PRIVACY POLICY - Oakland Plumber

Last Updated: October 9, 2025

Effective Date: October 1, 2021

1. INTRODUCTION AND ACCEPTANCE

This Privacy Policy (“Policy”) governs the collection, use, storage, disclosure, and protection of personal information and data by RPH Digital LLC (“Company,” “we,” “our,” or “us”), a Delaware limited liability company with its principal place of business at 8 The Green, Suite A, Dover, DE 19901. This Policy applies to all websites, web pages, mobile applications, and digital properties owned, operated, or controlled by the Company (collectively, the “Services” or “Website”).

By accessing, browsing, or using any of our Services in any manner whatsoever, including but not limited to visiting our Website, submitting any web form, clicking any button, initiating any telephone call, providing any information, or engaging with any feature or functionality of the Services, you (“User,” “you,” or “your”) expressly acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy in its entirety, without limitation or qualification. If you do not agree with any provision of this Policy, you must immediately cease all use of our Services.

This Policy should be read in conjunction with our Terms and Conditions, which are incorporated herein by reference and together constitute the entire agreement between you and the Company regarding your use of our Services.

2. NATURE OF BUSINESS AND SERVICES

2.1 Lead Generation and Referral Services

The Company operates as a lead generation, consumer connection, and referral service platform. We do not directly provide home services, legal services, or any other consumer services advertised or referenced on our Website. Our primary business function is to:

(a) Connect consumers with third-party service providers who may fulfill service requests;

(b) Collect and aggregate consumer inquiry information;

(c) Sell, transfer, license, or otherwise provide consumer contact information and service request data to third-party service providers, marketing partners, call centers, call networks, and affiliated entities;

(d) Facilitate telephone connections between consumers and service providers;

(e) Operate as an affiliate marketing and advertising platform; and

(f) Engage in related data collection, processing, and monetization activities.

2.2 No Direct Service Provision

You expressly acknowledge and agree that:

(a) The Company does not provide, render, or perform any home services, legal services, or other consumer services;

(b) All actual services are provided by independent third-party service providers;

(d) Any service inquiries, quotes, appointments, contracts, or transactions are directly between you and the third-party service provider; and

(e) The Company bears no responsibility for the quality, timeliness, legality, or any other aspect of services provided by third parties.

2.3 No Verification of Service Providers

IMPORTANT DISCLOSURE: The Company does not verify, investigate, validate, warrant, guarantee, or make any representations whatsoever regarding:

(a) The licensure, certification, or professional credentials of any third-party service provider;

(b) The insurance status, bonding status, or financial responsibility of any third-party service provider;

(d) The qualifications, experience, competence, or fitness of any third-party service provider;

(e) The reputation, reviews, ratings, or past performance of any third-party service provider;

(f) The ability or willingness of any third-party service provider to fulfill your service request; or

(g) Any other aspect, characteristic, or quality of any third-party service provider.

It is your sole and exclusive responsibility to conduct appropriate due diligence, verify credentials, check references, confirm licensure and insurance, and make informed decisions regarding any service provider you choose to engage.

3. INFORMATION WE COLLECT

3.1 Personal Information Actively Provided by You

When you use our Services, we collect personal information that you voluntarily and actively provide to us, including but not limited to:

(a) Contact Information: Full legal name, residential address, city, state, ZIP code, telephone number(s) (including mobile, home, and work numbers), email address(es), and any other contact information you provide;

(b) Service Request Information: Detailed description of services needed, preferred service timing, urgency of request, property information, project scope, budget estimates, and any other information relevant to your service inquiry;

(c) Demographic Information: Age, date of birth, gender, occupation, income level, homeownership status, and other demographic data you choose to provide;

(d) Communication Content: Any information, messages, inquiries, feedback, questions, comments, or other content you submit through web forms, email, telephone, text message, or any other communication channel;

(e) Financial Information: In limited circumstances, payment information, credit card details, or other financial data may be collected if you engage in any transaction through our Services;

(f) Identity Verification Information: Government-issued identification numbers, Social Security numbers, or other identity verification data that may be required in certain jurisdictions or for specific service categories;

(g) Preferences and Interests: Your stated preferences regarding services, communication methods, timing preferences, and other preference-related information; and

(h) Any Other Information: Any additional personal information you voluntarily choose to provide through any medium or channel.

3.2 Information Automatically Collected Through Technology

When you access or use our Services, we automatically collect certain information through various tracking technologies, including but not limited to cookies, web beacons, pixels, tags, scripts, local storage, and similar technologies:

(a) Device Information: Device type, model, manufacturer, operating system, version, unique device identifiers, mobile network information, hardware specifications, and device settings;

(b) Browser Information: Browser type, version, language preference, time zone setting, browser plug-in types and versions, and browser configuration;

(c) Usage Information: Pages visited, features accessed, links clicked, buttons pressed, time spent on pages, navigation paths, referral sources, exit pages, click-stream data, scroll depth, and interaction patterns;

(d) Technical Information: Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, timestamp of access, session duration, error logs, crash reports, and system activity;

(e) Location Information: General geographic location derived from IP address, including country, state, city, and approximate latitude/longitude coordinates (we do not collect precise GPS location data unless you explicitly grant such permission);

(f) Cookies and Similar Technologies: We use first-party and third-party cookies, session cookies, persistent cookies, flash cookies, and similar tracking technologies to collect information about your interactions with our Services;

(g) Analytics Data: We use Google Analytics and other analytics platforms to collect aggregated and de-identified information about traffic patterns, user behavior, conversion rates, and website performance metrics; and

(h) Advertising and Marketing Data: Information about your exposure to, interaction with, and response to our marketing and advertising efforts, including ad impressions, click-through rates, and conversion tracking.

