Privacy Policy

01Introduction

Effective Date: July 27, 2026

Leadvaro, LLC (“Leadvaro,” “we,” “us,” or “our”) operates a B2B data infrastructure and business intelligence platform.

This Privacy Policy explains how we collect, obtain, use, maintain, disclose, and protect personal information through our website, products, services, and business data operations. It also explains the privacy rights available to individuals whose information we process and how those individuals can exercise those rights.

This Privacy Policy applies to two primary categories of individuals:

Customers, prospective customers, and website visitors. If you use our website, communicate with us, create an account, or use our products and services, the provisions addressing customers and website visitors apply to you.

Business professionals represented in our database. If your professional information—such as your name, position, business email, telephone number, employer, or professional profile—is included in our business database, the provisions relating to business professionals apply to you. Individuals who wish to have their information removed should review the database opt-out process described in Section 14.

02Customers and Website Visitors

2.1 Information We Collect

Depending on how you interact with Leadvaro, we may collect several categories of information.

Account and Business Information. When you register for an account, request information, or communicate with us, we may collect:

• Full name
• Business email address
• Company name
• Job title
• Login and account credentials
• Other information you voluntarily provide

Billing Information. When you purchase our services, billing information may be processed through third-party payment service providers. This can include billing addresses and payment-method information. We do not retain complete payment card numbers on our own systems.

Product and Usage Information. We may collect information relating to your use of our platform, including:

• API requests and activity logs
• Search and query volumes
• Credit consumption
• Features and functionality used
• Technical information
• Service performance information

We use this information to operate the platform, monitor performance, improve our products, maintain security, and enforce applicable agreements.

Information You Submit. You may provide information to our services for purposes such as verification, enrichment, matching, or processing. For example, you may submit an email address for verification or a company record for enrichment. We refer to information submitted in this manner as “Submitted Data.”

Website and Analytics Information. When you visit our website, we may collect aggregated information concerning website activity, including:

• Pages viewed
• Session duration
• Approximate geographic region
• Browser and device information
• Referral sources
• Website interaction information

We may use analytics technologies, including Google Analytics and similar services, to understand overall website usage and improve our website.

Communications. We may retain communications you send to us, including customer-support requests, emails, inquiries, feedback, and other correspondence.

2.2 How We Use Customer Information

We may use customer and website visitor information to:

• Deliver, operate, maintain, and improve our services
• Create and administer accounts
• Process payments and provide billing documentation
• Respond to questions and support requests
• Communicate important service, security, and account information
• Monitor and protect the security of our systems
• Enforce our Terms of Service and other contractual obligations
• Detect and prevent misuse, fraud, or unauthorized activity
• Meet legal and regulatory requirements

We do not sell customer account or usage information to third parties for advertising purposes.

2.3 When Customer Information Is Shared

We may disclose customer or website visitor information to trusted third parties when reasonably necessary to operate our business. These parties may include:

Service providers. We may use vendors that provide cloud hosting, payment processing, analytics, customer support, security, infrastructure, and other operational services. Such providers are permitted to process information only as necessary to perform services for us.

Government authorities. We may disclose information when required by law, regulation, legal process, court order, or governmental request, or when disclosure is necessary to protect our legal rights.

Business transaction parties. If Leadvaro is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, information may be transferred to the relevant parties, subject to applicable legal requirements.

03Information Submitted to Our Services

When you submit information to Leadvaro for verification, enrichment, matching, or another service, we process that information to provide the requested functionality. For example, we may:

• Verify an email address
• Match a company to an existing business record
• Enrich a business profile
• Validate contact information
• Return information requested through our platform

We may also use submitted information as one of several signals used to improve the accuracy, completeness, and freshness of our business database. Our Terms of Service govern the rights and permissions associated with Submitted Data.

What We Do Not Do

We do not take a customer’s submitted list and independently market or resell that exact list as a standalone dataset attributable to that customer. We also do not identify a customer as the source of a particular business record.

