Global Terms of Use, Privacy Policy & Data Protection Notice of ImmigrationLeads.com

These Global Terms of Use, Privacy Policy and Data Protection Notice (“Terms” or “Notice”) govern access to and use of ImmigrationLeads.com and explain how Leads Paid Inc. (“Leads Paid”, “we”, “us” or “our”) collects, uses, discloses and otherwise processes personal information in connection with the ImmigrationLeads.com lead-generation platform, campaigns and related websites.

This Notice is intended for users in the United States and other countries. Because privacy and marketing laws differ by jurisdiction, we apply the rights and requirements that are applicable to a particular individual, activity and jurisdiction. Nothing in this Notice limits any non-waivable rights available under applicable law.

1. Platform and Network Sites

ImmigrationLeads.com is a technology, advertising and lead-generation platform through which immigration consultants, immigration law firms, relocation providers and other relevant service businesses (“Clients” or “Partners”) may create, participate in or receive immigration-related enquiries and leads generated from advertising and lead-generation campaigns.

Campaigns may operate through ImmigrationLeads.com itself or through websites, domains, subdomains, microsites, landing pages, applications, forms and other digital properties operated by or on behalf of Leads Paid (collectively, “Network Sites”). Network Sites may be added, removed or changed over time without being individually listed in this Notice. A Network Site may link directly to this Notice or may provide a site-specific privacy notice that supplements it.

Where a Network Site provides a more specific notice at or before collection, that more specific notice controls for the particular collection, sharing, communication or consent described there.

Platform accounts are intended for persons aged 18 or older who are legally capable of entering into agreements. By registering for, accessing or using ImmigrationLeads.com as a Client, you agree to these Terms.

2. Our Role and the Role of Clients

2.1 When Leads Paid Determines the Purpose

Where Leads Paid determines why and how personal information is collected or used—for example to operate Network Sites, administer the platform, allocate enquiries, prevent fraud, secure systems, maintain consent records or manage campaigns—Leads Paid is responsible for that processing under applicable privacy law.

2.2 When Leads Paid Processes for a Client

Where Leads Paid processes personal information solely on documented instructions from a Client and does not independently determine the purpose of that processing, Leads Paid may act as a processor, service provider, contractor or similar regulated service role, depending on the applicable law.

2.3 Client Responsibility After Lead Delivery

Once Lead Data is lawfully delivered, disclosed or made available to a Client or Partner, that recipient is independently responsible for its subsequent use, communications, storage, security, retention, deletion, onward disclosure and compliance with applicable law, except to the extent Leads Paid continues to process the information on the recipient’s behalf under a separate agreement.

3. Personal Information We May Collect

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or can reasonably be linked to an individual or household, to the extent protected by applicable law. “Lead Data” means Personal Information and other information voluntarily submitted through a Campaign or Network Site.

Depending on the Campaign, Network Site and service requested, we may collect:

• identifiers and contact details, such as name, email address, postal address and telephone number;
• account, company and business-contact information for Clients;
• transaction, billing and campaign information;
• internet, browser, device, IP address, cookie, analytics, referral and usage information;
• approximate location derived from IP address or similar technical information;
• nationality, country of residence, immigration status, visa or permit information, employment, occupation, education, family or sponsor information, financial/profile information, service preferences and other information relevant to an immigration enquiry;
• communications, enquiry details, free-text responses and appointment or service-request information;
• consent, form, source, timestamp, delivery and campaign records; and
• other information that an individual voluntarily provides through a Network Site or Campaign.

We do not ask individuals to provide highly sensitive information unless it is reasonably necessary for the particular service or Campaign and the applicable collection notice explains the purpose. Where sensitive information is subject to additional legal requirements, we process it only as permitted by applicable law.

4. Sources of Personal Information

We may obtain Personal Information:

• directly from individuals who submit a form, request information, create an account or communicate with us;
• from a Client, Partner or authorised representative where legally permitted;
• from Network Sites and Campaigns operated by or on behalf of Leads Paid;
• automatically from browsers, devices, cookies, pixels, analytics tools and similar technologies;
• from advertising platforms, campaign providers and referral sources; and
• from service providers or other lawful sources where permitted by applicable law.