3.3 Information from Third-Party Sources

We may collect, receive, or acquire personal information about you from third-party sources, including but not limited to:

(a) Marketing Partners and Affiliates: Information from co-marketing partners, affiliate networks, lead generation partners, and other business collaborators;

(b) Data Brokers and Data Aggregators: Commercially available information purchased or licensed from data brokers, data aggregators, consumer reporting agencies, and similar entities;

(c) Public Records: Information from public records, government databases, regulatory filings, property records, business registries, and other publicly available sources;

(d) Social Media Platforms: Information from social media platforms if you interact with our social media presence or if you link your social media accounts to our Services;

(e) Service Provider Networks: Information from call networks, call centers, service provider networks, and other entities to whom we provide or from whom we receive consumer leads;

(f) Verification Services: Information from identity verification services, fraud prevention services, and similar third-party verification providers; and

(g) Other Third Parties: Any other lawful source from which we may receive information about you in connection with our business operations.

3.4 Aggregated and De-Identified Information

We may create aggregated, anonymized, or de-identified data from the personal information we collect. Such data does not identify you individually and is not considered personal information under this Policy. We may use and disclose such aggregated or de-identified data for any lawful business purpose without restriction.

4. HOW WE USE YOUR INFORMATION

4.1 Primary Business Purposes

We use your personal information for the following primary business purposes:

(a) Lead Generation and Sales: To sell, transfer, license, or otherwise provide your contact information and service request data to third-party service providers, marketing partners, call centers, call networks, affiliated entities, and other parties who may fulfill your service request or offer related services;

(b) Connection Services: To facilitate telephone connections, route phone calls, connect you with service providers, and enable communications between you and potential service providers;

(c) Matching and Referrals: To match your service request with appropriate third-party service providers based on service type, geographic location, availability, and other relevant criteria;

(d) Multiple Provider Contact: To distribute your information to multiple service providers (potentially up to eight or more entities) to maximize your chances of receiving service quotes, information, and assistance;

(e) Revenue Generation: To monetize the information you provide through lead sales, referral fees, commissions, affiliate arrangements, and other business models;

(f) Network Operations: To operate and participate in call networks, lead distribution networks, and partner networks that facilitate consumer-provider connections; and

(g) Business Development: To develop, expand, and optimize our lead generation and referral business operations.

4.2 Operational and Service-Related Purposes

We use your personal information for various operational and service-related purposes, including:

(a) Service Provision: To provide, maintain, operate, and improve our Services;

(b) Request Processing: To process, analyze, and respond to your service requests and inquiries;

(c) Communications: To communicate with you via telephone, email, text message, or other channels regarding your service request, our Services, and related matters;

(d) Customer Support: To provide customer service, technical support, and assistance;

(e) Verification and Validation: To verify the accuracy of information you provide and validate your identity when necessary;

(f) Quality Assurance: To monitor, record, and review telephone calls and communications for quality assurance, training, compliance, and dispute resolution purposes;

(g) Website Functionality: To enable features and functionality of our Website, including form submission, search capabilities, and interactive elements;

(h) Personalization: To personalize your experience on our Website and tailor content to your interests and preferences;

(i) Technical Operations: To maintain, secure, and optimize our technical infrastructure, including servers, databases, networks, and applications; and

(j) Troubleshooting: To diagnose and resolve technical issues, bugs, and errors.

4.3 Marketing and Advertising Purposes

We use your personal information for marketing and advertising purposes, including:

(a) Direct Marketing: To send you promotional materials, marketing communications, newsletters, special offers, and advertisements regarding our Services and the services of third parties;

(b) Telemarketing: To contact you by telephone, including through the use of automated dialing systems, artificial voice, and prerecorded messages, for marketing and promotional purposes;

(d) Text Message Marketing: To send marketing and promotional text messages (SMS/MMS) to your mobile phone;

(e) Targeted Advertising: To deliver targeted, interest-based advertising on our Website and through third-party advertising networks (note: while we currently use Google Analytics for traffic analysis only, we reserve the right to implement remarketing and retargeting in the future);

(f) Campaign Management: To plan, execute, measure, and optimize marketing campaigns across various channels;

(g) Market Research: To conduct market research, surveys, and analysis to better understand consumer needs and preferences; and

(h) Promotional Activities: To conduct contests, sweepstakes, promotions, and special events.

4.4 Analytics and Business Intelligence

We use your personal information for analytics and business intelligence purposes:

(a) Website Analytics: To analyze website traffic, user behavior, engagement metrics, and conversion rates using Google Analytics and similar tools;

(b) Performance Metrics: To measure and analyze the performance of our Services, marketing campaigns, and business operations;

(d) Optimization: To optimize our Services, user experience, conversion funnels, and business processes;

(e) Reporting: To generate internal reports, dashboards, and analytics for business decision-making;

(f) Forecasting: To forecast demand, predict consumer behavior, and plan business operations; and

(g) Competitive Analysis: To analyze competitive dynamics and market positioning.

4.5 Legal, Compliance, and Risk Management

We use your personal information for legal, compliance, and risk management purposes:

(a) Legal Compliance: To comply with applicable laws, regulations, legal processes, court orders, subpoenas, and governmental requests;

(b) Regulatory Requirements: To meet regulatory requirements, including those imposed by federal, state, and local authorities;

(d) Fraud Prevention: To detect, prevent, investigate, and respond to fraud, unauthorized access, security breaches, and other illegal or prohibited activities;

(e) Risk Assessment: To assess and manage business risks, credit risks, and operational risks;

(f) Dispute Resolution: To resolve disputes, claims, and controversies;

(g) Legal Proceedings: To establish, exercise, or defend legal claims and participate in legal proceedings;

(h) Record Keeping: To maintain records for business, accounting, audit, and legal purposes;

(i) Insurance: To obtain, maintain, and process insurance coverage and claims; and

(j) Due Diligence: To conduct due diligence in connection with business transactions, including mergers, acquisitions, and asset sales.

