Consumer Data Privacy Notice

NOTICE AT COLLECTION

This Notice applies to you if you are a consumer whose personal information has been collected by Big Daddy Leads for sale to insurance professionals.

This Privacy Notice explains how South Western Consulting Group LLC, doing business as Big Daddy Leads ("Big Daddy Leads," "we," "us," or "our"), collects, uses, discloses, and sells your personal information, and describes your privacy rights under applicable state and federal law.

IMPORTANT: Big Daddy Leads collects and sells consumer personal information to licensed insurance agents, agencies, and brokers who use such information to market insurance products and services. If you do not want your personal information sold for these purposes, you have the right to opt out as described in Section 5 below.

1. WHO WE ARE

Big Daddy Leads is a data licensing company that collects consumer information indicating interest in insurance products and licenses that information to licensed insurance professionals for marketing purposes.

Contact Information:

• Email: dadmin@bigdaddyleads.com
• Phone: (813) 605-1827
• Mail: 6421 N Florida Ave Ste D-787, Tampa, FL 33604
• Website: BigDaddyLeads.com

2. PERSONAL INFORMATION WE COLLECT

2.1 Categories of Personal Information Collected

We collect the following categories of personal information about consumers:

A. Identifiers

• Full name (first and last name)
• Mailing address (street address, city, state, ZIP code)
• Email address
• Telephone number (mobile and/or landline)
• State of residence
• Age or age range
• Unique online identifiers (cookies, device IDs, IP addresses)

B. Demographics

• Age or age range
• State of residence
• Geographic location (city, county, state)

C. Commercial Information

• Records of interest in insurance products (life insurance, Medicare, final expense, IUL, etc.)
• Search history related to insurance products
• Online behavior indicating insurance product interest
• Niche category classification (U65, Veterans, IUL, Final Expense, Medicare, General Life)

D. Internet or Network Activity

• Browsing history related to insurance products
• Search queries for insurance information
• Interaction with insurance-related advertisements
• Website pages visited indicating insurance interest
• Clickstream data
• IP address and device information

E. Geolocation Data

• General geographic location (city, state, region)
• Location inferred from IP address
• State of residence

F. Inferences

• Consumer profiles reflecting insurance product preferences
• Propensity to purchase insurance products
• Behavioral predictions related to insurance shopping
• Derived interest categories

2.2 Sources of Personal Information

We obtain your personal information from the following categories of sources:

A. Third-Party Data Providers

• Data aggregators and data brokers
• Marketing data vendors
• Consumer intent data providers
• Online behavioral data platforms
• Lead generation networks

B. Online Behavioral Data

• Advertising networks and exchanges
• Website publishers and content providers
• Search behavior monitoring services
• Retargeting platforms

C. Public Records

• Publicly available databases
• Government records (where legally accessible)
• Public directories

D. Marketing Partners and Affiliates

• Co-registration networks
• Promotional partners
• Survey providers
• Contest and sweepstakes platforms

E. Directly From Consumers

• Information you provide when you complete online forms
• Information you submit when requesting insurance quotes
• Information you provide through insurance-related inquiries
• Information collected when you interact with insurance advertisements

F. Consumer Transaction and Experience Data

• Records of your interactions with insurance-related content
• Previous insurance inquiry history
• Insurance shopping behavior

2.3 Sensitive Personal Information

We may collect information that is considered "sensitive personal information" under California law, including:

• Precise geolocation (in limited circumstances)
• Account login credentials (if you create an account to manage your preferences)

We do NOT knowingly collect:

• Social Security numbers
• Driver's license numbers
• State identification card numbers
• Passport numbers
• Financial account numbers
• Credit card numbers
• Racial or ethnic origin
• Religious or philosophical beliefs
• Union membership
• Genetic data
• Biometric data
• Health information
• Sex life or sexual orientation information
• Citizenship or immigration status

3. HOW WE USE YOUR PERSONAL INFORMATION

3.1 Business and Commercial Purposes

We use your personal information for the following purposes:

A. Data Licensing and Sales

• Licensing your information to licensed insurance agents and agencies
• Selling consumer lead data to insurance professionals
• Creating targeted insurance prospect lists
• Matching consumers with insurance product offerings
• Facilitating insurance marketing campaigns

B. Data Enhancement and Analysis

• Verifying and validating contact information
• Appending additional data attributes
• Categorizing consumers by insurance interest type
• Creating consumer segments and audiences
• Analyzing consumer behavior patterns
• Improving data quality and accuracy

C. Marketing Analytics

• Measuring effectiveness of data products
• Analyzing conversion patterns
• Optimizing lead generation processes
• Understanding consumer insurance shopping behavior

