Privacy Policy

This Privacy Policy explains how White Glove Leads, LLC ("White Glove Leads", "we", "us", or "our") collects, uses, discloses, retains, and protects personal information when you visit whitegloveleads.com, create an account, purchase a subscription, use our dashboard, submit onboarding materials, contact one of our clients, or otherwise interact with our services (the "Service").

White Glove Leads prepares hyper-local Facebook group content for local businesses. Most clients publish that content themselves, from their own personal Facebook accounts. Some ask us to do the publishing for them, and where they do, a named White Glove person performs that step by hand. Section 3 describes what that involves.

Either way, one fact shapes this entire Policy and does not change between the two: we never access the client's Facebook account. There is a large category of data we simply never touch.

By using the Service, you agree to this Policy. If you do not agree, do not use the Service. Our Terms of Service govern purchases and use of the Service, including the license you grant us in the materials you upload. This Policy covers privacy practices. Where the Terms and this Policy address the same subject, the Terms control on contract questions and this Policy controls on how we handle personal information.

Privacy contact: privacy@whitegloveleads.com.

Starting here, because it is the part people care about most, and because it is a limit on our own product, not a promise we can quietly drop.

WE NEVER COLLECT, REQUEST, RECEIVE, OR STORE YOUR FACEBOOK PASSWORD, LOGIN CREDENTIALS, SESSION TOKENS, COOKIES, OR ANY OTHER MEANS OF ACCESSING YOUR FACEBOOK ACCOUNT. WE DO NOT CONNECT TO YOUR PAGE, HOLD POSTING PERMISSIONS, OR ACT INSIDE YOUR ACCOUNT. THIS IS TRUE EVEN WHEN WE ARE THE ONES PUBLISHING FOR YOU — SEE SECTION 3. THERE IS NO SETUP STEP, NO TEMPORARY ACCESS, AND NO EXCEPTION. IF SOMEONE CLAIMING TO BE US ASKS FOR YOUR FACEBOOK PASSWORD, IT IS NOT US.

We have no technical ability to read your Facebook inbox, your friends list, your group memberships, or anything else inside your account. There is no integration to revoke, because there is no integration.

We do not scrape or harvest Facebook group member lists. We do not build profiles of people who live in a client's service area. We do not collect information about anyone who has not reached out to a client. If a neighbor scrolls past a client's post, sees it, or is simply a member of the same group, we have no record of them and never will.

We do not buy personal information from data brokers, and we do not enrich or append records from third-party data sources.

We do not sell personal information, and we do not share it for cross-context behavioral advertising. See section 13.

Clients choose who performs the publishing step, and can change that choice with us later:

• You publish. We prepare the post — the words, the photos, the group, and that group's rules — and you or your own staff publish it from your own Facebook account. This is the default.
• We publish for you. You approve the content, and a named White Glove person publishes it by hand, from an account we operate, as part of the work we do for you.

CHOOSING “WE PUBLISH” DOES NOT GIVE US ACCESS TO YOUR FACEBOOK ACCOUNT, NOW OR EVER. EVERYTHING IN SECTION 2 APPLIES IDENTICALLY IN BOTH MODES. WE DO NOT PUBLISH FROM YOUR ACCOUNT — WE HAVE NO MEANS TO, AND WE WILL NOT ASK YOU FOR ONE.

What it involves, concretely. A person on our team reads the approved post, opens the group, puts the approved copy and the approved photos into Facebook's own composer, and presses Facebook's own publish control. It is manual work, done one post at a time, by a person whose name we record. Where we build tooling to help that person, it prefills approved content and stops there — we do not run software that publishes by itself, and we do not simulate human behavior to get around a platform's controls. If any of that changes, this section changes before it ships, and it will still never involve your credentials.

What data it touches. The same material you already gave us: the approved copy, the photos selected for that post, your business name and contact details, and the group it goes into. Publishing puts that content on Facebook, which is the point of the service. It does not give us anything new about you, and it does not give us anything about the people in the group.

What we record. Which prepared post went out, into which group, when, the link to it if we captured one, and which of our people published it. We keep that as our own record of work performed — it is how both of us can tell what was delivered.

Replies. When we publish, our operator may see replies to that post before you do. What becomes a record does not change: we note how many replies there were, and a person becomes a record in our system only when they contact you. Section 5 governs that, in both modes.

Taking a post down. If you published it, it is on your account and only you can delete it — we never had access to the account that posted it. If we published it for you, tell us and we will take it down, though a group's own moderators ultimately control what stays in their group.