5. Why We Use Personal Information

We may collect, use and otherwise process Personal Information to:

• operate ImmigrationLeads.com, Network Sites, forms and Campaigns;
• respond to enquiries and provide requested information;
• match, route, allocate, refer or deliver an immigration-related enquiry to one or more relevant Clients or Partners;
• allow relevant Clients or Partners to contact an individual regarding the immigration, relocation or related service requested or described at the point of collection;
• manage Client accounts, Campaigns, billing, payments and reporting;
• provide customer and Client support;
• measure Campaign performance, analytics and attribution;
• detect duplicate, fraudulent, automated, test or invalid submissions;
• prevent misuse and protect the security and integrity of our systems;
• maintain records of submissions, notices, consent, preferences, allocation and delivery;
• resolve complaints, disputes, replacement requests and legal claims;
• comply with applicable laws, regulations, court orders and lawful governmental requests; and
• carry out other compatible purposes disclosed at collection or otherwise permitted by law.

6. Disclosure to Clients, Partners and Service Providers

Personal Information may be disclosed, as applicable, to:

• one or more Clients or Partners whose immigration, relocation or related services are relevant to the enquiry or Campaign;
• hosting, CRM, communications, call, messaging, email, analytics, advertising, payment, security, software, storage and infrastructure providers;
• professional advisers, auditors, insurers and consultants where reasonably necessary;
• affiliates involved in operating or supporting the platform or Campaign;
• governmental, regulatory, judicial or law-enforcement authorities where required or permitted by law; and
• other persons or organisations where the individual directs, requests or consents to the disclosure or where applicable law otherwise permits it.

The specific category of Client or Partner receiving an enquiry should be described by the relevant Network Site, Campaign or notice at collection. Not every Lead is provided to every Client.

7. Lead Generation, Referrals, Sale, Sharing and Targeted Advertising

ImmigrationLeads.com is a global immigration lead-generation platform operated by Leads Paid Inc. Clients or Partners may pay Leads Paid for advertising, campaign-management, lead-generation, referral, marketing or related services. As part of the service, we may transfer contact information and immigration-enquiry details to one or more relevant Clients or Partners.

Depending on the applicable law and the circumstances, a transfer of Personal Information to a Client, Partner, advertising provider or other third party may be treated as a “sale,” “sharing,” disclosure for “targeted advertising,” or a similar regulated activity, even where the individual submitted the enquiry for the purpose of being matched with a relevant provider.

Where applicable law provides a right to opt out of sale, sharing, targeted advertising or certain profiling, eligible individuals may exercise that right through any privacy-choice mechanism made available on the applicable site or by contacting our Privacy Contact. Where legally required and technically received by our systems, we will process recognized browser-based opt-out preference signals in accordance with applicable law.

We do not permit a Client to use Lead Data for materially unrelated purposes merely because the Client received the Lead through our platform.

8. Calls, Text Messages, Email and Marketing Communications

Submitting a general enquiry does not automatically create unlimited permission for marketing communications. The notice and consent displayed on the relevant form determine the communications that the individual has agreed to receive.

Where a form expressly states that one or more Clients or Partners may contact the individual by telephone, text message, email or other channel, the individual’s submission may constitute consent to the communications described in that form to the extent permitted by applicable law.

Where a law requires a particular form of consent, disclosure, signature, seller identification, opt-in, opt-out or suppression process for calls, prerecorded or artificial-voice messages, text messages, email or other marketing communications, the party initiating or authorising that communication is responsible for satisfying those requirements.

Where required by applicable law, consent to marketing communications will not be treated as a condition of purchasing a product or service. Individuals may withdraw or revoke marketing consent using the method described in the relevant communication, by contacting the sender, or by contacting us where Leads Paid controls the communication.

9. Cookies, Analytics and Advertising Technologies

ImmigrationLeads.com and Network Sites may use cookies, pixels, tags, local storage, analytics tools, advertising identifiers and similar technologies to operate sites, remember settings, prevent fraud, measure traffic and Campaign performance, understand referrals and, where permitted, support advertising or targeted advertising.