Information derived from customer submissions may become part of our broader business database only after appropriate verification and validation. Once incorporated, such information is handled according to the same database practices that apply to information obtained through other legitimate sources.

Customers are responsible for ensuring that their submissions comply with applicable privacy, data-protection, and other legal requirements. Customers must not submit sensitive or special-category personal information unless expressly permitted by our applicable agreements and law.

04Business Professionals in Our Database

4.1 Information Included in Our Business Database

Leadvaro maintains a database containing professional contact information and company intelligence used for legitimate B2B purposes. Our database may contain professional and company records from multiple geographic markets.

A professional record may contain information such as:

• Name
• Company
• Office Address
• Telephone Number
• Email Address
• Job Title
• Job Function and Responsibilities
• Education
• Social Media URL

Company records may include:

• Company name
• Website and domain
• Industry classification
• Employee or headcount range
• Revenue range
• Funding stage and financing history
• Headquarters location
• Technology information
• Hiring activity
• Growth indicators

The specific information associated with an individual or company can vary depending on the availability and reliability of the underlying sources.

05How We Build Our Database

This data is collected from publicly available sources, licensed third-party providers, and lawful enrichment processes and is shared only with subscribers according to their subscription plan. The purpose of providing this data is to enable legitimate business outreach, and the lawful basis for processing includes Legitimate Interests.

5.1 Publicly Available Information

A substantial portion of our business information may come from information that companies and professionals have made publicly available in a professional or business context. Potential sources include:

• Company websites
• Professional networking profiles
• Business directories
• Government records and filings
• Court records
• Public business resources
• Other publicly accessible sources

Public Information either publicized by you or by a 3rd party that you have authorized.

5.2 Data Providers and Business Partners

We also collect Personal Information from sources other than the individual to whom the data relates. These sources may include:

• We may receive information from licensed third-party data providers, verification providers, technology partners, and other organizations that provide information under contractual arrangements.
• Where appropriate, we require relevant providers to represent that they have the necessary rights or lawful basis to provide information to us.

5.3 Customer Uploads & Contribution License

Customers may submit information to Leadvaro for purposes such as verification, matching, enrichment, or other Service functionality.

Where permitted, we may process such information to provide the requested Service, maintain data quality, verify records, and improve the operation and accuracy of our Services.

5.4 Verification and Data Refresh

We periodically review and verify records in our database. Our data-quality processes may include:

• Periodic email verification
• Periodic professional-profile verification
• Removal of records that remain unverifiable for an extended period

We do not purchase or license pre-built third-party contact databases as a primary source for our records. Records that cannot be sufficiently verified are removed from our active database.

06Legal Basis for Processing in the EU, EEA, and United Kingdom

Where applicable, Leadvaro processes professional contact information under recognized legal bases established by applicable data-protection laws, including the GDPR and UK GDPR.

6.1 Legitimate Interests

Our principal legal basis for processing professional contact information may be legitimate interest. Our legitimate interests may include enabling B2B commerce, providing business intelligence, supporting sales and marketing activities, maintaining data accuracy, and delivering our services to business customers.

When relying on legitimate interests, we consider factors such as:

• Whether the information relates to a professional rather than private capacity
• Whether the information was made publicly available in a professional context
• The nature and sensitivity of the information
• The reasonable expectations of the individual
• Available mechanisms for objection and removal
• Applicable safeguards and restrictions on customer use

Our processing is designed to focus on professional information rather than sensitive personal information.

6.2 Legal Obligations

We may process personal information when necessary to satisfy a legal or regulatory obligation, including responding to lawful requests, investigations, court orders, or regulatory requirements.

6.3 Other Legal Bases

Other GDPR legal bases, such as protection of vital interests or performance of a public task, generally do not form part of our ordinary business-data processing activities unless the circumstances require otherwise. Where appropriate, we may conduct and maintain Legitimate Interests Assessments relating to our processing activities.

07How Professional Information Is Used and Shared

In Short: We may disclose your personal information when necessary for the purposes outlined in this Privacy Policy, including to certain categories of service providers and other third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) that support our business operations and provide services on our behalf. These parties may only access or process your information to the extent reasonably necessary to perform the services we have engaged them to provide.

Where appropriate, we require these third parties to enter into contractual obligations requiring them to maintain the confidentiality and security of your information, use it only according to our instructions, and retain it only for as long as necessary to provide their services or as otherwise permitted by applicable law.

Depending on how you interact with our services, the types of third parties we may work with can include:

• hosting and infrastructure providers;
• data and enrichment providers;
• security and fraud-prevention providers;
• customer-support providers;
• analytics and service providers;
• professional advisers;
• payment and billing providers;
• other service providers acting under appropriate contractual safeguards.

Business Transactions. We may share, transfer, or otherwise make available personal information as part of a corporate transaction or potential transaction. This may occur in connection with a merger, acquisition, financing, reorganization, sale of assets, sale of all or part of our business, or similar corporate event. Where legally required, we will take appropriate steps to protect personal information during and after such transactions.

We may also share information with:

• Business customers using our services
• Data and verification partners
• Service providers supporting our operations
• Infrastructure providers
• Government authorities when legally required

Leadvaro does not authorize customers to use Leadvaro data for unlawful purposes.

08International Data Transfers

Leadvaro may operate and process business information across multiple jurisdictions. Where personal information is transferred internationally, we use appropriate mechanisms required under applicable privacy laws.

For transfers from the European Economic Area or United Kingdom to countries that do not provide an adequate level of data protection, we may rely on applicable Standard Contractual Clauses or other legally recognized transfer mechanisms, where appropriate.

Business customers that require a Data Processing Addendum or applicable transfer documentation may request the relevant documentation from us. For other international transfers, we seek to comply with the requirements of applicable local privacy laws.

09Information Security

Leadvaro maintain technical, administrative, and organizational safeguards intended to protect personal information against unauthorized access, alteration, loss, disclosure, or misuse. Depending on the service, these measures may include:

• access controls;
• authentication controls;
• encryption in transit;
• encryption at rest where appropriate;
• logging and monitoring;
• backup and recovery controls;
• vulnerability management;
• incident response procedures;
• personnel access controls; and
• data deletion procedures.

If we experience a security incident involving personal information, we will take appropriate steps to investigate, mitigate the incident, and provide notifications where required by applicable law.

10Privacy Rights

The rights available to you depend on where you live and the laws that apply to your information.

10.1 GDPR and UK GDPR Rights

Individuals located in the EU, EEA, or United Kingdom may have rights including:

• Access: Request information about the personal data we process about you.
• Correction: Ask us to correct inaccurate or incomplete information.
• Deletion: Request removal of your personal information, subject to applicable exceptions.
• Restriction: Request that certain processing activities be limited.
• Objection: Object to processing based on legitimate interests, including applicable direct-marketing processing.
• Portability: Request certain information in a structured, commonly used, machine-readable format.
• Withdrawal of Consent: Where processing relies on consent, withdraw that consent at any time.

To submit a request, contact us using the privacy contact information provided below. We generally aim to respond within 30 days. Where permitted by law, complex requests may require additional time, and we will notify you when an extension is necessary.

You may also have the right to lodge a complaint with the relevant data-protection supervisory authority.

11California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). Depending on the circumstances, these rights may include:

• The right to know what categories of personal information we collect
• The right to access personal information
• The right to request correction of inaccurate information
• The right to request deletion
• The right to opt-out of the sale or sharing of personal information
• The right to receive information regarding applicable sources and business purposes
• The right to receive equal treatment when exercising privacy rights

We do not discriminate against individuals for exercising privacy rights provided by applicable law.

To submit a California privacy request, contact us with the subject line: “California Privacy Request”. We may take reasonable steps to verify the identity of the person making a request before providing or deleting personal information.

12Other U.S. State Privacy Rights

Residents of states with comprehensive privacy legislation may have additional rights depending on the applicable law. These may include rights to:

• Access personal information
• Correct inaccurate information
• Delete personal information
• Obtain information in a portable format
• Opt-out of certain forms of processing, sale, or sharing
• Exercise other rights established by applicable state law

Requests should be submitted using the privacy contact information provided in this Policy.

13India and Australia

Individuals located in India may have rights under applicable Indian privacy legislation, including the Digital Personal Data Protection Act, 2023, where applicable. Depending on the circumstances, these rights may include obtaining information regarding processing and requesting correction or deletion.

Individuals in Australia may have rights under the Privacy Act 1988 and the Australian Privacy Principles, including rights relating to access, correction, and privacy complaints.

Requests may be submitted through our privacy contact address.

14Database Opt-Out and Removal

If your professional information is included in our database and you want us to remove it, you may submit an opt-out request. To request removal:

• Email us using the privacy address listed in Section 19.
• Use “Opt-Out Request” as the subject line.
• Provide your full name, business email address, and current or most recent employer.
• We may request additional information when reasonably necessary to identify the correct record.

We aim to process valid removal requests within 30 days. Once your information is removed, we will add the relevant information to a suppression list designed to prevent the record from being reintroduced through future collection or customer submissions.

Please understand that removal from our database does not automatically remove information previously licensed to customers. Those customers may independently retain information in their own CRM systems, marketing platforms, or business records. We cannot directly control their independent databases, although we will take reasonable steps to prevent future delivery of suppressed information.

15Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Policy, contractual obligations, legitimate business purposes, or applicable legal requirements.

Customer Information. Account and usage information may be retained while an account remains active and for a reasonable period after account closure, unless a longer period is required or permitted by law.

Database Information. Business records are periodically reviewed and verified. Records that cannot be independently verified for an extended period may be removed from our active database. Information subject to a valid deletion or opt-out request may be placed on a suppression list to prevent the same information from being reintroduced through future collection.

Submitted Information. Submitted Data may be retained for purposes such as service operation, quality assurance, security, fraud prevention, and database improvement, subject to the practices described in this Policy. Information that fails our verification requirements will not be incorporated into the active database.

16Cookies and Similar Technologies

Leadvaro uses cookies and similar technologies to operate and secure our website, remember preferences, maintain login sessions, and understand website usage. These technologies may include:

• Essential cookies
• Preference cookies
• Analytics technologies
• Similar website-performance technologies

We may use Google Analytics or comparable analytics services to understand aggregated website traffic and user behavior.

You can control cookies through your browser settings. Blocking or deleting cookies may affect certain website functions.

Where legally required, we honor applicable privacy preference signals such as Global Privacy Control.

17Children's Privacy

Our services are intended for business and professional users and are not directed toward children. We do not knowingly collect personal information from children below the applicable legal age.

If we learn that we have unintentionally collected personal information from a child in circumstances where collection is not permitted, we will take appropriate steps to delete that information.

18Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in our services, business practices, technology, legal requirements, or privacy standards. When we make changes, we will publish the updated version on our website and revise the effective date.

If a change materially affects privacy rights or obligations, we may provide additional notice where required or appropriate, including through email or our services. We encourage you to review this Policy periodically.

19Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, wish to submit an opt-out request, or have a concern regarding the handling of personal information, please contact us at privacy@leadvaro.com. We will review your request and delete your data in accordance with applicable legal requirements and our internal data retention policies.

Suggested subject lines include: Opt-Out Request · California Privacy Request · State Privacy Request · GDPR Request · Privacy Inquiry.

Mail:
Privacy Officer
Leadvaro, LLC
1209 Mountain Road Pl NE, Ste R
Albuquerque, NM 87110
United States

Telephone: +1 505-528-5557

We aim to respond to privacy inquiries within 30 days, subject to applicable legal requirements and permitted extensions.