Privacy Policy

Last updated: June 18, 2026

This Privacy Policy explains how [LEGAL ENTITY NAME] d/b/a Gravitas Leads (“Gravitas Leads,” “we,” “us”) collects, uses, discloses, and protects personal information in connection with our websites (gravitasleads.io, mailer.gravitasleads.io), the Gravitas Leads Mailer Portal, and our data and list-cleaning services (collectively, the “Services”). It also describes the privacy rights available to you and how to exercise them.

1. Our Two Roles

Because we offer two different services, we handle personal information in two different capacities:

  • As a business / “controller.” For our website, marketing, account management, and our Data Products business (the marketing records and leads we license to customers), we determine how and why personal information is processed. In this capacity we may “sell” or “share” certain personal information as those terms are defined under U.S. state privacy laws (see Sections 5 and 7).
  • As a service provider / “processor.” For our List Cleaning & Validation service, we process the lists our customers upload (“Customer Data”) only on the customer’s behalf and per their instructions, to validate and clean the list and return the result. We do not sell Customer Data and do not use it for our own purposes (see Section 4).

2. Information We Collect

2.1 Information you provide:

  • Account & contact information — name, business email, phone, company name, and similar details you submit when you create an account, request information, or contact us.
  • Payment information — processed by our payment processor, Stripe. We do not store full card numbers; we retain limited details such as card brand, last four digits, and expiration.
  • Customer Data you upload for cleaning — the contact lists (e.g., email addresses and associated fields) you submit to the Cleaning Services. See Section 4.
  • Communications — information in your messages, support requests, and form submissions (including the “Advertise with us” form).

2.2 Information collected automatically: device and usage data such as IP address, browser and device type, pages viewed, referring URLs, timestamps, and actions taken in the Services, collected through cookies and similar technologies (see Section 6).

2.3 Information from third parties: for our Data Products business, we obtain consumer records and related personal information from third-party data providers, partners, and publicly available sources. We also receive information from service providers (e.g., analytics and payment providers).

3. How We Use Information

We use personal information to:

  • provide, operate, secure, and improve the Services and process transactions;
  • create and manage accounts, verify email addresses, and authenticate users;
  • perform the Cleaning Services on Customer Data (per Section 4);
  • assemble, maintain, and license Data Products for marketing use by our customers;
  • communicate with you about your account, transactions, and support, and (where permitted) send marketing you can opt out of;
  • detect, prevent, and investigate fraud, abuse, and security incidents; and
  • comply with legal obligations and enforce our agreements.

4. Customer Data You Upload for Cleaning

When you use the Cleaning Services, the lists you upload are processed only to provide the service to you. As between you and us, you are the controller of that data and we act as your processor / service provider. Specifically:

  • we process Customer Data solely to validate, verify, and clean it and return the result to you;
  • we do not sell Customer Data, and we do not use it for our own marketing, to build Data Products, or for any purpose other than providing the Cleaning Services;
  • the validation is performed by our sub-processor, EmailOversight, Inc., which processes the addresses solely to perform validation under documented instructions and applicable privacy law;
  • we retain Customer Data only as long as needed to deliver your result and for limited support and recordkeeping, after which it is deleted or de-identified; you may request deletion at any time (see Section 9 and the contact below).

You are responsible for having a lawful basis and any required consents to upload and process the Customer Data, and for honoring the rights of the individuals in your list.

5. “Sale” and “Sharing” of Personal Information (Data Products)

Our Data Products business involves licensing consumer marketing records to customers. Under certain U.S. state privacy laws (such as the California Consumer Privacy Act, as amended by the CPRA), providing such records to our customers and partners may be considered a “sale” or “sharing” of personal information. The categories of personal information that may be sold or shared include identifiers (such as name, postal address, email, and phone number) and commercial/marketing information.

We do not knowingly sell or share the personal information of consumers we know to be under 16 years of age. You have the right to opt out of the sale or sharing of your personal information — see Section 8 (“Your Privacy Rights”) and the “Do Not Sell or Share” instructions below. Customer Data uploaded for the Cleaning Services is never sold or shared.

6. Cookies & Tracking Technologies

We and our providers use cookies, web beacons, and similar technologies to operate the site, remember preferences, measure usage and performance, and (where applicable) support marketing. Strictly necessary cookies are required for the Services to function. You can control non-essential cookies through your browser settings and, where available, recognized opt-out signals such as Global Privacy Control (GPC). Disabling some cookies may affect functionality.

7. How We Disclose Information

We may disclose personal information to:

  • Service providers / processors that perform functions on our behalf — for example, Stripe (payments), EmailOversight (validation), our cloud hosting and storage provider, and our email delivery provider — under contracts that limit their use of the information;
  • Customers and partners, in connection with the Data Products business (subject to Section 5 and applicable opt-outs);
  • Legal and safety recipients — to comply with law, legal process, or lawful requests, and to protect the rights, safety, and property of Gravitas Leads, our users, or the public;
  • Corporate transactions — a successor or acquirer in connection with a merger, financing, acquisition, or sale of assets.

We do not disclose Customer Data uploaded for the Cleaning Services except to our validation sub-processor to perform the service, or as required by law.

8. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information: to know/access what we collect and how we use and disclose it; to request correction or deletion; to opt out of the sale or sharing of your personal information and of targeted advertising; to limit the use of sensitive personal information; to data portability; and to be free from discrimination for exercising your rights. EEA/UK residents may also have rights to object to or restrict processing and to lodge a complaint with a supervisory authority.

How to exercise your rights. Submit a request by emailing [PRIVACY EMAIL] (or [CONTACT EMAIL]) with the subject “Privacy Request,” or call [CONTACT PHONE]. We will verify your request (and an authorized agent’s authority, if applicable) before responding, and we will not discriminate against you for exercising your rights. If we decline a request, you may appeal by replying to our response.

Do Not Sell or Share My Personal Information. To opt out of the sale or sharing of your personal information, email [PRIVACY EMAIL] with the subject “Do Not Sell or Share,” or use a recognized opt-out preference signal (e.g., GPC). [If you adopt a self-service privacy webform (e.g., a OneTrust request portal), link it here.]

If you are a covered person under a law such as New Jersey’s “Daniel’s Law” or a similar judicial-privacy statute, you may request non-disclosure of protected information using the contacts above.

9. Data Retention

We retain personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Customer Data uploaded for the Cleaning Services is retained only as described in Section 4. When information is no longer needed, we delete or de-identify it.

10. Security

We use appropriate technical, administrative, and organizational measures designed to protect personal information — including encryption in transit, access controls, and a strict content-security policy on our applications. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

11. International Users

We are based in the United States and process and store information in the United States. If you access the Services from outside the U.S., you understand that your information will be processed in the U.S., where data protection laws may differ from those in your country.

12. Children’s Privacy

The Services are intended for business users and are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided us personal information, contact us and we will delete it.

13. Third-Party Links

The Services may link to third-party websites or services we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices.

14. Changes to This Policy

We may update this Policy from time to time. The “Last updated” date above reflects the most recent version. Material changes will be posted here and, where appropriate, notified to you.

15. Contact Us

Gravitas Leads
[BUSINESS ADDRESS]
Privacy: [PRIVACY EMAIL]
General: [CONTACT EMAIL]
Phone: [CONTACT PHONE]