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Legal Policies

Effective Date: January 28, 2025
Last Updated: January 28, 2025

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Privacy Policy

1. Introduction

Leads Always ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our lead generation services. This policy applies to our operations in Australia, the United States, and the United Kingdom.

2. Information We Collect

2.1 Personal Information

  • Contact Information: Name, email address, phone number, company name, job title
  • Business Information: Company size, industry, website URL, business needs
  • Communication Data: Records of our communications with you, including emails and meeting notes
  • Technical Data: IP address, browser type, device information, website usage data

2.2 Automatically Collected Information

  • Website analytics data through Google Analytics
  • Cookies and similar tracking technologies
  • Page views, time spent on site, and navigation patterns

3. How We Use Your Information

We use your personal information for the following purposes:

  • Lead Generation Services: To identify and connect you with potential business opportunities
  • Service Delivery: To provide our lead generation and sales meeting booking services
  • Communication: To respond to inquiries, provide customer support, and send service-related notifications
  • Marketing: To send promotional materials and updates about our services (with your consent)
  • Analytics: To improve our website and services through usage analysis
  • Legal Compliance: To comply with applicable laws and regulations

4. Legal Basis for Processing (GDPR/UK GDPR)

For users in the EU and UK, we process your personal data based on:

  • Consent: For marketing communications and non-essential cookies
  • Contract: To perform our lead generation services
  • Legitimate Interest: For website analytics and business development
  • Legal Obligation: To comply with applicable laws

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

We may share your information with trusted third-party service providers, including:

  • CRM Platforms: For customer relationship management
  • Email Marketing Services: For communication and marketing campaigns
  • Analytics Providers: Google Analytics for website performance analysis
  • Cloud Storage Providers: For secure data storage and backup

5.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

5.3 Legal Requirements

We may disclose your information if required by law or to protect our rights, property, or safety.

6. Data Retention

We retain your personal information for as long as necessary to:

  • Provide our services to you
  • Comply with legal obligations
  • Resolve disputes and enforce agreements

Typically, we retain client data for 7 years after the end of our business relationship, unless a longer retention period is required by law.

7. Your Rights

7.1 General Rights

  • Access: Request a copy of your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your personal information
  • Opt-out: Unsubscribe from marketing communications

7.2 GDPR/UK GDPR Rights (EU/UK Residents)

  • Portability: Request transfer of your data to another service
  • Restriction: Request limitation of processing
  • Objection: Object to processing based on legitimate interest
  • Automated Decision-Making: Right not to be subject to automated decision-making

7.3 CCPA Rights (California Residents)

  • Know: Right to know what personal information is collected
  • Delete: Right to delete personal information
  • Opt-Out: Right to opt-out of the sale of personal information
  • Non-Discrimination: Right not to be discriminated against for exercising privacy rights

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

  • SSL/TLS encryption for data transmission
  • Secure cloud storage with encryption at rest
  • Regular security assessments and updates
  • Access controls and employee training

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard Contractual Clauses for EU/UK transfers
  • Adequacy decisions where applicable
  • Other legally recognized transfer mechanisms

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

Terms of Service

1. Acceptance of Terms

By accessing or using Leads Always services, you agree to be bound by these Terms of Service and all applicable laws and regulations. If you do not agree with any of these terms, you are prohibited from using our services.

2. Description of Services

Leads Always provides B2B lead generation and sales meeting booking services, including:

  • Identification and qualification of potential business prospects
  • Outreach and communication with prospects on your behalf
  • Booking of sales meetings with qualified leads
  • Reporting and analytics on campaign performance

3. User Obligations

3.1 Prohibited Activities

You agree not to:

  • Use our services for any unlawful purpose or in violation of applicable laws
  • Provide false, misleading, or inaccurate information
  • Interfere with or disrupt our services or servers
  • Attempt to gain unauthorized access to our systems
  • Use our services to send spam or unsolicited communications
  • Violate any third-party rights, including intellectual property rights

3.2 Account Responsibilities

  • Maintain the confidentiality of your account credentials
  • Notify us immediately of any unauthorized use of your account
  • Ensure all information provided is accurate and up-to-date
  • Comply with all applicable laws and regulations in your jurisdiction

4. Payment Terms

4.1 Pricing

Our services are provided on a performance-based model where you only pay for meetings that are successfully booked and attended by prospects.