4.6 Other Business Purposes

We may use your personal information for any other lawful business purpose, including:

(a) Business Transactions: To facilitate, evaluate, negotiate, and complete business transactions, including mergers, acquisitions, reorganizations, asset sales, financing, and partnerships;

(b) Corporate Operations: To manage and operate our business, including accounting, recordkeeping, internal administration, and corporate governance;

(c) Professional Advisors: To engage and communicate with our attorneys, accountants, consultants, and other professional advisors;

(d) Investor Relations: To communicate with investors, shareholders, lenders, and other stakeholders;

(e) Employment: To recruit, hire, manage, and communicate with employees, contractors, and service providers;

(f) Vendor Management: To select, engage, manage, and pay vendors, suppliers, and business partners;

(g) Innovation: To research, develop, and implement new products, services, features, and technologies;

(h) Testing: To conduct testing, experimentation, and pilot programs;

(i) Artificial Intelligence: To train, develop, and improve artificial intelligence and machine learning models and algorithms; and

(j) Any Other Purpose: For any other purpose disclosed to you at the time of collection or to which you consent.

5. DISCLOSURE AND SHARING OF YOUR INFORMATION

5.1 Sale and Transfer of Lead Data

CRITICAL DISCLOSURE: The Company’s primary business model involves the sale, transfer, license, and monetization of your personal information. By using our Services, you expressly consent to and authorize the following:

(a) Lead Sales: We sell your contact information and service request data to third-party service providers, contractors, attorneys, medical professionals, and other service professionals who may be able to fulfill your service request;

(b) Multiple Parties: Your information may be sold to, shared with, or transferred to multiple parties simultaneously, potentially including eight (8) or more separate entities for each service request you submit;

(c) Call Networks: We transfer your telephone number and related information to call centers, call routing networks, and telecommunications providers who will contact you on behalf of service providers;

(d) Affiliate Networks: We share your information with affiliate marketing networks, co-marketing partners, and joint venture partners who operate similar lead generation businesses;

(e) Data Monetization: We monetize your information through various business models, including but not limited to per-lead sales, revenue sharing arrangements, subscription fees, licensing agreements, and commission-based referrals;

(f) Repeated Sales: We may sell or share your information multiple times to different parties for the same or different service requests, and we may continue to sell or share your information even after you have engaged a service provider;

(g) Information Aggregation: Your information may be aggregated with information from other users and sold or licensed as compiled datasets to third parties for marketing, research, and business intelligence purposes; and

(h) Broad Distribution: Once your information is sold or transferred to third parties, we have no control over how those third parties use, share, or further disclose your information, and they are not bound by this Privacy Policy.

5.2 Service Providers and Business Partners

We share your personal information with various service providers and business partners who assist us in operating our business:

(a) Technology Providers: Hosting providers, cloud computing services, database management services, software-as-a-service providers, and technology vendors;

(b) Analytics Providers: Google Analytics and other analytics platforms that help us understand website traffic and user behavior;

(c) Marketing Service Providers: Email service providers, SMS/text message platforms, marketing automation tools, and advertising technology providers;

(d) Telecommunications Providers: Call routing services, phone number provisioning services, telephony platforms, and voice-over-IP (VoIP) providers;

(e) Payment Processors: Payment gateways, merchant services, and financial technology providers (if applicable);

(f) Customer Service Providers: Call center operators, customer support platforms, and chatbot services;

(g) Data Enhancement Services: Data appending services, data enrichment providers, and consumer verification services;

(h) Professional Service Providers: Attorneys, accountants, auditors, consultants, and other professional advisors;

(i) Administrative Service Providers: Document management services, recordkeeping services, and administrative support vendors; and

(j) Security Providers: Cybersecurity services, fraud detection services, and security monitoring providers.

5.3 Advertising and Marketing Partners

We share your personal information with advertising and marketing partners:

(a) Advertising Networks: Third-party advertising networks and platforms that may display our advertisements or that facilitate advertising activities;

(b) Social Media Platforms: Social media advertising platforms (e.g., Facebook, Instagram, LinkedIn) for advertising purposes;

(d) Retargeting Providers: While we do not currently use retargeting, we reserve the right to share information with retargeting and remarketing platforms in the future;

(e) Co-Marketing Partners: Companies with whom we engage in joint marketing initiatives, co-branded offerings, or collaborative campaigns; and

(f) Sponsors and Event Partners: Sponsors of our events, promotions, contests, or sweepstakes, and their marketing partners.

5.4 Corporate Transactions

We may disclose or transfer your personal information in connection with corporate transactions:

(a) Mergers and Acquisitions: To prospective or actual acquirers, merger partners, investors, or their advisors in connection with any merger, acquisition, consolidation, or purchase of business assets;

(b) Asset Sales: To buyers or transferees in connection with the sale, transfer, or disposition of all or any portion of our business or assets;

(c) Corporate Reorganization: To entities involved in any reorganization, restructuring, dissolution, or other corporate transaction;

(d) Financing Transactions: To lenders, investors, financial institutions, and their advisors in connection with financing, investment, or lending transactions;

(e) Bankruptcy or Insolvency: To trustees, receivers, administrators, or similar parties in any bankruptcy, insolvency, receivership, or similar proceedings;

(f) Due Diligence: To parties conducting due diligence in connection with any potential or actual corporate transaction; and

(g) Successor Entities: To any successor entity or acquiring party, who will have the right to continue using your personal information in accordance with this Policy or as otherwise permitted by law.

