Privacy Policy
Effective Date: September 20, 2026
This Privacy Policy describes how Loyalty LTD, a Nevada limited liability company ("Loyalty LTD," "we," "us," or "our"), collects, uses, discloses, and protects personal information through the websites and services it operates under the Validated Lead Group, Validated Home Services, Validated Mortgage Leads, Validated Debt Leads, and Validated Insurance Leads brands. Each of those brands is a brand of Loyalty LTD.
Loyalty LTD is a lead generation and performance marketing company. When you submit an inquiry, we may sell or share the information you provide with buyers, service providers, and marketing partners who may contact you about the products or services you asked about. Section 12 explains your rights under California law, including your right to opt out of that sale or sharing.
Loyalty LTD, a Nevada limited liability company
2206 Heavenly View Drive, Henderson, Nevada 89014
(424) 704-5950
1. Information We Collect
Information you provide. When you submit a form, request pricing, apply as a media partner, join a waitlist, or contact us, we collect what you enter: name, company, title, email address, telephone number, and any message or notes; product or service interests, monthly volume, geographic interests, and similar campaign-fit details; for mortgage properties, an NMLS identifier; for media partner applications, business, traffic-source, and compliance information; and your consent selections.
Consent records. To evidence consent under the Telephone Consumer Protection Act and, where applicable, the Fair Credit Reporting Act, we record the exact text of each consent disclosure you agreed to, its version, the date and time you agreed, the page on which you agreed, your IP address, and your browser user agent.
Information collected automatically. When you visit our websites we collect your IP address, browser and device information, the pages you view, the page you landed on, the site that referred you, and campaign identifiers carried in the URL (for example utm_source, utm_medium, utm_campaign, utm_term, utm_content, gclid, fbclid, msclkid). We record the first such visit in your session and the most recent, so that we can attribute an inquiry to the campaign that produced it. We use cookies, local storage, and similar technologies for these purposes and for site function, security, and analytics.
Information from others. We may receive information about you from buyers and partners (for example, whether an inquiry was accepted), from service providers (for example, telephone number validation), and from publicly available sources.
2. How We Use Information
We use personal information to: route your inquiry to buyers, service providers, or partners who can respond to it; contact you about your inquiry by phone, text, and email, as permitted by law and by the consent you gave; evaluate whether an inquiry meets campaign, buyer, and compliance criteria; validate and enrich contact and attribute information; attribute inquiries to the campaigns and sources that produced them and pay partners accordingly; operate, secure, debug, and improve our websites and services; prevent fraud, invalid traffic, and abuse; maintain records of consent and honor opt-out requests; comply with legal obligations and enforce our agreements; and, with your consent where required, send marketing communications.
3. Selling and Sharing Personal Information
In the course of providing our services, we disclose the personal information you submit โ and related consent and attribution records โ to third parties for money or other valuable consideration. Under the California Consumer Privacy Act and similar laws, this is a sale of personal information. Recipients include buyers of leads and calls (such as home services contractors, mortgage lenders and brokers, debt relief providers, and insurance agencies and brokers), service providers acting on our behalf, and, where you selected one, the partner network named on the form.
We may also disclose identifiers and internet activity to advertising partners for cross-context behavioral advertising, which the CCPA calls sharing.
You may opt out of the sale and sharing of your personal information at any time through our Do Not Sell or Share My Personal Information page. Opting out stops future sales and sharing; it does not recall information already disclosed to a buyer who received it before your request, and it may mean we cannot route your inquiry.
We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.
4. Other Disclosures
We may disclose personal information to affiliates and subsidiaries of Loyalty LTD; to service providers who host, store, process, validate, transmit, or analyze data on our behalf, including cloud hosting, database, email delivery, telephony, and analytics providers; to professional advisors; to government agencies, regulators, courts, or law enforcement where required by law or legal process, or where we believe disclosure is necessary to protect rights, safety, or property; to prevent fraud or enforce our agreements; and to a successor in connection with a merger, acquisition, financing, or sale of assets.
5. Telephone and Text Communications
If you provide a telephone number and consent to be contacted, we and the buyers or partners to whom we route your inquiry may call or text you, including using automated technology, artificial or prerecorded voice, and SMS or MMS, as described in our TCPA Consent Disclosure. Consent is not a condition of purchase. You may revoke consent at any time by replying STOP to any text, by telling any representative during a call, or by contacting us at the address below. We retain consent and revocation records for at least five (5) years.
7. Data Retention
We retain personal information for as long as needed to fulfill the purposes described in this Policy, to comply with legal, regulatory, tax, and accounting obligations, to resolve disputes, and to enforce our agreements. Consent records are retained for at least five (5) years. Inquiry records are retained for as long as needed to serve the inquiry, evidence attribution and payment, and defend claims.
