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Privacy Policy

Effective Date: July 8, 2025  |  Last Updated: January 20, 2026

WTS Financial d/b/a W.T.S. Lead Center (“W.T.S. Lead Center,” “we,” “us,” or “our”) explains how we collect, use, disclose, and safeguard information when you visit our website or use our services.

This Privacy Policy applies to:

(A) Business Users such as insurance professionals, agencies, and other entities that access our website or use our platform; and

(B) Lead Consumers, meaning individuals whose information appears in lead records processed through our platform.

If you do not agree with this Policy, do not use our website or services.

1. Our Role

W.T.S. Lead Center operates as a marketing technology, CRM, and lead delivery platform. We do not: • Sell insurance to consumers • Act as the caller or sender for independent agents • Control or determine the legality of agents' communications • Guarantee the existence, scope, or sufficiency of consumer consent Independent business customers determine whether and how to contact leads and are solely responsible for compliance with applicable laws.

2. Information We Collect

2.1 Information Provided by Business Users

We may collect: • Name, business name, email, phone number, mailing address • Account credentials, settings, and configuration data • Billing details and transaction history (payments processed by third parties) • Communications with support or onboarding teams

2.2 Information Collected Automatically

When you access our site or platform, we may collect: • IP address, browser/device type, operating system • Referring URLs, page views, timestamps, session data • Cookies, pixels, SDKs, and similar technologies (see Section 7)

2.3 Lead Data (Lead Consumers)

For lead delivery services, we may receive and process information from third-party sources, which may include: • Name, phone number, email address • Geographic information (state, ZIP) • Timestamp, IP address, form identifier • Consent or opt-in metadata, where provided by the source Lead Data is provided as received from third-party sources and may vary by campaign, publisher, jurisdiction, and time.

3. How We Use Information

We use information to: • Provide and operate the platform and CRM services • Deliver leads to authorized business customers • Process payments and manage subscriptions • Provide onboarding, service, and security communications • Improve platform performance, analytics, and reliability • Detect fraud, abuse, or violations of our Terms of Service • Comply with legal obligations and enforce agreements • Market W.T.S. Lead Center services to Business Users, subject to applicable law

4. How We Disclose Information

4.1 Service Providers

We disclose information to vendors that support our operations, including: • Hosting and CRM infrastructure • Communications delivery (calling, SMS, email) • Payment processing • Analytics and security services These providers may access information only to perform services on our behalf and are required to protect it.

4.2 Lead Delivery to Business Customers

When Business Users purchase lead delivery services, Lead Data is delivered into the customer's platform location so the customer may evaluate and contact consumers regarding insurance-related inquiries. Under certain state privacy laws (including California), this disclosure may be classified as a "sale" or "sharing" of personal information depending on the specific facts and the customer's use of the data. Where required by law, consumers may exercise opt-out rights described below.

4.3 Analytics and Advertising Partners

We may disclose device identifiers and site interaction data to analytics and advertising partners for measurement, attribution, and audience building. We do not disclose Lead Consumer contact data for third-party marketing.

4.4 Legal and Safety

We may disclose information as required by law, legal process, or to protect rights, safety, and security.

4.5 Corporate Transactions

Information may be transferred as part of a merger, acquisition, financing, reorganization, or sale of assets.

5. Communications

5.1 Service Communications (Business Users)

We may send operational communications related to: • Account setup and onboarding • Security alerts • Lead delivery • Billing and payments • Platform updates and support

5.2 Marketing Communications (Business Users)

We may send promotional emails about W.T.S. Lead Center services. You may unsubscribe at any time using the link provided or by contacting support@wts-financial.com.

5.3 Text and Call Communications

Any statement in this Policy regarding consent for calls or texts applies only to communications sent directly by W.T.S. Lead Center. Independent business customers are solely responsible for obtaining, maintaining, and honoring any consent required for their own calls, texts, emails, or other outreach.

6. Business Customer Compliance Obligations

Business Users who receive Lead Data are solely responsible for compliance with all applicable laws and regulations, including: • TCPA and state telemarketing laws • National and state Do-Not-Call rules • CAN-SPAM • Call recording consent laws • Insurance licensing and advertising rules • Carrier and platform messaging policies W.T.S. Lead Center does not provide legal advice and does not determine whether a particular outreach is lawful.

7. Cookies, Pixels, and Advertising Controls

7.1 Cookies and Pixels

We use cookies and pixels (including Meta/Facebook Pixel and similar tools) to: • Measure advertising performance • Analyze site usage • Improve platform functionality

7.2 Cookie Controls

You can manage cookies through your browser settings. Disabling cookies may limit site functionality.

7.3 Opt-Out of Sale/Share and Targeted Advertising

Where required by law (including California), consumers may opt out of the sale or sharing of personal information by emailing support@wts-financial.com. We honor valid Global Privacy Control (GPC) signals where required.

8. California Privacy Rights

California residents may have rights to: • Know/access personal information • Delete personal information (subject to legal exceptions) • Correct inaccurate personal information • Opt out of sale or sharing • Not be discriminated against for exercising rights Requests may be submitted via email at support@wts-financial.com. We verify requests as required by law and respond within applicable timeframes.

9. How Lead Consumers May Stop Contact

Lead Consumers may: • Reply "STOP" to text messages • Use unsubscribe links in emails • Request placement on an agent's internal Do-Not-Call list • Register with the National Do-Not-Call Registry Because independent business customers control their own outreach, W.T.S. Lead Center does not control all communications but will make commercially reasonable efforts to assist or direct requests appropriately.

10. Data Retention

We retain information as reasonably necessary to: • Provide services • Meet legal obligations • Resolve disputes • Enforce agreements • Maintain security and prevent fraud Retention periods vary by data type and legal requirements.

11. Data Security

We implement commercially reasonable safeguards, including encryption in transit, access controls, and monitoring. No system is perfectly secure. Business Users are responsible for safeguarding account credentials.

12. International Transfers

We are U.S.-based. Information may be processed in the United States and other jurisdictions.

13. Children's Privacy

Our services are not directed to children under 13. We do not knowingly collect personal information from children.

14. Updates to This Policy

We may update this Policy from time to time. The "Last Updated" date reflects the current version. Continued use constitutes acceptance.

15. Contact Information

WTS Financial d/b/a W.T.S. Lead Center Email: support@wts-financial.com Requests, complaints, and opt-out inquiries related to this Privacy Policy should be directed to the email address above.