Privacy policy

We operate the advertising campaigns and the forms that generate every record in the system. Some of those forms are hosted by the advertising platform the ad runs on — a Facebook or Instagram instant form, for example — which we build, own the questions on, and receive the submissions from. We are not a broker reselling data sourced from third parties.

This policy covers both the consumers who submit those forms and the agents who hold accounts with us.

When a consumer asks about whole life coverage we collect what they enter on the form — first name, last name, state and phone number — together with metadata attached to the submission, such as its timestamp and the ad and form it came from. Where the form is hosted on our own site we also record the originating IP address and the page it was served on; a form hosted by an advertising platform does not pass those to us.

Where that platform passes us an email address alongside the submission, we receive and retain it, but it is not part of the record delivered to an agent.

If the consumer confirms a one-time code the form requires, we retain the fact of that confirmation and its timestamp. The code itself is sent and checked by the advertising platform that hosts the form, not by us.

We hold the information you provide at signup, your delivery and filter settings, billing records held by our payment processor, and a delivery log tying each purchased lead to your account.

We use this to run the account, support you, prevent resale, and adjudicate credit requests.

The exact disclosure language shown at submission is archived on our systems, together with the submission timestamp, the question it was shown under, and the identifiers of the ad and form it came from. Where the form is hosted on our own site we archive the originating IP address as well. None of it is delivered as part of the lead.

A consumer who then enters the one-time code the form requires creates a second, independent record: a confirmation only the holder of that phone could give, timestamped.

We keep this documentation as our internal proof that each consumer requested contact.

We use analytics services to understand how people find and use this site. They record the pages visited, the links and buttons used, the campaign tags on the link that brought a visitor in, an approximate location derived from IP address, and the device and browser in use. This information is held by those providers on our behalf and is used to measure our advertising and improve the site.

On our public pages this includes session recording: a reconstruction of a visit showing the pages viewed and where the visitor clicked, scrolled and moved. Values typed into form fields are masked before the recording is made, so names, phone numbers and email addresses do not appear in it. Recording is switched off entirely inside the signed-in agent dashboard, so purchased lead information is never captured.

We tag inbound advertising links with campaign parameters and keep them in the visitor’s browser for up to thirty days, so that a purchase can be attributed to the ad that produced it. The advertising platforms we buy from set their own tags for the same purpose. A visitor can clear all of these through their browser’s site-data controls, and most browsers and privacy extensions can block them outright.

A consumer record is disclosed to the single agent whose account it is delivered to, and to the service providers that operate the platform on our behalf — hosting, our payment processor, analytics and session recording, email and messaging delivery, and telephony.

We do not sell personal information for money or other valuable consideration. We do report purchases made on this site to the advertising platforms we buy from, including Meta and Google, so that we can measure and improve the campaigns that brought the buyer here. What we send is an irreversibly hashed form of the purchasing agent’s email address, phone number and name, together with the advertising identifiers already present in their browser and their IP address.

We report consumer submissions in the same way. When a consumer completes a form and its one-time code check, we report that confirmation back to the advertising platform whose ad produced it, so the platform can find more people like them. What we send is an irreversibly hashed form of the consumer’s name and phone number, their state, and the identifier of the ad form they submitted. Under some state privacy laws, including the CCPA/CPRA, both of these count as sharing personal information for cross-context behavioral advertising.

We may disclose information where required by law or to protect our rights.

Delivered leads are retained while they sit in an agent account. We retain our own consent records for the period we are required to keep proof of consent. Account and billing records are kept for the life of the account and any legally required window after it closes.

When a retention period ends, or a deletion request is honored, the underlying record is removed from our systems and from delivered leads.

Consumers may request access to, correction of, or deletion of their information by contacting us. Depending on where they live they may have additional rights under laws such as the CCPA/CPRA. We honor verified requests and do not discriminate for exercising them.

A record removed on request disappears from any agent’s delivered leads as well, so no one continues to work data the consumer has asked us to erase.

The same address reaches us for the tracking described above: a request to be excluded from session recording, or to stop the advertising sharing described in Sharing, can be sent there and we will honor it.

We use encryption in transit, role-limited access, and reputable infrastructure and payment providers. Card details are handled by our payment processor and are not stored on our systems.

No method of transmission or storage is perfectly secure, but we work to protect information in line with its sensitivity and to notify affected parties where the law requires.

Questions about this policy, or requests to access or delete data, can be sent to privacy@primalprospect.com. We respond within the timeframes required by applicable law.