Stopping. Tell us to pause or stop posting and we stop queuing and performing publishing work for your account until you tell us to resume. That is a change to the service, not to your data: it deletes nothing, it is not a cancellation, and it does not entitle you to a refund, credit, or proration. Deletion is section 18; cancellation is governed by the Terms.

If you are a business that buys the Service, we collect:

• Identifiers and account data: your name, email address, phone number, business name, billing and contact emails, account IDs, login and session records, and similar identifiers.
• Commercial information: plan selected, term length, billing cycle, invoices, payment status, territory and zip code selections, support tickets, and purchase history.
• Payment information: payment method details are processed by our payment processor, Stripe. We do not store full payment card numbers on our servers. We may store tokenized references, card brand, last four digits, and expiration month and year.
• Onboarding and creative content: project photos, team photos, bios, your story, service descriptions, website URLs, promo preferences, towns and zip codes served, and related materials you upload. We use these to build your voice profile and draft posts that sound like you.
• Content and approval records: the drafts we prepared for you, your approvals, edit requests, and rejections, and which packet went out when. We keep these so both of us can tell what was approved and by whom.
• Group membership status: which local groups the posting account has joined or been declined from, so we know where content can go. This is what you tell us or record in the dashboard, or what our own operator records after doing that work for you. Either way it is our own record — we do not read it out of your Facebook account.
• Posting activity: which prepared post was published, into which group, when, the link to it if we captured one, and who published it. Where you publish, this is your own report to us and not an observation of Facebook. Where we publish for you, it is our record of work our own person performed. See section 3.
• Internet and technical data: IP address, browser type, device information, pages viewed, referring URLs, approximate location derived from IP, and diagnostic logs, for our own site and dashboard only.
• Communications: messages you send us through contact forms, email, and support threads, plus related metadata.

Most of this is required to provide the Service. If you decline to provide it, we may not be able to deliver the Service, and that does not entitle you to a refund.

A "Lead" is a person who contacts one of our clients. That is the only way a person's information enters our system.

Leads reach a client in three ways: by commenting on a post the client published, by sending the client a direct message, or by submitting the client's lead form. In each case, the person chose to start the conversation.

Depending on how they reached out, we may receive and store:

• Name, or the name shown on the account they contacted the client from.
• Contact details they provided: phone number, email address, and sometimes a street address or service address.
• Project notes: what they need done, rough scope, timeline, budget range, property details they chose to mention, and any other free text they wrote.
• The source and timestamp of the inquiry — which post, which group, or which form, and when.
• Follow-up status the client records in the dashboard, such as contacted, scheduled, won, or lost, and an estimated job value if the client enters one.

We collect this so we can deliver the Lead to the client and so the client can respond, and so we can measure and improve how well the Service works.

We do not sell Lead information. We do not disclose an identifiable Lead to any other client. We do not use Lead information to market anything to that person on our own behalf. We do not enrich, append, or buy additional data about a Lead.

When a neighbor comments on a client's post, that comment is visible on Facebook because the neighbor posted it there. Where the client published the post, we record the comment only to the extent the client gives it to us or it flows through a lead form. Where we published it for the client, our own operator reads the replies and records how many there were; that person becomes a record here only when they have contacted the client, and a White Glove person logs them deliberately, one at a time. Neither mode monitors groups, and neither one records people who did not reach out.

For Lead information, the client is the business that decides how the data is used, and we handle it on the client's behalf as a service provider. If you are a homeowner with a question or request about your inquiry, email privacy@whitegloveleads.com and we will handle it or route it to the client as the law requires. Section 18 covers your rights.

We collect information directly from clients during onboarding and ongoing use; automatically through cookies and similar technologies on our own site and dashboard; from payment, hosting, and communications providers acting on our behalf; from our own people, who record the work they performed for a client, including a post they published on that client's behalf; and from people who contact a client through that client's lead form or who are passed to us by the client after contacting them directly.

We do not collect personal information from Facebook's platform, from group rosters, from data brokers, or from public-records scraping.

We use personal information broadly, for any purpose compatible with operating and growing the Service, including to:

• Build a client's voice profile and draft, review, and deliver content packets.
• Maintain our database of local groups and each group's rules, and track which groups a client belongs to.
• Deliver Leads to the client that the Lead contacted, and support the client's follow-up in the dashboard.
• Publish approved content on a client's behalf where the client has chosen that, and record what was published, where, when, and by whom. See section 3.
• Process subscriptions, renewals, invoices, cancellations, and payment-related fraud and chargeback prevention.
• Communicate with clients about their account, onboarding, service updates, and support.
• Produce reporting on content volume, approvals, and Lead flow.
• Test, debug, secure, and improve the Service, including reviewing content and account activity to investigate abuse, fraud, and misuse.
• Analyze performance and develop the Service: what post formats, angles, photo types, offers, categories, territories, and pricing work, and why. This includes analysis across all client accounts.
• Create de-identified and aggregated data sets, benchmarks, statistics, research, and new products or features. See section 8.
• Improve our own prompts, templates, archetypes, scoring, and models.
• Market the Service, including case studies, testimonials, before-and-after examples, and sample content. See section 10.
• Enforce our Terms, exercise or defend legal claims, protect rights, property, and safety, and comply with law.