5.5 Legal and Regulatory Disclosures

We may disclose your personal information when we believe disclosure is necessary or appropriate:

(a) Legal Obligations: To comply with applicable laws, statutes, regulations, rules, ordinances, and legal obligations;

(b) Legal Process: To respond to subpoenas, court orders, legal process, warrants, discovery requests, and governmental demands;

(c) Regulatory Authorities: To cooperate with regulatory authorities, law enforcement agencies, governmental bodies, and administrative agencies;

(d) Legal Rights: To establish, exercise, enforce, or defend our legal rights, claims, and interests;

(e) Protection of Rights: To protect our rights, property, operations, employees, agents, customers, and users;

(f) Safety and Security: To protect the safety, security, and well-being of any person or the general public;

(g) Fraud and Crime: To detect, prevent, investigate, or take action regarding fraud, illegal activities, suspected or actual criminal conduct, or violations of our policies;

(h) Emergency Situations: To respond to emergency situations that threaten the life, health, or safety of any person; and

(i) Legal Advice: To obtain legal advice from our attorneys regarding our legal rights and obligations.

5.6 Consent-Based Disclosures

We may disclose your personal information to any party with your express consent or at your direction. Such consent may be obtained at the time of collection, subsequently during your use of our Services, or through your acceptance of this Privacy Policy.

5.7 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that does not personally identify you with any third party for any lawful purpose, including marketing, advertising, research, analytics, and business intelligence, without restriction and without notice to you.

6. TELEPHONE COMMUNICATIONS AND TCPA COMPLIANCE

6.1 Express Written Consent to Contact

By using our Services in any manner, you provide your express written consent, pursuant to the Telephone Consumer Protection Act (47 U.S.C. § 227) and related federal and state laws, to be contacted by:

(a) The Company (RPH Digital LLC);

(b) Our marketing partners, affiliates, and business associates;

(d) Call centers and call networks with whom we partner; and

(e) Up to eight (8) or more separate entities seeking to provide services or information related to your inquiry.

6.2 Scope of Telephone Consent

Your consent authorizes the above parties to contact you via:

(a) Telephone Calls: Including calls to mobile phones, landlines, residential numbers, and business numbers;

(b) Automated Technology: Calls made using automatic telephone dialing systems (ATDS), autodialers, predictive dialers, or similar automated technology;

(c) Artificial or Prerecorded Voice: Calls using artificial voice, prerecorded voice messages, or automated voice systems;

(d) Text Messages: Short message service (SMS) and multimedia messaging service (MMS) text messages to your mobile phone;

(e) Multiple Attempts: Multiple call attempts, follow-up calls, and subsequent calls over time; and

(f) Any Phone Number: Any telephone number you provide to us, have provided in the past, or associate with your inquiry, even if such number appears on any federal, state, local, or corporate Do Not Call registry or list.

6.3 Marketing and Informational Communications

You expressly consent to receive telephone calls and text messages that are:

(a) Marketing in Nature: Promotional, marketing, advertising, or sales-related communications regarding the services you requested and related services;

(b) Informational: Providing information, quotes, estimates, proposals, and details about services;

(c) Follow-Up Communications: Follow-up calls and messages after your initial inquiry or after you have engaged with a service provider;

(d) Third-Party Offers: Marketing messages on behalf of or from third-party service providers, partners, and affiliates;

(e) Multiple Service Providers: Communications from multiple service providers who may compete with one another to provide services to you; and

(f) Ongoing Communications: Communications that may continue for an extended period unless you affirmatively revoke your consent.

6.4 Acknowledgment of Costs

You acknowledge and agree that:

(a) Standard telephone minute charges and text messaging rates may apply to communications you receive pursuant to this consent, as determined by your mobile carrier or telephone service provider;

(b) You are solely responsible for any and all such charges, fees, and costs;

(d) Message frequency may vary depending on the number of service providers seeking to contact you.

6.5 No Condition of Purchase

You acknowledge that your consent to be contacted is not required as a condition of purchasing any goods or services, and that you may decline to provide consent by refraining from using our Services. However, if you wish to utilize our Services to be connected with service providers, your consent to be contacted is necessary for us to fulfill that purpose.

6.6 Revocation of Consent

You may revoke your consent to be contacted at any time by:

(a) Sending a written request to: compliance@rphdigital.com;

(b) Sending written notice to: RPH Digital LLC, 8 The Green, Suite A, Dover, DE 19901;

(d) Requesting to be placed on our internal Do Not Call list during any telephone call; or

(e) Following any other opt-out mechanism provided in communications you receive.

Please note that:

(i) Revocation of consent is not retroactive and does not apply to communications made prior to your revocation;

(ii) We will process your revocation request within a reasonable time, typically within ten (10) business days;

(iii) Once your information has been sold or transferred to third parties, you must separately contact those third parties to revoke consent for their communications, as we cannot control their use of your information;

(iv) Revoking consent may prevent us from fulfilling your service request or connecting you with service providers; and

(v) Even after revocation, we may still contact you for non-marketing purposes, such as responding to inquiries, providing customer service, or fulfilling legal obligations.

6.7 Call Recording and Monitoring

You expressly consent to the recording, monitoring, logging, and retention of all telephone calls and communications between you and the Company, our partners, or service providers for purposes including:

(a) Quality assurance and training;

(b) Compliance monitoring and regulatory compliance;

(d) Business analytics and performance evaluation;

(e) Legal and evidentiary purposes; and

(f) Any other lawful business purpose.