Where applicable law requires consent for non-essential cookies or similar technologies, the relevant site should provide an appropriate consent or preference mechanism. Browser settings may also allow individuals to block or delete certain cookies, although doing so may affect site functionality.

10. International Privacy Framework

Leads Paid operates a global lead-generation platform. Privacy and marketing laws vary by jurisdiction. The provisions below apply only where the relevant law applies to Leads Paid, the applicable Campaign or the individual concerned. If a local law gives an individual greater or non-waivable rights, those rights are not limited by this Notice.

10.1 United States

Where applicable U.S. federal or state privacy law applies, Leads Paid will provide the rights and notices required by that law. Depending on the state and circumstances, rights may include access or know, correction, deletion, portability, opt-out of sale or sharing, opt-out of targeted advertising or certain profiling, limitation of certain sensitive-information uses, appeal rights and non-discrimination.

Where the California Consumer Privacy Act (“CCPA”), as amended, applies, eligible California residents may exercise applicable rights through the methods described in this Notice and any “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” mechanism made available on the relevant site.

10.2 Canada

Where Canadian private-sector privacy law applies, including PIPEDA or applicable substantially similar provincial legislation, Leads Paid will collect, use and disclose Personal Information for identified and reasonable purposes, obtain meaningful consent where required, maintain appropriate safeguards, and provide applicable access and correction rights. Commercial electronic messages are also subject to applicable Canadian marketing laws.

10.3 Singapore

Where the Singapore Personal Data Protection Act 2012 (“PDPA”) applies, Leads Paid will comply with applicable obligations concerning accountability, notification, consent, purpose limitation, accuracy, protection, retention limitation, transfer limitation, access, correction and data-breach notification.

Where Singapore Do Not Call requirements apply, the party initiating or authorising the relevant marketing communication is responsible for complying with those requirements unless a valid exception or applicable consent permits the communication.

10.4 Australia

Where the Australian Privacy Act 1988 and Australian Privacy Principles (“APPs”) apply, Leads Paid will manage Personal Information in accordance with applicable requirements concerning transparency, collection, notification, use and disclosure, direct marketing, cross-border disclosure, data quality, security, access and correction. Australian marketing communications may also be subject to separate spam, telemarketing and Do Not Call requirements.

10.5 European Economic Area — including Germany, Ireland and Portugal

Where the EU General Data Protection Regulation (“GDPR”) applies, including in Germany, Ireland and Portugal, Leads Paid processes Personal Information only where an applicable legal basis exists. Depending on the purpose, that basis may include consent, performance of a contract or requested pre-contract steps, legitimate interests that are not overridden by the individual’s rights and interests, or compliance with legal obligations.

Applicable GDPR rights may include information, access, rectification, erasure, restriction, portability, objection, withdrawal of consent, rights relating to certain automated decisions, and the right to lodge a complaint with a competent supervisory authority.

10.6 United Kingdom and Switzerland

Where United Kingdom or Swiss data-protection law applies, Leads Paid provides the corresponding privacy rights and safeguards required by those laws, including applicable transparency, access, correction, deletion, objection, transfer and complaint rights.

10.7 India

Where India’s Digital Personal Data Protection Act 2023, rules made under it, or other applicable Indian privacy requirements are in force and apply to a Campaign, Leads Paid will follow the notice, consent or other lawful basis, security safeguards, grievance mechanisms and Data Principal rights legally in force at the relevant time.

10.8 Malaysia

Where Malaysia’s Personal Data Protection Act 2010 and applicable amendments or regulations apply, Leads Paid will process Personal Information in accordance with applicable notice, consent, disclosure, security, retention, data-integrity and access requirements. Applicable rights may include access, correction, withdrawal of consent and objection to certain direct marketing.

10.9 New Zealand

Where New Zealand’s Privacy Act 2020 applies, Leads Paid will comply with the applicable Information Privacy Principles concerning collection, notice, security, access, correction, accuracy, retention, use, disclosure and overseas disclosure, including applicable notification requirements for indirect collection.

10.10 United Arab Emirates

Where the UAE Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data or another applicable UAE privacy regime applies, Leads Paid will process Personal Information in accordance with applicable requirements concerning lawful processing, notice or consent where required, security, data-subject rights and cross-border transfers. Separate regimes may apply in particular UAE financial free zones or regulated sectors.