4.2 Payment Schedule

  • Payments are due monthly based on delivered meetings
  • Invoices will be sent within 5 business days of month-end
  • Payment is due within 15 days of invoice date
  • Late payments may incur additional fees

4.3 Refunds

Refunds may be provided in cases where:

  • Meetings are not delivered as agreed
  • Service quality does not meet agreed standards
  • Technical issues prevent service delivery

5. Intellectual Property

5.1 Our Intellectual Property

All content, trademarks, and intellectual property on our website and in our services remain our property or that of our licensors.

5.2 Your Content

You retain ownership of any content you provide to us. By using our services, you grant us a limited license to use your content for service delivery purposes.

6. Privacy and Data Protection

Your privacy is important to us. Our collection and use of personal information is governed by our Privacy Policy, which is incorporated into these Terms by reference.

7. Service Availability

While we strive to maintain continuous service availability, we do not guarantee uninterrupted access. We may suspend or modify services for maintenance, updates, or other operational reasons.

8. Limitation of Liability

To the maximum extent permitted by law:

  • Our total liability shall not exceed the amount paid by you in the 12 months preceding the claim
  • We are not liable for indirect, incidental, or consequential damages
  • We do not guarantee specific results from our lead generation services

9. Indemnification

You agree to indemnify and hold us harmless from any claims, damages, or expenses arising from your use of our services or violation of these Terms.

10. Termination

10.1 Termination by You

You may terminate your account at any time with 30 days written notice. You remain responsible for all charges incurred before termination.

10.2 Termination by Us

We may terminate your account immediately if you violate these Terms or engage in prohibited activities.

11. Dispute Resolution

11.1 Governing Law

  • Australian clients: Governed by Australian law
  • US clients: Governed by the laws of the state where our US operations are based
  • UK clients: Governed by English law

11.2 Dispute Resolution Process

Any disputes will be resolved through:

  1. Good faith negotiations
  2. Mediation if negotiations fail
  3. Binding arbitration or court proceedings as a last resort

12. Changes to Terms

We may update these Terms from time to time. We will notify you of significant changes via email or website notice. Continued use of our services constitutes acceptance of updated Terms.

Cold Email Compliance & Anti-Spam Laws

As a lead generation service operating across multiple jurisdictions, we strictly adhere to all applicable anti-spam and cold email regulations. This section outlines the specific laws we comply with in each region where we operate.

1. United States - CAN-SPAM Act

1.1 Key Requirements

We comply with the CAN-SPAM Act of 2003, which regulates commercial email communications:

  • Sender Identification: All emails include accurate sender information and our physical business address
  • Clear Subject Lines: No misleading or deceptive subject lines or headers
  • Opt-Out Mechanism: Clear mechanisms to opt-out in every email with processing within 10 business days
  • Commercial Disclosure: Clear identification when emails are promotional in nature

1.2 Our Implementation

  • Personalized, relevant outreach based on business needs
  • Segmented campaigns to ensure relevance
  • Immediate honor of unsubscribe requests

1.3 Penalties

CAN-SPAM violations can result in fines up to $46,517 per email. We maintain strict compliance to avoid these penalties.

2. United Kingdom - UK GDPR, PECR & Data Protection Act

2.1 B2B vs B2C Distinction

UK law differentiates between business and consumer communications:

  • B2B Communications: We rely on legitimate interest for business-to-business outreach to corporate email addresses
  • B2C Communications: Explicit consent required for personal email addresses (e.g., @gmail.com, @yahoo.com)
  • Corporate Emails Only: We target only business email addresses at company domains

2.2 PECR Compliance

  • Include physical address and contact details in all communications
  • Provide clear opt-out mechanisms
  • Maintain suppression lists for opted-out contacts
  • Regular compliance audits and staff training

2.3 Penalties

UK violations can result in fines up to £500,000 under PECR or up to 4% of global turnover under UK GDPR.

3. Australia - Spam Act 2003

3.1 Consent Requirements

We operate under both express and implied consent frameworks:

  • Express Consent: Active permission via forms, checkboxes, or verbal agreement
  • Implied Consent: For existing business relationships or publicly listed business emails relevant to the recipient's role
  • Jurisdictional Scope: Applies to emails sent to or opened in Australia, regardless of sender location

3.2 Our Compliance Measures

  • Verification of existing business relationships before outreach
  • Use of publicly available business contact information only
  • Clear identification of sender and purpose
  • Functional unsubscribe mechanism in every email

3.3 Penalties

Australian Spam Act violations can result in fines up to $2.1 million for corporations.

4. Canada - CASL (Anti-Spam Legislation)

4.1 Consent Framework

Canada's CASL requires explicit consent with limited implied consent exceptions:

  • Explicit Consent: Required for most commercial communications
  • Implied Consent: Limited to published business emails relevant to recipient's business role
  • Third-Party Referrals: Only one outreach email permitted with referrer disclosure

4.2 Implementation

  • Verification of implied consent criteria before outreach
  • Disclosure of referral sources when applicable
  • Strict limitation on referral-based outreach
  • Clear sender identification and contact information

4.3 Penalties

CASL violations can result in fines up to $10 million for businesses.

5. European Union - GDPR & ePrivacy Directive

5.1 Lawful Basis for Processing

For EU prospects, we rely on legitimate interest for B2B communications:

  • Legitimate Interest Assessment: Balancing our business interests with individual privacy rights
  • Data Minimization: Collecting only necessary contact information
  • Transparency: Clear privacy notices explaining data processing
  • Individual Rights: Honoring requests for access, deletion, and objection

5.2 ePrivacy Compliance

  • B2B communications to corporate email addresses
  • Clear opt-out mechanisms
  • Respect for marketing preferences

5.3 Penalties

GDPR violations can result in fines up to €20 million or 4% of global annual turnover, whichever is higher.

6. Our Best Practices

6.1 Technical Compliance

  • Email Authentication: SPF, DKIM, and DMARC records properly configured
  • Suppression Lists: Automated management of opt-outs across all campaigns
  • Regular Audits: Monthly compliance reviews and list hygiene

6.2 Content Standards

  • Relevance: Highly targeted messaging based on business needs and industry
  • Transparency: Clear identification of sender and purpose
  • Value-Driven: Focus on providing genuine business value, not just sales pitches
  • Professional Tone: Business-appropriate language and formatting

6.3 Ongoing Compliance

  • Staff Training: Regular training on anti-spam laws and best practices
  • Legal Updates: Monitoring of regulatory changes across all jurisdictions
  • Client Education: Ensuring clients understand compliance requirements
  • Documentation: Maintaining detailed records of compliance procedures

7. Reporting Violations

If you believe you have received communications from us that violate any of these regulations, please contact us immediately:

  • Email: patrick@leadsalways.com
  • Response Time: We will investigate and respond within 48 hours
  • Remediation: Immediate removal from all campaigns and investigation of compliance procedures

Contact Information

If you have any questions about these policies or need to exercise your privacy rights, please contact us:

General Inquiries:

Email: patrick@leadsalways.com

Data Protection Officer (EU/UK):

Email: patrick@leadsalways.com

Privacy Rights Requests:

Email: patrick@leadsalways.com
Response Time: We will respond to your request within 30 days (or as required by applicable law)

Regulatory Authorities:

If you are not satisfied with our response to your privacy concerns, you may lodge a complaint with the relevant data protection authority:

  • Australia: Office of the Australian Information Commissioner (OAIC)
  • UK: Information Commissioner's Office (ICO)
  • EU: Your local data protection authority
  • California: California Attorney General's Office