Recordings may be retained for extended periods and may be disclosed to third parties as described in this Privacy Policy.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Types of Technologies Used

Our Website uses various tracking technologies to collect information about your use of the Services:

(a) Cookies: Small text files placed on your device that store information about your browsing activities, preferences, and settings. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a specified period or until deleted);

(b) Web Beacons (Pixels): Small graphic images or code embedded in web pages and emails that allow us to track page views, email opens, and user behavior;

(c) Local Storage: Technologies such as HTML5 local storage, which allow us to store information locally on your device;

(d) Scripts: JavaScript and other code that runs on your device to collect information and enable functionality;

(e) Flash Cookies (LSOs): Locally stored objects created by Adobe Flash technology;

(f) Device Fingerprinting: Techniques that collect information about your device configuration to create a unique identifier;

(g) ETags: Browser cache validation mechanisms that can be used for tracking purposes; and

(h) Similar Technologies: Any other current or future technologies that serve similar information collection or tracking purposes.

7.2 Purposes of Tracking Technologies

We use tracking technologies for the following purposes:

(a) Essential Operations: To enable basic functionality of our Website, including navigation, form submission, and user authentication;

(b) Performance and Analytics: To collect information about how visitors use our Website, including through Google Analytics, which pages are visited most often, how much time users spend on pages, and navigation patterns;

(d) Security: To identify unusual or suspicious activity, detect fraud, and protect the security of our Services;

(e) Marketing and Advertising: To deliver targeted advertising, measure advertising effectiveness, and optimize marketing campaigns (note: we currently use Google Analytics for traffic analysis only, but reserve the right to implement additional marketing technologies);

(f) Session Management: To maintain your session state and provide a seamless experience across pages;

(g) A/B Testing: To conduct experiments and test different versions of our Website;

(h) Conversion Tracking: To measure whether users complete desired actions such as form submissions or phone calls;

(i) Attribution: To understand which marketing channels and campaigns drive traffic and conversions; and

(j) User Experience Optimization: To improve the design, layout, and functionality of our Website based on user behavior data.

7.3 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to collect and analyze information about the use of our Services. Google Analytics uses cookies and similar technologies to collect information such as:

(a) How often users visit our Website;

(b) What pages users visit and in what sequence;

(d) What links users click;

(e) General demographic information and interests; and

(f) Technical information about devices and browsers.

The information collected by Google Analytics is transmitted to and stored by Google on servers in the United States and other countries. Google uses this information to evaluate website usage, compile reports on website activity, and provide other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required by law or where such third parties process the information on Google’s behalf. Google Analytics may track your activity across different websites and services over time.

For more information about Google Analytics, please visit: www.google.com/policies/privacy/partners/

You may opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at: tools.google.com/dlpage/gaoptout

7.4 Third-Party Tracking

Third parties, including service providers, marketing partners, and advertising networks, may use tracking technologies on our Website or may receive information from our Website. These third parties may collect information about your online activities over time and across different websites and services. We do not control these third-party tracking technologies or how they are used.

7.5 Managing Cookies and Tracking Technologies

You have several options for managing cookies and tracking technologies:

(a) Browser Settings: Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. However, if you disable cookies, some features of our Website may not function properly;

(b) Mobile Device Settings: You can adjust settings on your mobile device to control tracking and advertising features;

(c) Opt-Out Tools: You may use industry opt-out tools such as those provided by the Network Advertising Initiative (www.networkadvertising.org/choices) or Digital Advertising Alliance (www.aboutads.info/choices);

(d) Do Not Track: Some browsers have a “Do Not Track” feature that signals websites that you do not want to be tracked. We do not currently respond to Do Not Track signals; and

(e) Google Analytics Opt-Out: You may install the Google Analytics Opt-out Browser Add-on as described above.

Please note that opting out of tracking technologies may limit your ability to use certain features of our Website and may not prevent the collection of all information.

8. DATA SECURITY AND RETENTION

8.1 Security Measures

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

(a) Access Controls: Limiting access to personal information to employees, contractors, and service providers who have a legitimate business need to access such information;

(b) Authentication: Using passwords, multi-factor authentication, and other authentication mechanisms to verify user identity;

(c) Encryption: Encrypting certain sensitive information during transmission using Secure Socket Layer (SSL) or Transport Layer Security (TLS) technology;

(d) Network Security: Implementing firewalls, intrusion detection systems, and other network security measures;

(e) Physical Security: Restricting physical access to our facilities and servers where personal information is stored;

(f) Vendor Management: Requiring third-party service providers to implement appropriate security measures through contractual obligations;

(g) Security Monitoring: Monitoring our systems for security vulnerabilities and unauthorized access;

(h) Incident Response: Maintaining an incident response plan to address potential security breaches; and

(i) Regular Updates: Regularly updating and patching our systems and software to address known vulnerabilities.

8.2 Limitations of Security

Despite our security measures, you acknowledge and agree that:

(a) No Absolute Security: No method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security of your personal information;

(b) Unauthorized Access: Unauthorized entry or use, hardware or software failure, human error, and other factors may compromise the security of your information at any time;

(c) Third-Party Security: We are not responsible for the security measures implemented by third parties to whom we disclose your information, including service providers, marketing partners, and entities to whom we sell lead data;

(d) User Responsibility: You are responsible for maintaining the confidentiality of any passwords or account credentials and for restricting access to your devices;

(e) Breach Notification: In the event of a data breach, we will comply with applicable data breach notification laws, but the timing and scope of notification may be limited by law enforcement or security considerations; and

(f) No Liability: To the maximum extent permitted by law, we disclaim any liability for any unauthorized access to, disclosure of, or loss of your personal information, except where such disclaimer is prohibited by applicable law.

