This Privacy Policy describes how The 108 Group, LLC dba “Lead Eagle” (“Lead Eagle,” “we,” “us,” or “our”), a limited liability company organized under the laws of Wyoming, United States, collects, uses, and shares information in connection with the website located at https://leadeagle.io and any related subdomains we operate (the “Website”), and in connection with our products and services, including EagleID, Eagle InMarket, Audience Eagle, Search Eagle, Eagle Ads Management, Eagle Outbound, and Eagle Reactivation (collectively, the “Services”).

Lead Eagle is a marketing technology and data services company. Our Website and Services are designed for, and offered to, businesses and the marketing professionals who represent them. We do not market our Services to consumers, and consumers are not the intended audience of the Website. However, in the course of delivering the Services, we license and make available both business-to-business and consumer marketing data sourced from reputable third-party data suppliers, and this Policy describes how that data is handled and the choices available to individuals.

By accessing or using the Website or the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Privacy Policy, please discontinue use of the Website and Services.

To request a universal opt-out from the data Lead Eagle licenses and makes available, please contact us at [email protected]. See Section 8 (“Your Opt-Out Rights”) for details.

1. Scope of This Privacy Policy

This Privacy Policy applies to:

  • Information we collect from visitors to the Website.
  • Information we collect from prospective and current business clients during the sales, onboarding, and service-delivery process.
  • Information we process and make available in connection with the Services, including business and consumer marketing data licensed from third-party data suppliers.

Different sections of this policy describe these different categories. Where Lead Eagle acts as a service provider to a business client, that client is responsible for its own privacy disclosures to the individuals whose data is processed through the Services. We provide our business clients with the contractual terms, data handling commitments, and tooling needed to support their compliance, but we do not assume responsibility for the privacy practices of our clients on their own websites or in their own marketing campaigns.


2. Information We Collect

2.1 Information you provide directly

When you contact us, request a demo, sign up for a newsletter, place an order, download an eBook, or otherwise interact with the Website, we may collect information you provide directly, including:

  • Name, business email address, business phone number, company name, and job title.
  • Information you submit through web forms, including order details and stated business objectives.
  • Communications you send to us, including email, chat messages, and call recordings (where applicable and disclosed at the time of recording).

We accept, but do not store, credit card numbers for payment processing.

2.2 Information collected automatically

When you visit the Website, we and our service providers may automatically collect technical and usage information through cookies, pixels, server logs, and similar technologies, including:

  • Device and browser information (browser type, operating system, device identifiers).
  • IP address and approximate geographic location derived from IP.
  • Pages viewed, time spent on pages, referring and exit URLs, and other usage analytics.
  • Information collected through analytics and advertising cookies from providers such as Google Analytics, Meta, LinkedIn, and TikTok, subject to your cookie preferences.

2.3 Information processed and made available through the Services

In the course of delivering the Services, we license, process, and make available the following categories of information:

  • Business contact information, including name, business email, business phone, job title, and employer.
  • Professional and firmographic information about the employer organization, including company domain, industry classifications (such as NAICS and SIC codes), employee count, and publicly available business contact information.
  • Consumer marketing data, including name, postal address, telephone number, and email address, organized into interest and demographic categories for marketing use.
  • Online and digital identifiers, including email addresses, hashed or encrypted email addresses, online IDs, IP addresses, device identifiers, connected television (CTV) IDs, and mobile advertising IDs (MAIDs).
  • Online behavior information related to a client’s website or campaign, such as pages visited and content viewed.
  • Marketing-relevant signals, such as inferred professional or consumer interests and indicators of purchase intent derived from online behavior.

This information is sourced from a combination of (a) the client’s own first-party data, (b) Lead Eagle’s licensed and proprietary data sets, and (c) reputable third-party data providers and suppliers from which we have contractual rights to use such data. Third-party sources include consumer-facing companies and services, data compilers, public sources such as census data and other public records, public directories, filings and publications, surveys, and subscriptions, as well as digital and online partners that compile and aggregate opt-in data through campaign deployments, contests, transactions, and affiliate marketing websites, apps, and digital services. Lead Eagle’s data sources are limited to United States persons.