We may use information for any other purpose we describe to you at the time of collection, and for any purpose permitted by law.

We may combine information from different sources and different parts of the Service, and use it together for the purposes above.

We create de-identified and aggregated data from everything that flows through the Service — content performance, Lead volume and timing, group behavior, category and territory patterns, plan and billing trends, and product usage.

De-identified and aggregated data is data that cannot reasonably be used to identify you, your business, or any individual. We may use, retain, publish, license, sell, and otherwise commercialize that data indefinitely, for any purpose, including benchmarks, research, marketing, and building new products. That data is ours.

We maintain the de-identification: we do not attempt to re-identify it, and we require the same of anyone we give it to. A right to delete personal information does not require us to delete de-identified or aggregated data, and it does not require us to rebuild historical data sets.

Leads delivered to a client are for that client's use in responding to the inquiry. We do not sell them and we do not give an identifiable Lead to a competing client while an account is in good standing in a locked service category and zip code.

We analyze Lead data in aggregate and de-identified form to understand and improve how the Service performs. We do not use one client's identifiable Lead data on behalf of another client.

As the business that receives Lead personal information, the client is responsible for how it is used — including complying with the Telephone Consumer Protection Act, CAN-SPAM, and state privacy and telemarketing laws, and any industry rules. Lead data must be used to respond to the inquiry and for lawful follow-up related to that request.

If a client's subscription ends, the Leads they already received remain in their possession and their responsibility. We cannot retrieve or delete data from a client's own systems, and we are not responsible for what a client does with it.

We use the materials a client uploads — photos, story, service details, and the content we prepare from them — to run that client's account, and also to operate, promote, and improve the Service generally.

That includes using client materials, prepared content, results, business name, logo, and account activity in our own marketing: case studies, portfolio and sample content, sales conversations, our website, and social media. The Terms of Service grant us a broad, perpetual, irrevocable, worldwide, royalty-free, sublicensable license in uploaded material, and this Policy describes how we exercise it. The client keeps ownership of what they upload; we own what we create.

It also includes using client materials and prepared content internally to improve our prompts, templates, voice models, quality scoring, and content systems.

IF YOU DO NOT WANT YOUR BUSINESS NAMED IN OUR PUBLIC MARKETING, EMAIL PRIVACY@WHITEGLOVELEADS.COM AND WE WILL STOP USING YOUR NAME, LOGO, AND IDENTIFIABLE PHOTOS IN NEW PUBLIC MATERIAL. WE ARE NOT REQUIRED TO RECALL MATERIAL ALREADY PUBLISHED OR DISTRIBUTED, AND THIS DOES NOT LIMIT OUR USE OF DE-IDENTIFIED OR AGGREGATED DATA.

A client may also tell us to stop using a specific photo in new content, through the dashboard or support, and we will. Posts the client published themselves live on the client's own Facebook account, and we cannot remove them, because we never had access to the account that posted them — the client has to delete those. Posts we published on a client's behalf we will take down on request, subject to the group's own moderators, who control what stays in their group.

By uploading photos and creative materials, a client confirms they have the rights and consents needed for commercial marketing use, including consent from identifiable people and from customers whose homes or projects appear. If an identifiable person in a photo objects to our use of their image, tell us and we will stop using that photo in new material.

We use artificial intelligence to draft content, analyze uploaded photos, and support quality checks. To do that, uploaded photos and business details are sent to a third-party model provider that processes them on our behalf under contract. We currently use xAI's Grok API. We may change providers, and we will keep this section accurate when we do.

Our contracts with model providers are intended to prevent them from using our submissions to train their own general models. We do use our own systems' outputs and your material to improve our own prompts, templates, and models.

Photo analysis produces written descriptions — apparent role, clothing, setting — and groups sightings of the same person by comparing those descriptions. We do not create, store, or compare faceprints, facial-geometry templates, voiceprints, or other biometric identifiers, and we do not use photo analysis to identify anyone outside the material you gave us.