8.3 Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods depend on various factors, including:

(a) Business Purpose: How long the information is needed for the business purpose for which it was collected;

(b) Legal Requirements: Legal, regulatory, accounting, tax, or audit requirements that mandate retention for specified periods;

(d) User Requests: Whether you have requested deletion of your information and whether we are legally permitted to honor such request;

(e) Service Provider Agreements: Contractual obligations with service providers or partners that may affect retention;

(f) Resale Value: The ongoing value of the information for lead generation, remarketing, or resale to service providers; and

(g) Legitimate Interests: Our legitimate business interests in retaining the information.

In general, we may retain your personal information for:

(i) At least seven (7) years from the date of collection for business records and compliance purposes;

(ii) Indefinitely if the information has been anonymized or de-identified;

(iii) Indefinitely if we have a legitimate business interest in retention and no legal obligation to delete;

(iv) As long as legally required by applicable statutes of limitations, regulatory requirements, or preservation obligations; and

(v) As specified in any applicable state privacy law that grants you deletion rights, subject to exceptions permitted by such laws.

When we no longer need your personal information, we will delete or destroy it in a secure manner, or we will anonymize it so that it can no longer be associated with you. However, we may retain certain information in backup systems, archived records, or as otherwise permitted or required by law.

9. YOUR PRIVACY RIGHTS AND CHOICES

9.1 General Rights

Depending on your jurisdiction and applicable law, you may have certain rights regarding your personal information. These rights may include:

(a) Right to Know: The right to know what personal information we collect, use, disclose, and sell;

(b) Right to Access: The right to request access to the specific pieces of personal information we have collected about you;

(d) Right to Correction: The right to request correction of inaccurate personal information;

(e) Right to Opt-Out of Sale: The right to opt out of the sale of your personal information;

(f) Right to Opt-Out of Sharing: The right to opt out of the sharing of your personal information for targeted advertising;

(g) Right to Limit Use of Sensitive Information: The right to limit the use and disclosure of sensitive personal information;

(h) Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights;

(i) Right to Withdraw Consent: The right to withdraw consent for processing based on consent;

(j) Right to Data Portability: The right to receive your personal information in a portable format; and

(k) Right to Object: The right to object to certain processing activities.

The availability and scope of these rights depend on the laws applicable to your jurisdiction.

9.2 California Residents – CCPA/CPRA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights:

Right to Know and Access

You have the right to request that we disclose:

(a) The categories of personal information we collected about you;

(b) The categories of sources from which personal information was collected;

(d) The categories of third parties to whom we disclose, sell, or share personal information;

(e) The specific pieces of personal information we collected about you; and

(f) If we sold or shared your personal information, the categories of personal information sold or shared and the categories of third parties to whom it was sold or shared.

Right to Deletion

You have the right to request deletion of personal information we collected from you, subject to certain exceptions under California law, including:

(i) To complete the transaction for which the information was collected or fulfill the service requested;

(ii) To detect, protect against, or prosecute security incidents or illegal activity;

(iii) To debug or repair errors;

(iv) To exercise free speech rights or ensure another consumer’s right to free speech;

(v) To comply with legal obligations;

(vi) To use the information internally in a lawful manner compatible with the context in which you provided the information; and

(vii) Other exceptions specified in the CCPA/CPRA.

Right to Correct

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

Right to Opt-Out of Sale and Sharing

You have the right to opt out of:

(a) The “sale” of your personal information (as defined by the CCPA/CPRA); and

(b) The “sharing” of your personal information for cross-context behavioral advertising.

IMPORTANT NOTICE REGARDING SALE OF INFORMATION: Our business model involves the sale and transfer of consumer lead data to third-party service providers. By using our Services, you are expressly consenting to such sale. However, if you wish to opt out of the sale of your personal information going forward, you may submit a request as described in Section 9.5 below.

Right to Limit Use of Sensitive Personal Information

If we use or disclose sensitive personal information for purposes beyond those permitted by the CCPA/CPRA, you have the right to limit such use or disclosure.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights, including by:

(a) Denying you goods or services;

(b) Charging different prices or rates for goods or services;

(d) Suggesting that you will receive a different price, rate, level, or quality of goods or services.

However, we may charge different prices or provide different levels of service if the difference is reasonably related to the value provided by your personal information, or if permitted by law.

California Categories of Personal Information

In the preceding twelve (12) months, we have collected, used, disclosed, and sold the following categories of personal information as defined by the CCPA/CPRA:

Identifiers (name, address, email, phone number, IP address)
Personal information under Cal. Civ. Code § 1798.80(e) (name, address, telephone number)
Commercial information (service requests, inquiries)
Internet or network activity (browsing history, website interactions)
Geolocation data (general location derived from IP address)
Inferences (preferences, interests, characteristics)

We have sold and shared all of the above categories to service providers, marketing partners, call networks, and other third parties for business and commercial purposes as described in Section 5 of this Privacy Policy.

9.3 Other State Privacy Rights

Residents of other states may have similar privacy rights under applicable state laws, including:

Virginia (VCDPA): Virginia residents have rights to access, correct, delete, and obtain a copy of their personal information, as well as to opt out of targeted advertising, sale of personal information, and profiling.

Colorado (CPA): Colorado residents have rights to access, correct, delete, and obtain a copy of their personal information, as well as to opt out of targeted advertising, sale of personal information, and profiling.

Connecticut (CTDPA): Connecticut residents have rights to access, correct, delete, and obtain a copy of their personal information, as well as to opt out of targeted advertising, sale of personal information, and profiling.

Utah (UCPA): Utah residents have rights to access, delete, and obtain a copy of their personal information, as well as to opt out of targeted advertising and sale of personal information.

Other States: Additional states may enact comprehensive privacy laws that grant similar rights to residents. We will update this Privacy Policy as necessary to comply with such laws.

To exercise rights under state privacy laws, please use the contact methods described in Section 9.5 below.

