DRAFT for lawyer review. Not yet legal advice or a final policy.

Privacy policy

Last updated: [date]. LeadWake is operated by [legal entity name], ABN [ABN], an Australian business based in Queensland, Australia ("we", "us"). This draft is written for US customers.

Two kinds of personal information

1. Our customers' account details (name, business, email, postal address, billing details). We collect these to run your account and bill you. Card details are handled by Stripe; we don't store card numbers.

2. Contact lists our customers upload (their past customers and leads). Our customer decides what is uploaded and who is emailed. We process this information on their behalf as a service provider (a "processor" under state privacy laws), only to run their campaigns.

How we use uploaded lists

You've paid for your leads and earned your customers. Here's exactly what LeadWake does and doesn't do with them.

• We never sell, share or rent your list.
• We never train AI on your customers' personal details. When we use an AI model to write emails, we send it your business details and general job types, not your customers' names or email addresses.
• We learn only from anonymous, combined results, such as reply and booking rates by trade, state, email step and month. These numbers contain no names, emails or message text and can't be tied back to your business.
• Raw data is only used beyond your own campaigns if you tick the optional opt-in box. It is unticked by default and you can withdraw at any time in Settings.
• Your emails come from your own domain and replies go to your own inbox.
• Nothing sends until you approve it, and the pause button stops everything straight away.
• One-click delete wipes your lists, contacts, emails and logs. We keep a one-way scrambled (hashed) copy of unsubscribed addresses so we never email those people again on your behalf, unless you delete your whole account.
• Canceled accounts are deleted 30 days after cancelling.
• Encryption: names and emails are encrypted at rest (AES-256) and all traffic uses HTTPS. Staff do not browse customer lists.

We do not sell or share personal information

We do not sell personal information, and we do not "share" it for cross-context behavioral advertising, as those terms are used in the California Consumer Privacy Act (CCPA/CPRA) and similar state laws. We don't use contact lists for targeted advertising.

Service providers and international transfers

We use service providers to run LeadWake: hosting ([host, region]), email delivery (Resend), payments (Stripe) and an AI writing service (which does not receive contact names or emails). Because we are based in Australia, your information may be accessed from Australia and stored in [regions]. [Lawyer: confirm transfer wording.]

Your privacy rights

Depending on your state (for example California, Colorado, Connecticut, Virginia, Texas and others), you may have the right to know what personal information we hold, to get a copy, to correct it, to delete it and to opt out of sale or targeted advertising (we do neither). We won't discriminate against you for using these rights. Email [privacy@leadwake.io] to make a request; we'll verify your identity and respond within the time the law requires (generally 45 days). If you're on one of our customers' lists, we'll pass your request to that business and help them act on it. [Lawyer: confirm which state laws apply given our size and revenue thresholds.]

Unsubscribes

Every email includes the sender's postal address and an unsubscribe link. Opt-outs take effect immediately, faster than the 10 business days allowed under CAN-SPAM.

Security and breaches

Names and emails are encrypted at rest. If a breach affects your information, we'll notify you and regulators as required by the applicable state breach notification laws.

Children

LeadWake is for businesses and isn't directed to children under 13.

DRAFT for lawyer review. Not yet legal advice or a final policy.