Lead Eagle does not collect or use individual Social Security numbers, banking or financial account information, or information that we know was collected from persons under eighteen (18) years of age.


3. How We Use Information

We use the information described above for the following purposes:

  • To operate, maintain, and improve the Website and the Services.
  • To respond to inquiries, process orders, deliver the Services, and provide customer support.
  • To communicate with prospective and current business clients about Lead Eagle products, updates, offers, and educational content.
  • To create and make available marketing audience categories grouped by common interests, demographics, or preferences (“Data Segments”), which may be offered to marketers for use across online (web and mobile), email, and offline channels.
  • To help marketers reach their own first-party CRM lists and proprietary audiences through display media, email, and direct mail channels.
  • To provide verification, record look-up, anti-fraud, and analytics services.
  • To analyze usage of the Website and the Services in order to improve performance, security, and user experience.
  • To comply with legal obligations, enforce our agreements, and protect the rights, property, and safety of Lead Eagle, our clients, and others.

For email-based services, our agreements require strict compliance with the CAN-SPAM Act and other email best practices, and prohibit illegal, inappropriate, or offensive advertising and content.

Lead Eagle does not use the information described in Section 2.3 to make decisions that produce legal or similarly significant effects on individuals.


4. Cookies and Similar Technologies

The Website, the Services, our service providers, and our clients may use cookies and similar tracking technologies. We use these for purposes including:

  • Strictly necessary cookies that enable core Website functionality.
  • Analytics cookies that help us understand how visitors use the Website.
  • Marketing and advertising cookies that allow us and our advertising partners to measure the performance of advertising and to deliver more relevant advertising.

Cookies are small text files that websites store on a visitor’s device to identify the visitor’s browser or to store information or settings, helping with navigation, remembering preferences, enabling functionality, and supporting analytics and advertising services. Web beacons (also known as pixel tags or clear GIFs) are typically used to show that a webpage or email was accessed or opened, or that certain content was viewed or clicked, and to compile statistics about website usage and campaign performance.

You can manage your cookie preferences through the cookie consent banner displayed on the Website, and you can adjust your browser settings to refuse cookies. Some parts of the Website may not function properly if cookies are disabled.

For users located in California, the European Economic Area, the United Kingdom, or other jurisdictions where applicable law requires it, the Website’s cookie banner is configured to obtain or honor your consent and opt-out preferences as required by law.


5. How We Share Information

We share information in the following circumstances:

5.1 With service providers

We share information with third-party service providers who perform services on our behalf, such as cloud hosting (including Google Cloud, Amazon Web Services, and Microsoft Azure), analytics, email delivery, payment processing, and customer support. These service providers are contractually obligated to handle the information consistent with this Privacy Policy and applicable law, and have no independent right to use or share the information.

5.2 With business clients

Where Lead Eagle delivers Services that produce data outputs (such as lead lists, audience exports, or CRM integrations), we provide those outputs to the business client that engaged us. The client is responsible for the use of those outputs in accordance with applicable law and its own privacy commitments. More specifically, we license personal information to our clients for the purpose of enabling marketing and advertising campaigns, and for identity verification and fraud detection and prevention.

5.3 With business and data partners

We may share data, including business and consumer information and Data Segments, with business and data partners to help provide more tailored advertising and for analytical purposes, and we may share aggregated, de-identified, or business-level information to improve the Services and develop new offerings. Lead Eagle does not share personal information with ad networks (platforms that serve advertising on third-party websites) in a manner that places personal information into those platforms.

5.4 For legal reasons

We may disclose information if we believe in good faith that such disclosure is necessary to comply with a legal obligation, to respond to lawful requests from public authorities, to enforce our agreements, to investigate or prevent illegal activity, or to protect the rights, property, or safety of Lead Eagle, our clients, our employees, or others.

5.5 In a business transaction

If Lead Eagle is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, information may be transferred as part of that transaction, subject to standard confidentiality protections.