9.4 European Economic Area (EEA), United Kingdom (UK), and Switzerland Residents

If you are located in the EEA, UK, or Switzerland, you may have additional rights under the General Data Protection Regulation (GDPR) or equivalent data protection laws, including:

(a) Legal Basis for Processing: We process your personal information based on:

(i) Consent: When you have provided explicit consent;

(ii) Contract: When processing is necessary to perform a contract with you;

(iii) Legitimate Interests: When we have legitimate business interests that are not overridden by your rights;

(iv) Legal Obligation: When required by law; or

(v) Vital Interests: To protect your vital interests or those of another person.

(b) Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes;

(d) Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your jurisdiction;

(e) Data Transfers: Your personal information may be transferred to and processed in the United States and other countries that may not provide equivalent data protection. We rely on appropriate transfer mechanisms such as Standard Contractual Clauses where required;

(f) Automated Decision-Making: We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you; and

(g) Data Protection Officer: If required, we will appoint a data protection officer who can be contacted at compliance@rphdigital.com.

IMPORTANT NOTE: Our Services are primarily directed at users in the United States. If you are located outside the United States and choose to use our Services, you acknowledge that your information will be transferred to, stored, and processed in the United States in accordance with this Privacy Policy and U.S. law.

9.5 How to Exercise Your Rights

To exercise any of the privacy rights described above, you may:

(a) Email Us: Send a request to compliance@rphdigital.com with the subject line “Privacy Rights Request”;

(b) Mail Us: Send a written request to: RPH Digital LLC Attention: Privacy Rights Request 8 The Green, Suite A Dover, DE 19901

Your request must:

(i) Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information (we may request additional information for verification purposes);

(ii) Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond;

(iii) Include your full name, address, email address, and telephone number; and

(iv) Specify which right(s) you are exercising.

We will respond to verifiable consumer requests within the timeframes required by applicable law, typically:

45 days for CCPA/CPRA requests (with possible 45-day extension)
30 days for GDPR requests (with possible 60-day extension)
Timeframes specified by other applicable state laws

We may deny certain requests as permitted by applicable law, including where:

We cannot verify your identity;
The request is manifestly unfounded or excessive;
An exception applies under applicable law; or
The request conflicts with our legal obligations.

Authorized Agent: You may designate an authorized agent to submit requests on your behalf. The authorized agent must provide proof of authorization, and we may require you to verify your identity directly with us.

Appeal Rights: If we deny your request, you may have the right to appeal the denial under applicable state law. We will provide information about the appeal process in our response to your request.

10. CHILDREN’S PRIVACY

10.1 Age Restrictions

Our Services are not directed to, intended for, or designed to attract individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18 years of age. If you are under 18 years old, do not use our Services, do not provide any information through our Services, and do not submit any forms or contact any phone numbers displayed on our Website.

10.2 Parental Consent

In compliance with the Children’s Online Privacy Protection Act (COPPA) and similar laws, we do not knowingly collect, use, or disclose personal information from children under 13 years of age without verifiable parental consent. If we discover that we have collected personal information from a child under 13 without verification of parental consent, we will delete that information as quickly as possible.

10.3 Reporting Underage Use

If you are a parent or guardian and believe that your child under the age of 18 has provided personal information to us, please contact us immediately at compliance@rphdigital.com, and we will take steps to delete such information from our systems.

11. THIRD-PARTY WEBSITES AND SERVICES

11.1 Third-Party Links

Our Website may contain links to third-party websites, applications, services, or resources that are not owned, operated, or controlled by us. These links are provided for your convenience and reference only.

11.2 No Responsibility for Third Parties

We are not responsible for:

(a) The privacy practices, data collection, content, accuracy, or opinions expressed on any third-party website or service;

(b) The products, services, or business practices of any third party;

(d) Any transactions, communications, or interactions you have with third parties;

(e) The terms and conditions, privacy policies, or practices of any third party; or

(f) Any loss, damage, or harm arising from your use of or reliance on any third-party website, service, or content.

11.3 Third-Party Policies

When you click on links to third-party websites or engage with third-party services, you leave our Website and become subject to the privacy policies and terms of service of those third parties. We strongly encourage you to review the privacy policies and terms of service of any third-party websites or services you visit or use.

11.4 No Endorsement

The inclusion of any link to a third-party website or service does not imply our endorsement, approval, or affiliation with that third party or their website, products, or services.

12. INTERNATIONAL DATA TRANSFERS

12.1 United States Operations

Our Services are operated from the United States. If you are located outside the United States and choose to use our Services or provide information to us, your personal information will be transferred to, stored, and processed in the United States.

12.2 Adequacy of U.S. Data Protection

You acknowledge that the United States may not provide a level of data protection equivalent to that in your jurisdiction. The U.S. legal framework for data protection may differ from your country’s laws, and U.S. government authorities may have access to your personal information under certain circumstances pursuant to U.S. law.

12.3 Consent to Transfer

By using our Services and providing personal information to us, you expressly consent to:

(a) The transfer of your personal information to the United States and other countries where we or our service providers operate;

(b) The storage and processing of your personal information in the United States in accordance with this Privacy Policy and applicable U.S. law; and

12.4 Transfer Mechanisms

Where required by applicable law, we implement appropriate safeguards for international data transfers, which may include:

(a) Standard Contractual Clauses approved by the European Commission or equivalent regulatory authority;

(b) Adequacy decisions by the European Commission or equivalent regulatory authority;

(d) Certification under approved frameworks (such as the EU-U.S. Data Privacy Framework, if applicable and if we obtain certification);

(e) Consent; or

(f) Other legally recognized transfer mechanisms.

However, you acknowledge that such safeguards may not provide protection equivalent to the laws of your jurisdiction.