8. Security
We maintain administrative, technical, and physical safeguards reasonably designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Children
Our websites and services are directed to businesses and to adults. We do not knowingly collect personal information from children under thirteen (13), and we do not knowingly sell or share the personal information of consumers under sixteen (16). If you believe a child has provided us personal information, contact us and we will delete it.
10. Third-Party Sites and Partners
Our websites may link to third-party sites, and the buyers and partners to whom we route inquiries are independent businesses with their own privacy practices. This Policy does not govern their collection or use of your information once you deal with them directly.
11. Your Choices and Rights
Depending on where you live, you may have the right to know what personal information we have collected about you, to access it, to correct it, to delete it, to opt out of its sale or sharing, to limit the use of sensitive personal information, and not to be discriminated against for exercising those rights. You may exercise these rights through our Data Privacy Request page or our Do Not Sell or Share page, or by emailing privacy@loyaltyltd.co. We will verify your identity before acting on a request and will respond within the time required by applicable law (generally 45 days, extendable once by 45 days with notice). You may designate an authorized agent to make a request on your behalf; we may require proof of authorization.
12. California Privacy Notice
Our California Privacy Notice applies to California residents and supplements the rest of this Policy as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA").
Personal information does not include publicly available information, de-identified or aggregated information, or information excluded from the CCPA's scope, such as information covered by the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, HIPAA, or the Driver's Privacy Protection Act. Where a Loyalty LTD property handles information subject to the FCRA or GLBA, that information is governed by those laws and any notice provided under them.
Categories of personal information collected in the preceding twelve (12) months, the sources, and whether sold or shared:
| Category | Examples we collect | Source | Sold / shared |
|---|---|---|---|
| A. Identifiers | Name, alias, postal address, unique identifier, IP address, email address, account name, Social Security number, driver's license number, passport number | You; automatic collection | Yes |
| B. Customer records (Cal. Civ. Code ยง1798.80) | Name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification number, bank or credit card numbers | You | Yes |
| D. Commercial information | Products or services of interest, volume, geographic interests, notes, inquiry history | You | Yes |
| H. Sensory data | Audio, visual, thermal, olfactory, or similar data, including call recordings and images submitted for identity review | You; automatic collection | Yes |
| F. Internet or network activity | Pages viewed, landing page, referrer, campaign identifiers, browser and device information | Automatic collection | Yes |
| G. Geolocation | Coarse location inferred from IP address; states or regions of interest you enter | Automatic collection; you | Yes |
| I. Professional or employment information | Title, company, NMLS identifier, business and traffic-source details in partner applications | You | Yes |
| K. Inferences | Campaign fit and routing determinations drawn from the above | Derived | Yes |
We collect identifiers, customer records information, and sensory data as described in the table above, including Social Security numbers, driver's license or state identification numbers, passport numbers, financial account information, call recordings, and images submitted for identity review. Some of this information is sensitive personal information under the CCPA. We collect and use sensitive personal information only for the permitted purposes described in our California Privacy Notice, and we do not use or disclose it to infer characteristics about you.
Purposes. The purposes described in Section 2.
Categories of third parties to whom we sell or share. Buyers of leads and calls in the categories described in Section 3; partner networks you select; advertising partners.
Categories of third parties to whom we disclose for business purposes. Service providers and contractors described in Section 4.
Your rights. The right to know, access, correct, delete, opt out of sale and sharing, and not be discriminated against, described in Section 11. Submit requests through the Data Privacy Request page, the Do Not Sell or Share page, or privacy@loyaltyltd.co. We do not use or disclose sensitive personal information for purposes that would give rise to a right to limit.
Financial incentives. We do not offer financial incentives in exchange for personal information.
Shine the Light. California residents may request a list of third parties to whom we disclosed personal information for their direct marketing purposes in the preceding calendar year by writing to privacy@loyaltyltd.co.
13. Other State Privacy Rights
Residents of states with comprehensive privacy laws may have similar rights to those described in Sections 11 and 12, including the right to opt out of the sale of personal information, targeted advertising, and certain profiling, and the right to appeal a denied request. Use the same channels to exercise them.
14. Changes to This Policy
We may update this Policy from time to time. Updates are posted with a new effective date. Continued use after posting means you accept the updated Policy.
15. Contact
Loyalty LTD, a Nevada limited liability company
2206 Heavenly View Drive, Henderson, Nevada 89014
(424) 704-5950
privacy@loyaltyltd.co