5.6 Text/SMS messaging

The 108 Group, LLC dba Lead Eagle sends text message updates and responses to customers about pricing and products offered at leadeagle.io. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. We use information you provide to send and respond to your mobile messages, which includes sharing it with platform providers, phone companies, and other vendors who help us deliver messages. Text messaging originator opt-in data and consent are not shared with any third party. We may disclose information to satisfy legal, regulatory, or governmental requests, to avoid liability, or to protect our rights or property. This section applies to your use of the text message service and does not modify the rest of this Privacy Policy.

5.7 What we do not do

Lead Eagle does not sell personal information to individual consumers. We do not sell client data to third parties outside the scope of the engagement that produced the data, and we do not share or transfer the data outputs of a specific business client engagement with any other client or third party except as directed by the client or as required by law.


6. Self-Regulatory Frameworks and Industry Standards

The third-party data suppliers from which Lead Eagle licenses data adhere to widely adopted self-regulatory standards, including those set forth by the Digital Advertising Alliance (DAA) and the Network Advertising Initiative (NAI). Lead Eagle supports these standards and the opt-out mechanisms associated with them, described in Section 8.

As part of these standards, our data suppliers employ privacy-protective measures for online marketing, including irreversibly hashing personal information into non-human-readable, de-identified form before it is used or shared for ad targeting, segregating databases containing personal information from online browsing data, and avoiding placing personal information into cookies. Our suppliers’ data segments do not work with financial or insurance account information, Social Security numbers, or information about individuals’ health or medical conditions.

[DECISION POINT FOR LEAD EAGLE: Confirm whether Lead Eagle is itself a member or participant in the DAA, NAI, or DMA. If so, this section can state direct membership. If not, keep the current “our data suppliers adhere / we support” framing. Likewise confirm whether the hashing and database-segregation measures are performed by Lead Eagle directly or only by your suppliers, and adjust attribution accordingly.]


7. Data Security and Retention

Lead Eagle and its data suppliers maintain administrative, technical, and physical safeguards designed to protect the information we process, including multiple layers of physical and electronic security. These include:

  • Encryption of data in transit using industry-standard TLS protocols.
  • Encryption of data at rest using modern public key encryption standards, with encryption keys stored securely.
  • Firewall protections and access controls that limit access to data to authorized personnel who need it to perform their job functions.
  • Regular review of our security practices and the practices of our material service providers.

No method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

We retain information for as long as is necessary to provide the Services, meet our legal and contractual obligations, resolve disputes, and enforce our agreements. Client data is retained in accordance with the terms of the applicable client agreement. Where a client relationship terminates, we retain residual client data in accordance with the data retention provisions of the applicable client agreement (typically up to six months) before secure deletion, except where longer retention is required by law. We may retain certain information for products that involve risk, compliance, or anti-fraud measures.


8. Your Opt-Out Rights

8.1 Opting out of Lead Eagle’s licensed data

You may request that Lead Eagle stop using your information in the data we license and make available to our clients. To do so, email [email protected] and include (a) your first and last name and (b) your current postal address. You may also provide other addresses you have lived at during the previous five years, which may help us locate and process your request. We will process your request with our data suppliers.

Opting out in this way will stop Lead Eagle from using the relevant data to help our clients send or tailor ads and content to you through email, direct mail, or online display marketing. It will not opt you out of our clients’ separate databases or the databases of other companies we work with, so those companies may still send ads, offers, and content to you. We may retain certain information for risk, compliance, or anti-fraud purposes.

[DECISION POINT FOR LEAD EAGLE: A working consumer opt-out is the most legally sensitive item for a data reseller. Decide whether to (a) name the upstream supplier’s universal opt-out address for a true source-level opt-out, or (b) commit in writing to forwarding opt-out requests to your suppliers. Option (b) is reflected above and keeps the supplier unnamed.]

8.2 Opting out of online and mobile ad targeting

To opt out of third-party ad platforms and ad networks more broadly, including ones we and our suppliers work with, you can use the opt-out pages offered by the DAA’s AboutAds program (https://optout.aboutads.info) and the Network Advertising Initiative (https://optout.networkadvertising.org).