13. CHANGES TO THIS PRIVACY POLICY

13.1 Right to Modify

We reserve the absolute and unfettered right to modify, amend, revise, update, supplement, or otherwise change this Privacy Policy at any time, in our sole discretion, with or without notice to you. Changes may be necessitated by changes in law, changes in our business practices, the introduction of new services or features, or for any other reason we deem appropriate.

13.2 Notice of Changes

When we make changes to this Privacy Policy:

(a) We will update the “Last Updated” date at the top of this Privacy Policy;

(b) We may (but are not obligated to) provide notice of material changes through:

(i) A prominent notice on our Website;

(ii) Email notification to the email address you have provided;

(iii) Text message notification;

(iv) A pop-up or banner notification when you visit our Website; or

(v) Any other method we deem appropriate.

(c) In some cases, particularly for material changes that expand our rights to use your personal information, we may seek your affirmative consent to the changes.

13.3 Continued Use Constitutes Acceptance

Your continued access to or use of our Services after the “Last Updated” date constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you must immediately stop using our Services. However, please note that any personal information collected prior to changes may remain subject to the previous privacy policy unless you exercise applicable privacy rights such as deletion.

13.4 Review Responsibility

It is your responsibility to periodically review this Privacy Policy for changes. We recommend that you review this Privacy Policy each time you use our Services to ensure you understand our current privacy practices.

13.5 Archived Versions

We may maintain archived versions of prior privacy policies. If you would like to review a previous version of our Privacy Policy, please contact us at compliance@rphdigital.com.

14. DISPUTE RESOLUTION AND ARBITRATION

14.1 Informal Resolution

In the event of any dispute, controversy, or claim arising out of or relating to this Privacy Policy or our collection, use, or disclosure of your personal information (collectively, “Disputes”), you agree to first attempt to resolve the Dispute informally by contacting us at compliance@rphdigital.com and providing a detailed description of the Dispute and the relief sought. We will attempt to resolve the Dispute through good-faith negotiations.

14.2 Binding Arbitration

If the Dispute cannot be resolved informally within sixty (60) days, you and the Company agree that any Dispute shall be resolved through binding individual arbitration in accordance with the following terms:

(a) Arbitration Rules: Arbitration shall be administered by the American Arbitration Association (AAA) in accordance with its Consumer Arbitration Rules then in effect, except as modified by this Privacy Policy;

(b) Location: Arbitration shall take place in New Castle County, Delaware, or at such other location as the parties may mutually agree;

(c) Arbitrator: The arbitration shall be conducted by a single neutral arbitrator selected in accordance with AAA rules;

(d) Costs: Each party shall bear their own costs and expenses, including attorney’s fees, except as otherwise provided by law or the AAA rules. The arbitrator may award costs and attorney’s fees to the prevailing party;

(e) Decision: The arbitrator’s decision and award shall be final and binding, and judgment on the award may be entered in any court having jurisdiction;

(f) Scope: The arbitrator shall have exclusive authority to resolve all Disputes, including disputes regarding the arbitrability of claims and the interpretation, scope, or enforceability of this arbitration provision;

(g) Exceptions: Notwithstanding the foregoing, either party may bring an individual action in small claims court if the claim qualifies, and either party may seek injunctive or equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of intellectual property rights;

(h) No Class Actions: YOU AND THE COMPANY AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY ON AN INDIVIDUAL BASIS AND NOT AS PART OF ANY PURPORTED CLASS, REPRESENTATIVE, OR COLLECTIVE ACTION OR PROCEEDING. THERE SHALL BE NO RIGHT OR AUTHORITY FOR ANY DISPUTE TO BE ARBITRATED ON A CLASS-ACTION BASIS OR TO UTILIZE CLASS ACTION PROCEDURES. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS AND MAY NOT PRESIDE OVER ANY FORM OF CLASS, REPRESENTATIVE, OR COLLECTIVE PROCEEDING.

(i) Waiver of Jury Trial: YOU AND THE COMPANY HEREBY WAIVE ANY RIGHT TO A JURY TRIAL IN CONNECTION WITH ANY DISPUTE.

14.3 Opt-Out of Arbitration

You may opt out of this arbitration provision by sending written notice to RPH Digital LLC, 8 The Green, Suite A, Dover, DE 19901, within thirty (30) days of your first use of our Services. The opt-out notice must state that you are opting out of the arbitration provision, include your name, address, and email address, and be personally signed by you.

14.4 Survival

This arbitration provision shall survive the termination of your use of our Services and any termination of this Privacy Policy.

15. GOVERNING LAW AND JURISDICTION

15.1 Governing Law

This Privacy Policy and any Disputes shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles. The application of the United Nations Convention on Contracts for the International Sale of Goods is expressly excluded.

15.2 Jurisdiction and Venue

To the extent that the arbitration provision above does not apply or is found to be unenforceable, you and the Company agree that any judicial proceeding arising out of or relating to this Privacy Policy shall be brought exclusively in the state or federal courts located in New Castle County, Delaware. You hereby irrevocably consent to the personal jurisdiction and venue of such courts and waive any objection based on inconvenient forum.

15.3 Statute of Limitations

To the maximum extent permitted by applicable law, any claim or cause of action arising out of or related to this Privacy Policy or our privacy practices must be filed within one (1) year after the claim or cause of action arose, or such claim or cause of action shall be forever barred, regardless of any statute or law to the contrary.

16. DISCLAIMERS AND LIMITATIONS OF LIABILITY

16.1 No Warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

(a) “AS IS” Basis: OUR SERVICES AND ALL INFORMATION, CONTENT, AND MATERIALS PROVIDED THROUGH OUR SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED;

(b) Disclaimer of All Warranties: WE EXPRESSLY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, RELIABILITY, TIMELINESS, QUIET ENJOYMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE;