptions caused by platform downtime

- Platform policy violations by you

- Changes to platform terms or pricing

- Platform termination of API access


If a Platform Integration Fails:

- We will attempt to notify you

- Some Service features may become unavailable

- We may need to discontinue support for that platform

- No refunds will be provided for platform-related service disruptions


### 14.7 Disconnecting Integrations


You can disconnect platforms at any time:

- Through your account settings

- By revoking access in the third-party platform

- By contacting our support team


When you disconnect:

- We stop accessing new data from that platform

- Existing data may be retained per our retention policy

- Related Service features will be disabled

- Active leads from that platform will be preserved but not updated


### 14.8 Third-Party Privacy Policies


Each integrated platform has its own privacy policy:

- Yelp Privacy Policy: https://www.yelp.com/tos/privacy_policy

- Thumbtack Privacy Policy: https://www.thumbtack.com/privacy/

- Twilio Privacy Policy: https://www.twilio.com/legal/privacy

- OpenAI Privacy Policy: https://openai.com/policies/privacy-policy

- Google Privacy Policy: https://policies.google.com/privacy

- Stripe Privacy Policy: https://stripe.com/privacy


We recommend reviewing these policies to understand how these platforms handle your data.


---


## 15. Communications and Contact Information


We collect and use contact information to communicate with you about the Service, leads, and our business.


### 15.1 Contact Information We Use


Direct Contact Information:

- Email addresses you provide during registration or in account settings

- Phone numbers you verify for caller ID features

- Business phone numbers you enter for receiving lead calls

- Contact information in your business profile


Integrated Platform Contact Information:

- Phone numbers from your Yelp business account

- Email addresses from your Thumbtack profile

- Contact information displayed on your connected business pages

- Business phone numbers listed on public profiles

- Updated contact details automatically synced from connected platforms


By connecting platforms, you authorize us to:

- Retrieve contact information from those platforms

- Use that contact information for all communication types described here

- Update our records when contact information changes on those platforms


### 15.2 How We Use Contact Information


Contact information is used to send:


Transactional Communications:

- Lead notifications: Alerts when new customers inquire

- Automated call notifications: When our system calls your business about a lead

- Account security: Login alerts, password resets, verification codes

- Service status: System maintenance, outages, feature updates

- Billing notifications: Payment receipts, failed payments, subscription changes

- Support responses: Replies to your support requests


Marketing Communications:

- Promotional offers: Discounts, special deals, upgrade opportunities

- Feature announcements: New features, product updates, enhancements

- Educational content: Best practices, tips, webinars, guides

- Newsletters: Industry insights, case studies, success stories

- Surveys: Feedback requests, satisfaction surveys


Compliance Communications:

- Terms updates: Changes to Terms of Service or Privacy Policy

- Legal notices: Required regulatory notices, TCPA compliance information

- Consent confirmations: Records of your consents and opt-ins


### 15.3 Multi-Channel Communications


Communications may be sent via:

- Email: Primary communication channel for most notifications

- SMS/Text: Urgent lead notifications, verification codes

- Voice calls: Automated calls about new leads (if you enable this feature)

- In-app notifications: Alerts within the Service dashboard

- Push notifications: Browser or mobile app notifications (if enabled)


Communication Frequency:

- Varies based on lead volume, account activity, and your settings

- Lead notifications: Real-time as leads are received

- Marketing: Typically weekly or monthly

- Transactional: As needed for Service operation


### 15.4 Multi-Platform Contact Synchronization


Automatic Updates:

When you connect third-party platforms, we may:

- Automatically retrieve contact information when you first connect

- Periodically sync updated contact information from those platforms

- Use the most recent contact information from any connected platform

- Update stored contact information when platform data changes


Priority of Contact Information:

If contact information differs across sources:

1. Contact information you directly enter in our Service (highest priority)

2. Contact information from most recently connected platform

3. Contact information from initial account registration


Your Responsibilities:

- Ensure contact information is accurate on all connected platforms

- Update your contact preferences in our Service settings

- Notify us if you change phone numbers or email addresses

- Keep business contact information current


### 15.5 Opting Out of Communications


Marketing Communications Opt-Out:

You can opt out of marketing communications by:

- Clicking "Unsubscribe" at the bottom of marketing emails

- Replying "STOP" to marketing SMS messages

- Adjusting notification preferences in account settings

- Emailing info@leadwinner.ai with subject "Opt-Out Marketing"


Transactional Communications (Cannot Opt Out):

You will continue to receive essential communications about:

- Critical security alerts and account issues

- Lead and customer inquiry alerts (while Service is active)

- Billing and payment notifications

- Terms of Service or Privacy Policy changes

- Service outages or critical updates

- Responses to your support requests


Why You Cannot Opt Out of Transactional Communications:

These are necessary for Service operation and your business to function. To stop receiving these communications, you must close your account.


### 15.6 Contact Information Accuracy


You are responsible for:

- Maintaining accurate and current contact information

- Responding to communications sent to your registered contact information

- Notifying us immediately if contact information is incorrect

- Checking spam/junk folders for our communications

- Ensuring we can reach you for critical Service notifications


If Contact Information is Incorrect:

- Update your email/phone in account settings

- Update contact information on connected platforms (Yelp, Thumbtack)

- Contact support if you're locked out and cannot update information


Consequences of Incorrect Contact Information:

- You may miss important lead notifications (lost business opportunities)

- You may not receive critical security alerts

- We may not be able to verify your identity for support requests

- Billing issues may arise if we cannot reach you about payment problems


### 15.7 Third-Party Contact Information


Important: By providing contact information from connected platforms, you represent:

- You are authorized to use that contact information for business purposes

- Contact information is accurate and current

- You have permission to share this information with us

- You will update contact information if it changes


We are NOT responsible for:

- Incorrect contact information from third-party platforms

- Contact information changes that aren't synced from platforms

- Communications sent to outdated contact information

- Deliverability issues caused by carrier or email provider filtering


---


## 16. Multi-Platform Service


Our Service is designed to work with multiple lead generation and productivity platforms.


### 16.1 Supported Platforms


Currently Integrated Lead Sources:

- Yelp: Customer inquiries and business messaging

- Thumbtack: Project requests and quotes


Additional Integrations:

- Google Calendar: Availability checking

- Google Sheets: Dynamic data for AI responses

- Twilio: SMS and voice communication


Future Platform Support:

We may add support for additional platforms such as:

- Angi (formerly Angie's List)

- HomeAdvisor

- Other local service marketplaces


### 16.2 Platform-Agnostic Features


Unified Experience Across Platforms:

- Single dashboard for all leads regardless of source

- Consistent AI-powered auto-reply across all platforms

- Centralized notification system (email, SMS, in-app)

- Unified analytics and reporting

- Single billing for all integrations


Platform-Neutral Data Management:

- Leads from all platforms stored in unified format

- Cross-platform search and filtering

- Consistent lead status tracking

- Unified conversation history


### 16.3 Platform-Specific Differences


Yelp Leads:

- Typically do NOT include customer phone numbers initially

- Customer phone may be shared later if customer opts in

- Messaging is primary communication method

- AI bot focuses on obtaining phone number for follow-up


Thumbtack Leads:

- Typically INCLUDE customer phone numbers immediately

- Project details are more structured and detailed

- Multiple quote/negotiation interactions possible

- AI bot focuses on providing quotes and scheduling


Feature Availability:

- Automated calling only works when customer phone is available

- Some features depend on platform API capabilities

- Response time windows may vary by platform


### 16.4 Multi-Platform Data Consolidation


How We Consolidate Data:

- Customer data from different platforms is kept separate (not merged)

- Each lead maintains its source platform

- Business settings can be configured per-platform or globally

- Notifications aggregate across all platforms


No Cross-Platform Customer Matching:

- We do NOT automatically identify the same customer across platforms

- Each lead is treated independently

- You are responsible for recognizing repeat customers


---


## 17. AI-Generated Content and Data Processing


Our Service uses artificial intelligence to automate customer communications.