We do not use automated processing to make decisions that produce legal or similarly significant effects about individuals. A human decides what to publish — the client approves the content, and a person publishes it, either the client or a named White Glove operator. A human at the client's business decides who to contact. No software of ours publishes anything or contacts anyone.

We disclose personal information to:

• Service providers and processors, for hosting, cloud storage, databases, security, model and AI processing, analytics, email delivery, customer support tooling, and payment processing, under contracts that limit their use of the data to performing services for us.
• The client and their team: users on a client account receive the Lead and campaign data intended for that business.
• Affiliates, subsidiaries, and entities under common control with us, for the purposes described in this Policy.
• Professional advisors — lawyers, accountants, auditors, insurers — under duties of confidentiality.
• Legal and safety recipients: to comply with law, subpoenas, and lawful requests; to enforce our Terms; to investigate fraud, abuse, or security incidents; and to protect the rights, property, and safety of White Glove Leads, our users, or the public.
• Acquirers and financing parties: in connection with a merger, acquisition, reorganization, financing, due diligence, bankruptcy, or sale of all or part of our assets, personal information is a business asset that may be reviewed and transferred, subject to appropriate confidentiality.
• Anyone else, with your direction or consent.

We may disclose de-identified and aggregated data to anyone, for any purpose, without restriction.

We do not send client or Lead personal information to Facebook or Meta as data: no contact uploads, no custom audiences, no advertising pixel, no app or integration on anyone's account. What does reach Facebook is the post itself — the approved copy, the photos chosen for it, and the business's own name and contact details — because publishing it is the service. Where the client publishes, that happens in the client's own session. Where we publish on the client's behalf, a White Glove person does it from an account we operate, never from the client's. Once a post is up, it and anything a neighbor writes in response are handled by Facebook under Facebook's own policies.

We use a single essential cookie to keep you signed in to whitegloveleads.com and the client dashboard, plus similar technologies needed for security and core functionality. You can control cookies through your browser settings; disabling essential cookies will break login and checkout.

We use server-side logs to understand traffic and product usage. We may add first-party or third-party analytics tools in the future to measure performance and improve the Service.

We do not currently run advertising pixels or cross-site tracking tags, and we do not share personal information for cross-context behavioral advertising. If we adopt any technology that changes that, we will update this Policy, provide the notices required by law, and offer the required opt-out — including a "Do Not Sell or Share My Personal Information" mechanism and Global Privacy Control support where applicable.

Because we do not currently engage in cross-context behavioral advertising, we do not respond to browser Do Not Track signals.

We may send marketing emails to clients and prospective business contacts where permitted by law. Every marketing email includes an unsubscribe link, and you can opt out at any time by using it or by emailing privacy@whitegloveleads.com.

Opting out of marketing does not stop transactional and service messages — billing notices, renewal notices, lead delivery, security alerts, and account and legal notices — which are part of the Service.

We do not send marketing to Leads on our own behalf.

We keep personal information for as long as we have a business or legal reason to keep it. There is no fixed deletion schedule. We decide retention based on: how long an account is active, how long we need the data to provide and improve the Service, applicable tax, accounting, and recordkeeping requirements, the window for chargebacks, disputes, and legal claims, and our security and fraud-prevention needs.

As a floor, and not as a cap: we keep client account, billing, onboarding, content, and approval records while the subscription is active and for at least three (3) years afterward, because they are how we show what was ordered, delivered, and approved. We keep Lead delivery records while the client's account is active and for at least two (2) years after delivery. We keep prospect and marketing records for at least two (2) years from last contact.

We may keep information longer where a law, subpoena, audit, insurance requirement, or active or reasonably anticipated dispute calls for it, and we may keep backup copies until they expire on their normal cycle.

Pausing the Service and cancelling are not deletion requests. Asking us to stop posting stops the work; cancelling stops the billing. Neither one deletes what we hold, and neither one starts a clock against this section. If you want your data deleted, ask us under section 18.

We may retain de-identified and aggregated data indefinitely, as described in section 8. Honoring a deletion request does not require us to delete de-identified or aggregated data, records we are required or permitted by law to keep, or content we created.

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, signed session tokens, access controls, session revocation, and least-privilege practices.

NO METHOD OF TRANSMISSION OR STORAGE IS COMPLETELY SECURE. WE DO NOT GUARANTEE THE SECURITY OF ANY INFORMATION, AND YOU PROVIDE IT AT YOUR OWN RISK. YOU ARE RESPONSIBLE FOR KEEPING YOUR ACCOUNT CREDENTIALS CONFIDENTIAL AND FOR ACTIVITY UNDER YOUR ACCOUNT.