10.11 Other Countries

Where Leads Paid operates a Campaign in another jurisdiction with applicable privacy, data-protection, consumer-protection or electronic-marketing laws, Leads Paid and the relevant Client or Partner will comply with the requirements applicable to their respective activities. A Network Site or form may provide additional local disclosure or consent where required.

11. Privacy Rights

Depending on where an individual lives and which law applies, privacy rights may include information, access, correction, deletion, portability, restriction, objection, withdrawal of consent, opt-out of sale or sharing, opt-out of targeted advertising or certain profiling, limitation of certain sensitive-data uses, appeal of certain request decisions, and complaint to an applicable regulator.

To exercise a privacy right, contact our Privacy Contact using the email below and identify the right, country or state, and the relevant site or Campaign. We may verify the requester’s identity and authority before fulfilling a request and may deny or limit a request where permitted by law.

12. Automated Decision-Making and Profiling

Leads Paid may use automated technologies to assist with routing, Campaign optimisation, fraud detection, analytics and platform operations. Unless a specific notice states otherwise, we do not intend automated technology alone to make a legal or similarly significant decision about an individual. Where applicable law provides rights concerning automated decision-making or profiling, eligible individuals may exercise those rights through the Privacy Contact.

13. International Complaints and Regulators

Where applicable law provides a right to complain to a privacy or data-protection regulator, individuals may lodge a complaint with the authority responsible for their jurisdiction. We encourage individuals to contact our Privacy Contact first so that we can attempt to resolve the matter.

14. Client Responsibilities for Lead Data

After receiving Lead Data, a Client or Partner must use the Lead only for lawful and permitted purposes and is independently responsible for applicable privacy, advertising, marketing, telemarketing, email, text-messaging, consumer-protection and sector-specific requirements.

Clients and Partners must maintain reasonable security, honor applicable opt-outs and withdrawal requests, avoid unlawful re-sale or onward disclosure, obtain any further consent required for new or materially different purposes, and retain Personal Information only for as long as reasonably necessary under applicable law.

15. Access, Correction, Deletion and Withdrawal Requests

Individuals may contact our Privacy Contact to request access, correction, deletion, withdrawal of consent or another privacy right that applies to information in Leads Paid’s possession or control.

Where the relevant Personal Information has already been lawfully delivered to an independent Client or Partner, that recipient is responsible for requests relating to the copy it independently holds. Where reasonably appropriate, Leads Paid may identify or notify the relevant recipient.

16. Accuracy

We generally rely on information provided by the individual, an authorised representative, a Client or another lawful source. Individuals should provide accurate information and notify us where information they provided is materially inaccurate or has changed.

17. Security

We maintain reasonable administrative, technical and organizational safeguards designed to protect Personal Information in our possession or control against unauthorized access, use, disclosure, alteration, loss or destruction.

No Internet transmission or electronic storage system is completely secure. Clients and Partners are independently responsible for protecting copies of Lead Data after delivery.

18. Retention

We generally retain full identifiable Lead Data only for as long as reasonably necessary to generate, deliver, administer and review the Lead and to handle quality, replacement, fraud or dispute matters.

Unless a longer period is reasonably required for an active complaint, dispute, investigation, legal obligation or other legitimate purpose, full identifiable Lead Data will normally be deleted or anonymized within 60 days after delivery to the relevant Client or Partner.

Minimal records reasonably necessary to evidence a submission, notice, consent, preference, source, Campaign, delivery, transaction or compliance matter may be retained for a longer period where reasonably necessary for legal, audit, fraud-prevention, compliance or dispute-resolution purposes.

19. International Data Transfers

Leads Paid operates internationally and may use service providers or systems located in countries other than the country in which the individual is located. Personal Information may therefore be transferred to, stored in or accessed from other countries.

Where applicable law requires a lawful transfer mechanism or additional safeguard, we use an appropriate mechanism, which may include adequacy decisions, contractual safeguards, standard contractual clauses, transfer addenda or another legally recognized mechanism.