### 17.1 AI Systems Used


AI Providers:

- OpenAI (GPT models): Primary AI for message generation

- Google Gemini: Alternative/backup AI for content generation


What AI Does:

- Generates automated responses to customer inquiries

- Creates telephone call scripts

- Drafts follow-up messages

- Suggests responses based on your business prompts


### 17.2 How AI Uses Your Data


Data Provided to AI:

- Customer inquiry content and lead details

- Your business information and custom prompts

- Conversation history with the customer

- Calendar availability (if connected)

- Data from Google Sheets (if connected)

- Your AI settings (tone, response length, instructions)


AI Training:

- Your conversations may be used by AI providers to improve their models

- We may share anonymized data with OpenAI and Google for training purposes

- You can request exclusion from AI training (contact info@leadwinner.ai)


Data Retention by AI Providers:

- OpenAI and Google have their own data retention policies

- Data sent to AI providers is subject to their privacy policies

- We do not control how AI providers use data for model training


### 17.3 AI Content Accuracy and Limitations


Important Disclaimers:

- AI may generate inaccurate, incomplete, or inappropriate content

- AI may misunderstand customer requests or context

- AI may violate platform policies or laws if not properly configured

- AI-generated content may lack human judgment and empathy


No Guarantees:

- We do NOT guarantee accuracy of AI-generated content

- We do NOT guarantee AI content will comply with all laws

- We do NOT guarantee AI will generate appropriate responses

- We are NOT liable for customer complaints about AI interactions


Your Responsibilities:

- Configure AI prompts carefully to guide appropriate responses

- Monitor AI-generated communications regularly

- Disable AI auto-reply if you prefer manual responses

- Ensure AI follows your business policies and legal requirements


### 17.4 Your Control Over AI


Customization Options:

- Write custom business prompts to guide AI behavior

- Set response length, tone, and delay preferences

- Configure what information AI can share (pricing, availability, etc.)

- Enable/disable AI auto-reply per business


Disabling AI:

- You can disable AI auto-reply at any time

- Manual mode requires you to respond to each lead

- Previously generated AI content is retained for record-keeping


---


## 18. Contact Us


For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:


### General Inquiries


Email: info@leadwinner.ai

Website: https://leadwinner.ai

Application: https://app.leadwinner.ai


### Time-Sensitive Requests


TCPA Opt-Out Requests:

- Email: info@leadwinner.ai

- Subject: "TCPA OPT-OUT"

- Response Time: Within 2 business days


Phone Verification Disputes:

- Email: info@leadwinner.ai

- Subject: "Phone Verification Dispute"

- Response Time: Within 5 business days


Data Privacy Requests (Access, Deletion, etc.):

- Email: info@leadwinner.ai

- Subject: "Data Privacy Request"

- Response Time: Within 30 days


Emergency Service Issues:

- Email: info@leadwinner.ai

- Subject: "URGENT - [describe issue]"

- Response Time: Within 24-48 hours


Security Incidents:

- Email: info@leadwinner.ai

- Subject: "SECURITY INCIDENT"

- Response Time: Immediate review


### Mailing Address


For Legal Notices and Formal Correspondence:


SYNERGY FACTOR INC

407 E AYRE ST, UNIT 1399

WILMINGTON, DE 19804

USA


### Response Times


- TCPA opt-out requests: Within 2 business days

- Data privacy requests: Within 30 days (or as required by applicable law)

- Security incidents: Immediate investigation

- General inquiries: 2-5 business days

- Technical support: 1-3 business days

- Legal notices: As required by law


### International Users


If you are contacting us from outside the United States:

- All times are in Eastern Time (ET)

- International rates may apply for phone/SMS communications

- English is our primary language for support


### What to Include in Your Request


To help us respond effectively, please include:

- Your full name and account email address

- Phone number(s) associated with your account (if applicable)

- Detailed description of your request or concern

- Any relevant account or transaction IDs

- Preferred method of response (email, phone, mail)

- Best times to reach you (for phone responses)


---


Last Updated: October 9, 2025


Version: 2.0


By using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.



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