One structural note in your favor: because we never hold Facebook credentials for anyone, a breach of our systems cannot expose a client's Facebook account. There is nothing there to take. That stays true for clients we publish for — we hold no credential of theirs either, which is why section 3 works the way it does.

If a breach affects your personal information, we will notify you and any regulator as required by applicable law.

The Service is directed to businesses and adults. We do not knowingly collect personal information from anyone under 16. If you believe a child provided personal information to us, contact privacy@whitegloveleads.com and we will take appropriate steps to delete it.

Photos are a separate question, because clients sometimes upload family or job-site photos that include children. When our photo review flags a person as likely a minor, that person is excluded from content by default and stays excluded unless the client makes an explicit decision otherwise. Clients must not upload photos of a child without the consent of that child's parent or guardian.

Clients: you can ask us for a copy of the data on your account at any time, and we will provide it in a portable, machine-readable format. That includes your business profile and onboarding materials, your voice profile, your content drafts and approval history, your group list, your Lead records, and your billing history. Standard exports come back within thirty (30) days, usually much sooner.

Clients can also ask us to delete their account data. Email privacy@whitegloveleads.com with the subject line "Delete my data". We will delete or de-identify what we hold, other than records we are required or permitted by law to keep for tax, accounting, fraud-prevention, security, or legal-dispute reasons, and we will tell you what we kept and why. Deletion is not a cancellation — cancel billing separately under the Terms — and it does not entitle you to a refund, credit, or proration.

Leads and other individuals: if you contacted one of our clients and want to know what we hold, correct it, or have it deleted, email privacy@whitegloveleads.com. You do not need an account with us. Tell us the business you contacted and roughly when, so we can find you. We will verify you, honor the request as the law requires, and tell the client about the request. Because the client is the business that decides how your information is used, we may also route your request to them.

California residents (CCPA/CPRA): you have the right to know what personal information we collect, use, disclose, and retain; to access a copy; to correct inaccurate information; to delete personal information, subject to statutory exceptions; to limit the use of sensitive personal information; to opt out of sale or sharing; and to non-discrimination for exercising your rights.

We do not sell personal information and we do not share it for cross-context behavioral advertising, so we do not currently offer a "Do Not Sell or Share My Personal Information" link. We do not collect sensitive personal information for the purpose of inferring characteristics, so there is nothing to limit. If either practice changes, we will update this Policy and provide the required mechanism before we begin.

Categories of personal information we have collected in the last 12 months: identifiers; commercial information; internet and other electronic network activity; geolocation approximated from IP; audio, electronic, and visual information (photos clients upload); professional and employment-related information; and inferences drawn from the above, used only to operate and improve the Service. The sources, business purposes, and categories of recipients for each are described in sections 4 through 12. We disclose each of these categories to service providers, and we may disclose all of them in a business transfer.

Residents of other states with comprehensive privacy laws — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others as they take effect — have comparable rights of access, correction, deletion, portability, and opt-out, along with a right to appeal a denial. To appeal, reply to our decision with the word "Appeal" and we will respond within the time your state's law allows. If we deny your appeal, your state attorney general may accept a complaint.

To exercise any right, email privacy@whitegloveleads.com with the subject line "Privacy Request" and enough detail for us to verify your identity and locate your data. We respond within the timeframes required by law. You may use an authorized agent where permitted; we may require proof of authorization and may still verify you directly. We will not discriminate against you for exercising privacy rights.

We are a United States business. We store and process personal information in the United States, and our service providers may process it in the United States and other countries.

If you access the Service from outside the United States, you understand and agree that your information will be transferred to and processed in the United States, where privacy laws differ from and may offer less protection than those in your country. The Service is not offered to, and is not intended for, individuals in the European Economic Area, the United Kingdom, or Switzerland, and we do not undertake to comply with the GDPR.

Our site links to third-party sites, and content we prepare is published on Facebook — by the client, or by us on the client's behalf. Those platforms are governed by their own privacy policies and terms, and we are not responsible for them or for what they do with your information. Your Facebook account, your membership in a group, and what a group's moderators do with a post are between you and Facebook, not us.

We may update this Privacy Policy at any time and at our sole discretion. We will post the revised Policy with a new "Last updated" date. For material changes, we will provide additional notice as required by law, such as by email or an in-dashboard notice, and we will obtain consent where the law requires it.

Continued use of the Service after the effective date means you accept the updated Policy. If you do not accept it, stop using the Service; that does not entitle you to a refund.

Privacy questions and requests: privacy@whitegloveleads.com. General support: support@whitegloveleads.com. Legal: legal@whitegloveleads.com. Website: https://www.whitegloveleads.com.