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 business-to-business (B2B) marketing technology and services company. Our 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.
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.
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 on behalf of our business clients in connection with the Services, in our
role as a service provider or data processor.
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).
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 collected through the Services
In the course of delivering the Services to business clients, we may process the following categories of information about individuals who interact with our clients’ websites or marketing campaigns:
• 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.
• Online behavior information related to the client’s website, such as pages visited and content viewed.
• Marketing-relevant signals, such as inferred professional interests and indicators of purchase intent derived from business-related online behavior.
• In limited circumstances, and only where the underlying data was lawfully collected and lawfully made available to us, additional information that may be useful for business marketing
purposes.
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 from which we have contractual rights to use such data. Lead Eagle’s data sources are limited to United States persons and are designed for business-to-business marketing use.
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 deliver business-to-business marketing services on behalf of our business clients, in
accordance with our agreements with those clients.
• 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.
Lead Eagle does not use the information described in Section 2.3 to make decisions that produce legal or similarly significant effects on individuals, and does not use such information for the targeting of consumers in connection with consumer products or services.
4. Cookies and Similar Technologies
The Website uses cookies and similar tracking technologies. Cookies are small data files placed on your device when you visit a website. We use cookies 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 our advertising and to deliver more relevant advertising.
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.
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.
5.3 With business partners
We may share aggregated, de-identified, or business-level information with partners for the purpose of
improving the Services and developing new offerings.
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 What we do not do
Lead Eagle does not sell client data to third parties outside the scope of the engagement that produced the data. 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. Data Security and Retention
Lead Eagle maintains administrative, technical, and physical safeguards designed to protect the information we process. 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.
• 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.
7. Your Privacy Rights
7.1 General rights
Depending on your jurisdiction, you may have rights with respect to the personal information we hold about you, including the right to access, correct, delete, or restrict our use of your personal information, the right to data portability, and the right to object to certain processing activities. You may exercise these rights, where applicable, by contacting us at the address in Section 11.
We will verify your identity before responding to a rights request, 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.
7.2 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 about you, 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.
Lead Eagle does not knowingly sell personal information of California residents in the manner contemplated by the CCPA/CPRA. Where the Services involve cross-context behavioral advertising or
other activities that may be classified as “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 the link referenced above or contact us using the
information in Section 11. We will not discriminate against you for exercising your rights under the CCPA/CPRA.
7.3 Residents of other U.S. states
Residents of other U.S. states with comprehensive privacy laws (including, as of the date of this Policy, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and others) may have rights similar to those
described above. We honor verified rights requests from residents of these states consistent with applicable law.
7.4 Residents outside the United States
The Services are intended for businesses and business contacts 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.
8. Children’s Privacy
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 11 and we will take steps to delete that information.
9. 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.
10. 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.
11. Contact Information
If you have questions about this Privacy Policy, wish to exercise a privacy right, or have a complaint
about our privacy practices, please contact us:
• Email: info (at) leadeagle (dot) io
• Phone: (707) 329-3313
• Entity: The 108 Group, LLC dba Lead Eagle
• Address: [30 N Gould St #39781 Sheridan, WY 8280]