These opt-outs set one or more opt-out cookies on your browser or device. They will not stop you from seeing ads, but in many cases they will stop participating companies from customizing ads based on inferences about your interests. These opt-outs are browser-specific and device-specific, so if you change browsers, use another device, or clear your cookies, you will need to opt out again.

8.3 Mobile device identifiers

To control mobile ad targeting, visit the privacy settings on your device and select “Opt out of Ads Personalization” or “Opt out of interest-based ads” (Android) or “Limit Ad Tracking” / disable “Allow Apps to Request to Track” (Apple iOS). This limits the collection of information used for advertising by third parties.


9. Your Privacy Rights

9.1 General rights

Depending on your jurisdiction, you may have rights with respect to the personal information we hold about you, including:

  • The right to know or confirm whether we are processing personal information about you.
  • The right to access and portability of the personal information we have collected.
  • The right to deletion of personal information we have collected, subject to certain exceptions.
  • The right to correction of inaccurate personal information.
  • The right to opt out of the sale or sharing of personal information, or of processing for targeted advertising.
  • The right to restrict or object to certain processing activities.

You may exercise these rights, where applicable, by contacting us at the address in Section 12. We will verify your identity before responding, which may require that you provide additional information to confirm your identity. We will respond within the timeframe required by applicable law (generally within 30 to 45 days). We may deny a request to the extent permitted by law, and if we do so we will inform you of the basis for the denial.

9.2 California residents (CCPA and CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA/CPRA”), provides you with specific rights regarding your personal information, including the right to know what personal information we collect, the right to delete that information, the right to correct inaccurate information, the right to opt out of the sale or sharing of personal information, and the right to limit the use of sensitive personal information.

Where the Services involve cross-context behavioral advertising or other activities that may be classified as “selling” or “sharing” under the CCPA/CPRA, the Website provides an opt-out mechanism through the “Do Not Sell or Share My Personal Information” link in the Website footer and through the cookie consent banner. To exercise CCPA/CPRA rights, please use that link or contact us using the information in Section 12. We will not discriminate against you for exercising your rights under the CCPA/CPRA.

9.3 Residents of other U.S. states

Residents of other U.S. states with comprehensive privacy laws may have rights similar to those described above. As of the date of this Policy, this includes residents of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Texas, Utah, and Virginia. These Additional U.S. State Privacy Disclosures supplement this Policy with respect to residents of those states. We honor verified rights requests from residents of these states consistent with applicable law.

9.4 Residents outside the United States

The Services are intended for businesses and individuals located in the United States. Lead Eagle’s data sources and identity resolution capabilities are limited to United States persons, and we do not solicit business from or target individuals in the European Economic Area, the United Kingdom, or other jurisdictions outside the United States. To the extent any non-U.S. resident submits personal information to the Website, that information will be processed in the United States, and by submitting information you consent to the transfer of your information to the United States.


10. Sensitive Information, Children, and Health Data

Lead Eagle does not offer Data Segments that contain or identify Social Security numbers, financial or insurance account records, health conditions or medical ailments, or data that we know or learn was obtained from children under eighteen (18) years of age. This applies to the data that Lead Eagle itself provides. Our clients, data partners, ad networks, or other platforms with whom we work may use or make available their own, distinct sets of data.

The Website and the Services are intended for a business audience and are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If you believe a child under 18 has provided personal information to us, please contact us using the information in Section 12 and we will take steps to delete that information.


11. Third-Party Websites

The Website may contain links to websites operated by third parties. Lead Eagle is not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party website you visit.


12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date at the top of this Policy and, where appropriate, provide additional notice through the Website or by email. Your continued use of the Website or the Services after any update constitutes your acceptance of the updated Policy.


13. Contact Information

If you have questions about this Privacy Policy, wish to exercise a privacy right, submit an opt-out request, or have a complaint about our privacy practices, please contact us:

  • Email: [email protected]
  • Phone: (707) 329-3313
  • Entity: The 108 Group, LLC dba Lead Eagle
  • Address: 30 N Gould St #39781, Sheridan, WY 82801