20. Data Incidents

We maintain processes for responding to suspected or confirmed security incidents involving Personal Information in our possession or control. Where applicable law requires notification to individuals or authorities, we will make the notifications for which Leads Paid is legally responsible.

21. Children

ImmigrationLeads.com and the platform are not directed to children under 13, and Client platform accounts are intended for adults aged 18 or older. We do not knowingly collect Personal Information directly from children under 13 through general lead-generation forms.

Where a Campaign legitimately involves information about a minor, such as a parent or guardian seeking an appropriate service for a child, the relevant form and applicable law govern that collection.

22. AI and Automated Technologies

Leads Paid may use artificial intelligence or automated technologies to assist with Campaign content, advertising creatives, landing pages, analytics, routing, fraud detection, optimization or platform operations.

Unless a specific notice states otherwise, we do not intend automated tools alone to make legal or similarly significant decisions about individuals. Where applicable law creates additional rights concerning automated decision-making or profiling, eligible individuals may exercise those rights as described in Section 11.

23. Lead Quality, Payments and Platform Use

Leads Paid does not guarantee that every Lead will answer, purchase, qualify for, or convert into a customer, nor does it guarantee that information voluntarily submitted by an individual is accurate.

Campaigns may operate using prepaid balances, subscriptions, budgets, per-Lead charges, referral fees or other agreed commercial arrangements. Applicable prices, replacement policies and billing rules may be specified separately.

Clients must not generate fraudulent Leads, use bots to manipulate submissions, unlawfully use Lead Data, compromise platform security or violate privacy, consumer-protection, intellectual-property or other applicable laws.

24. Client Content, Intellectual Property and Service Availability

A Client grants Leads Paid a limited licence to use materials, names, branding, logos, images and other content supplied by the Client solely as reasonably necessary to provide the platform or Campaign services.

ImmigrationLeads.com, platform software, systems, design and Leads Paid branding are owned by or licensed to Leads Paid. Leads Paid may modify, suspend or discontinue parts of the service and does not guarantee uninterrupted or error-free operation.

25. Limitation of Liability and Client Indemnity

To the maximum extent permitted by applicable law, Leads Paid will not be liable for indirect, incidental, special, consequential, exemplary or loss-of-profit damages arising from the platform, Campaigns or Leads, or for losses caused by a Client’s or Partner’s independent acts or omissions.

Except for liability that cannot lawfully be excluded or limited, Leads Paid’s aggregate liability arising from the platform or these Terms will not exceed the amount paid by the applicable Client to Leads Paid during the three months immediately preceding the event giving rise to the claim.

To the maximum extent permitted by applicable law, a Client will indemnify Leads Paid against third-party claims, regulatory claims, reasonable legal costs and losses to the extent arising from that Client’s unlawful use of Lead Data, communications, security failures, unauthorized disclosure, breach of applicable law or breach of these Terms. This does not make the Client responsible for unlawful acts caused solely by Leads Paid.

26. Business Transfers

If Leads Paid is involved in a merger, acquisition, financing, restructuring, reorganization, bankruptcy, sale of assets or similar business transaction, Personal Information may be transferred as part of that transaction subject to applicable law.

27. External Services

ImmigrationLeads.com and Network Sites may contain links to or integrations with independent third-party sites or services. Leads Paid is not responsible for their independent privacy practices, content or services.

28. Privacy Contact

Questions, privacy requests, complaints or requests to exercise applicable privacy rights may be sent to:

Privacy Contact
Leads Paid Inc.
Email:

29. Changes to this Notice

We may update this Notice from time to time to reflect changes in our services, technology, legal requirements or practices. The version and last-updated date shown above identify the version currently in effect.

The addition of a new Network Site or Campaign does not by itself require this Notice to be amended where the new site or Campaign operates within the categories, purposes and practices already described here. A Network Site may provide supplemental notice where a particular Campaign requires additional disclosures or consent.

30. Governing Law

These Terms are subject to the law applicable to Leads Paid Inc., the relevant Client agreement and the particular transaction or Campaign. Nothing in these Terms limits any mandatory consumer, privacy or data-protection right that cannot lawfully be waived under the law applicable to a particular individual.