D. Compliance and Legal Obligations

• Complying with federal and state privacy laws
• Processing consumer rights requests (opt-out, deletion, access, correction)
• Maintaining Do Not Call compliance
• Honoring consumer privacy preferences
• Responding to regulatory inquiries

E. Security and Fraud Prevention

• Detecting and preventing fraudulent data submissions
• Protecting against unauthorized access
• Maintaining data security and integrity

F. Internal Operations

• Maintaining and improving our data systems
• Training and quality assurance
• Customer support for licensed purchasers
• Record-keeping and auditing

3.2 Purposes for Data Sales

Your personal information is sold to licensed insurance professionals who use it for:

• Marketing insurance products (life insurance, Medicare, final expense, IUL, health insurance, etc.)
• Contacting you via telephone, email, SMS/text, or direct mail
• Offering insurance quotes and product information
• Following up on your expressed interest in insurance products
• Building customer relationships in the insurance industry

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

4.1 Sale of Personal Information

WE SELL YOUR PERSONAL INFORMATION.

Big Daddy Leads sells consumer personal information to third parties for monetary consideration. Specifically, we license consumer lead data to:

A. Categories of Third-Party Purchasers:

• Licensed insurance agents (individual agents)
• Insurance agencies and brokerages
• Insurance marketing organizations (IMOs)
• Insurance general agencies (GAs)
• Licensed insurance professionals and entities

B. Categories of Personal Information Sold:

• Identifiers (name, address, phone, email)
• Demographics (age, state)
• Commercial information (insurance interest indicators)
• Internet activity (related to insurance shopping behavior)
• Geolocation data (general location)
• Inferences (insurance product preferences)

C. Frequency and Volume:

• We sell consumer personal information on an ongoing, continuous basis
• Sales occur daily as licensed purchasers place orders
• A single consumer's information may be sold to multiple licensed purchasers

D. Compensation Received:

• We receive monetary payment for consumer personal information
• Pricing varies by data product type and freshness
• Typical pricing ranges from $0.10 to $35.00 per consumer record

4.2 Sharing of Personal Information

In addition to sales, we may share your personal information with:

A. Service Providers:

• Data processing and storage providers
• Data verification and enhancement services
• Email and communication service providers
• Analytics and measurement services
• Security and fraud prevention services
• Technology infrastructure providers

Service providers are contractually prohibited from using your personal information for their own purposes.

B. Business Partners:

• Data co-ops and consortiums (with your consent or as permitted by law)
• Joint marketing partners (where legally permitted)

C. Legal and Regulatory:

• Government agencies and law enforcement (when required by law)
• Regulatory authorities (in response to valid legal process)
• Courts and tribunals (pursuant to subpoena or court order)

D. Business Transfers:

• Potential buyers or investors (in connection with merger, acquisition, or sale)
• Successor entities (if our business is acquired or restructured)

4.3 What We Do NOT Do

We do NOT:

• Sell or share personal information of consumers who have opted out
• Sell or share personal information of minors under 16 years of age without affirmative authorization
• Discriminate against consumers for exercising their privacy rights
• Retain personal information longer than reasonably necessary

5. YOUR PRIVACY RIGHTS AND CHOICES

5.1 Right to Opt-Out of Sale/Sharing

YOU HAVE THE RIGHT TO OPT OUT OF THE SALE OR SHARING OF YOUR PERSONAL INFORMATION.

To exercise this right, you may:

Option 1: Use Our Online Opt-Out Form

• Visit: BigDaddyLeads.com/rights-request
• Complete the online form with your contact information

Option 2: Call Our Toll-Free Number

• Call: (813) 605-1827
• Select the "Opt-Out Request" option
• Provide your name and contact information to our representative

Option 3: Email Us

• Email: dadmin@bigdaddyleads.com
• Subject Line: "Opt-Out Request"
• Include: Your full name, phone number, email address, and mailing address

Option 4: Mail Us

• Big Daddy Leads – Privacy Rights
• 6421 N Florida Ave Ste D-787
• Tampa, FL 33604
• Include: Written statement requesting opt-out with your contact information

Processing Time:

• We will process your opt-out request within 15 business days
• You will receive confirmation once processed
• After opt-out, we will cease selling your personal information going forward

Verification:

• We may ask you to verify your identity by providing information that matches our records
• We do this to protect your privacy and prevent fraudulent opt-out requests

Effect of Opt-Out:

• We will stop selling your personal information to new purchasers
• We will add you to our internal suppression list
• Note: We cannot recall information already sold before your opt-out request was processed
• Licensed purchasers who previously purchased your information remain responsible for honoring your direct opt-out requests to them

5.2 Right to Limit Use of Sensitive Personal Information

If we use or disclose sensitive personal information for purposes other than providing requested services, you have the right to limit such use.

To exercise this right, use the same contact methods listed in Section 5.1.

5.3 Right to Know

You have the right to request that we disclose:

• A. Categories of Information:
  • Categories of personal information collected about you
  • Categories of sources from which we collected your personal information
  • Business or commercial purposes for collecting or selling your personal information
  • Categories of third parties to whom we sell or share your personal information
  • Categories of personal information we sold or shared about you
• B. Specific Pieces of Information:
  • Specific pieces of personal information we have collected about you

How to Exercise:

• Submit a request using any method in Section 5.1
• Specify whether you want categories of information, specific pieces, or both

Verification:

• We will verify your identity before providing information
• We may ask for additional information to confirm your identity

Response Time:

• We will acknowledge your request within 10 business days
• We will respond substantively within 45 calendar days
• If we need additional time, we will notify you and may extend up to 45 additional days

Delivery:

• We will deliver information in a readily usable format
• Information will be provided via mail, email, or secure portal as you prefer

5.4 Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.

How to Exercise:

• Submit a deletion request using any method in Section 5.1
• Specify what information you want deleted (all information or specific categories)

Exceptions – We May Deny Deletion If:

• Necessary to complete a transaction or provide a service you requested
• Required to detect security incidents or protect against fraud
• Required to comply with legal obligations
• Necessary for internal uses reasonably aligned with your expectations
• Required to exercise free speech or ensure another's right to free speech
• Necessary for scientific, historical, or statistical research in the public interest

Effect of Deletion:

• We will delete your personal information from our active databases
• We will direct our service providers to delete your personal information
• Note: We may retain certain information as permitted or required by law

5.5 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

How to Exercise:

• Submit a correction request using any method in Section 5.1
• Specify what information is inaccurate and provide correct information

Verification:

• We will verify your identity
• We may request documentation supporting the correction

Action:

• We will correct inaccurate information if we determine it is indeed inaccurate
• We will notify third parties to whom we sold the information of the correction

5.6 Right to Non-Discrimination

We will NOT discriminate against you for exercising any of your privacy rights, including by:

• Denying goods or services
• Charging different prices or rates
• Providing different quality of goods or services
• Suggesting you will receive different prices or quality of services

5.7 Authorized Agents

You may designate an authorized agent to submit privacy rights requests on your behalf.

Requirements:

• Provide written authorization signed by you
• Verify your identity directly with us
• Provide proof of agent's authority (power of attorney or written permission)

How Authorized Agents Submit Requests:

• Email signed authorization to: dadmin@bigdaddyleads.com
• Or mail to address in Section 5.1
• Include your contact information and specify the request type

5.8 Additional State Rights

Virginia Residents (VCDPA): You have similar rights under the Virginia Consumer Data Protection Act, including rights to access, correct, delete, obtain a copy of your data, and opt out of targeted advertising and sales.

Colorado Residents (CPA): You have rights under the Colorado Privacy Act including access, correction, deletion, portability, and opt-out rights.

Connecticut Residents (CTDPA): You have rights under the Connecticut Data Privacy Act similar to those described above.

Other States: If you reside in a state with consumer privacy laws, you may have similar rights. Contact us to exercise rights available under your state's laws.

6. DO NOT CALL REGISTRY

6.1 Federal Do Not Call Registry

If you have registered your phone number on the Federal Trade Commission's National Do Not Call Registry, licensed insurance professionals who purchase your information from us are required to honor that registration and generally may not call you for telemarketing purposes.

To Register Your Number:

• Visit: www.donotcall.gov
• Call: 1-888-382-1222 (from the phone you want to register)

Important Notes:

• Registration is free
• Your registration remains active permanently unless you cancel it
• However, certain exemptions exist under the Telephone Consumer Protection Act (TCPA) that may permit calls even to registered numbers

6.2 State Do Not Call Lists

Many states maintain their own Do Not Call registries. Check with your state attorney general's office or consumer protection agency to register.

6.3 Direct Opt-Out with Insurance Professionals

Licensed purchasers of your information are required to:

• Maintain their own internal Do Not Call lists
• Honor your requests to be placed on their Do Not Call lists
• Stop calling you if you request they stop

If you receive unwanted calls from an insurance professional who purchased your information from us:

• Ask them directly to place you on their Do Not Call list
• You may also exercise your opt-out rights with Big Daddy Leads (Section 5.1) to prevent future sales

7. RETENTION OF YOUR PERSONAL INFORMATION

7.1 Retention Periods

We retain your personal information for different periods depending on the purpose:

7.2 Deletion and Anonymization

When retention periods expire:

• Personal information is securely deleted using industry-standard methods
• Data may be anonymized so it can no longer identify you
• Deletion ensures information is unrecoverable

8. SECURITY OF YOUR PERSONAL INFORMATION

8.1 Security Measures

We implement reasonable security measures to protect your personal information, including:

A. Technical Safeguards:

• Encryption of data in transit and at rest
• Access controls and authentication systems
• Firewalls and intrusion detection
• Regular security assessments and testing

B. Administrative Safeguards:

• Employee training on data security
• Background checks for personnel with data access
• Incident response procedures
• Regular security policy reviews

C. Physical Safeguards:

• Secure data center facilities
• Access controls to physical locations
• Environmental protections

8.2 Limitations

While we use reasonable security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

8.3 Data Breaches

In the event of a data breach affecting your personal information, we will notify you as required by applicable law.

9. CHILDREN'S PRIVACY

9.1 No Collection from Minors

We do NOT knowingly collect, use, or sell personal information from individuals under 18 years of age.

Our services are directed exclusively to adults interested in insurance products.

9.2 Parental Rights

If you believe we have inadvertently collected personal information from a minor under 18, please contact us immediately at:

• Email: dadmin@bigdaddyleads.com
• Phone: (813) 605-1827

We will promptly investigate and delete such information if confirmed.

10. CHANGES TO THIS PRIVACY NOTICE

10.1 Updates

We may update this Privacy Notice from time to time to reflect:

• Changes in our data practices
• Changes in applicable privacy laws
• New features or services
• Industry best practices

10.2 Notification of Changes

When we make material changes:

• We will update the "Last Updated" date at the top
• For significant changes, we will provide additional notice (email, prominent website notice)
• Changes become effective upon posting unless otherwise stated

10.3 Your Responsibility

We encourage you to review this Privacy Notice periodically to stay informed about how we protect your information.

11. CONTACT US

11.1 General Inquiries

For questions about this Privacy Notice or our privacy practices:

Email: dadmin@bigdaddyleads.com
Phone: (813) 605-1827
Mail: Big Daddy Leads, 6421 N Florida Ave Ste D-787, Tampa, FL 33604

11.2 Privacy Rights Requests

To exercise your privacy rights (opt-out, access, deletion, correction):

• Online Form: BigDaddyLeads.com/rights-request
• Email: dadmin@bigdaddyleads.com
• Phone: (813) 605-1827
• Mail: Big Daddy Leads – Privacy Rights, 6421 N Florida Ave Ste D-787, Tampa, FL 33604

11.3 Response Time

We will respond to all inquiries and requests within the timeframes required by applicable law:

• 10 business days – Initial acknowledgment
• 45 calendar days – Substantive response
• Up to 90 days total – For complex requests (with notification of extension)

12. CALIFORNIA-SPECIFIC DISCLOSURES

12.1 Categories of Personal Information (Past 12 Months)

12.2 Business Purposes for Collection: We collect personal information for the business purposes described in Section 3.

12.3 Commercial Purposes for Collection: We collect and sell personal information for the commercial purpose of licensing consumer lead data to insurance professionals.

12.4 Categories of Sources: We collect personal information from the sources described in Section 2.2.

12.5 Categories of Third Parties – Sales: We sell personal information to licensed insurance agents, agencies, brokerages, and insurance marketing organizations.

12.6 Categories of Third Parties – Sharing: We share personal information with service providers and business partners as described in Section 4.2.

12.7 Retention Periods: We retain personal information as described in Section 7.

12.8 Financial Incentive Programs: We do not offer financial incentive programs related to the collection, sale, or deletion of personal information.

12.9 Metrics (2025 Data)

In 2025:

• We received 0 opt-out requests and fulfilled 0 (100%)
• We received 0 access requests and fulfilled 0 (100%)
• We received 0 deletion requests and fulfilled 0 (100%)
• We received 0 correction requests and fulfilled 0 (100%)

Average response time: 1 day

Note: Metrics will be updated annually.

13. ADDITIONAL NOTICES

13.1 California "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.

To make such a request, contact us at dadmin@bigdaddyleads.com.

13.2 Nevada Residents

Nevada residents have the right to opt out of the sale of certain covered information. While we believe our data practices fall within exemptions under Nevada law, Nevada residents may submit opt-out requests using the methods in Section 5.1.

13.3 Processing Outside Your State

Your personal information may be processed, stored, and transferred outside your state of residence, including to other states and potentially outside the United States.

14. DEFINITIONS

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

"Sale" or "Sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for monetary or other valuable consideration.

"Share" or "Sharing" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising.

"Third Party" means a person who is not a service provider or contractor.

"Service Provider" means a person that processes personal information on behalf of a business pursuant to a written contract.