DRAFT FOR REVIEW - NOT APPROVED FOR PUBLICATION

Draft for internal review only. Contacts, operating procedures and bracketed fields require verification before publication. This is a preview page, not a published policy.

Draft legal page

Privacy Policy

DRAFT FOR REVIEW • Proposed public page • Effective date [APPROVAL DATE — PENDING]

Scope and responsibility

KRussCo LLC ("we," "us" or "our") operates The Lead Toolbox business software and mobile application. This Policy describes how we handle personal information in connection with the app, the supporting website, account administration and support. It should be read with any separate notice provided for a particular feature.

When a business customer uploads or manages its own customers' records through LTB, that business may decide why and how those records are used. We and our platform providers process that information to deliver the service and follow appropriate instructions. If your request concerns a business's customer records, contact that business, or contact us so we can identify the responsible organization. This does not limit any rights you have against us for our own processing.

[PENDING: Confirm the exact store-listed app name, operator and controller/processor relationships. The broader KRussCo policy also covers KevRuss and GrowthRevo; this app-specific draft does not automatically extend app data use to cross-brand marketing.]

Information you provide

Depending on how you use the Service, information may include your name, business name, email, phone, account and role information; contact records and business communications entered into the CRM; appointments and related notes; files or media you upload; billing and transaction information relevant to your account; and support requests and feedback.

Do not include unnecessary sensitive information in support forms or uploads. Payment information may be handled by the payment provider used for the relevant transaction.

[PENDING: Identify the payment providers and the information actually received by LTB. Do not claim that full card details are never stored without confirming the payment architecture.]

Device information and permissions

The mobile app and its providers may process information needed to operate the app, authenticate access and diagnose problems, such as app version, device and operating-system information, identifiers, interaction events and crash reports. The exact categories and purposes must match the app build and enabled services.

[REQUIRED MOBILE DISCLOSURE — PENDING: Confirm and complete the following before publication. These are candidate categories from provider documentation and listings, not declarations that every LTB build collects them.]
  • Contacts: [whether device address-book access is used; information uploaded; purpose; optionality]. CRM contact records and the device address book are different sources.
  • Photos, files and camera: [selection or capture features; information uploaded; recipients and purpose].
  • Microphone and audio: [live calling, voicemail, recordings or transcription; processing and storage].
  • Location: [none, approximate or precise; foreground/background; feature and recipient]. A HighLevel "location" can mean a business sub-account, not device geolocation.
  • Notifications: [push provider, device token use and any message content delivered through push].
  • Diagnostics and analytics: [SDK/provider names, data categories, purposes, user linkage and retention].

We request a device permission only when an enabled feature needs it. You can change permissions in your device settings; disabling a permission may stop the related feature from working.

[PENDING: Confirm the actual runtime prompts, available controls and behavior in both platform builds.]

How information is used

We use information for the disclosed purposes relevant to your interaction: providing the Service; authenticating and managing access; delivering requested communications and integrations; processing account administration and billing; responding to support; maintaining security and investigating abuse; diagnosing and improving operation; and meeting legal obligations. Marketing uses require their own appropriate basis and choices and are not implied by a support or deletion request.

[OPTIONAL AI DISCLOSURE — PENDING: Identify the enabled AI feature, information processed, provider, purpose, retention and any training use. Do not publish a blanket claim either that customer data trains AI or that no provider uses data for training without evidence.]
[OPTIONAL RECORDING DISCLOSURE — PENDING: Identify when calls or meetings are recorded, how participants are notified, available choices, access, use and retention. Do not state that every call is recorded unless verified.]

Sharing and service providers

We use service providers to operate the platform and deliver relevant functions. HighLevel supplies the underlying platform services. Other providers may supply communications, hosting, payments, diagnostics, support or enabled integrations.

[PENDING: Add the verified providers/categories and relevant purposes for this build and site. Do not assert specific subprocessors or SDKs without evidence.]

Information may also be available to authorized members of your business account, shared with an integration at your direction, disclosed to meet lawful requests or protect legal rights and security, or transferred in a business transaction subject to applicable safeguards and notice. We limit operational access to appropriate purposes and require applicable protections from providers.

[ADVERTISING DECISION — PENDING: State accurately whether app or website information is used for targeted advertising, cross-context tracking, sale or sharing under applicable law. The April policy describes advertising and potential sale/sharing; those claims are not adopted here. Do not assert "no sale or sharing" or "no tracking" without evidence. If advertising is present, describe it and implement required choices before use.]

Retention and deletion

We retain personal information only as long as needed for the disclosed purposes, including service delivery, legitimate security and recordkeeping needs, legal requirements and dispute handling. Retention depends on the type of record, customer instructions where applicable and the reason it is held. When no longer needed, information is deleted or de-identified according to the approved process.

[REQUIRED RETENTION SCHEDULE — PENDING: Specify periods or meaningful criteria for account/profile data, CRM records, messages, media, recordings/transcripts, support tickets, diagnostic events, consent records, billing records and backups. Confirm which provider executes deletion and its backup cycle. The April document's specific one-, two-, three- and seven-year periods are not verified operational settings.]

To request account or data deletion, use our deletion page. We verify identity and authority using proportionate measures, explain the scope of the request and process it in accordance with applicable law. Deleting an app or disabling an account is not the same as deleting associated information. Where records must remain, we explain the applicable category and reason and restrict their use as appropriate.

[PENDING: Insert verified expected completion timing and backup handling. Do not promise immediate deletion.]

Security and international processing

We use reasonable administrative and technical measures appropriate to the information and service. No system can guarantee absolute security. Protect your credentials and report suspected misuse through support.

[PENDING: Describe actual encryption, access controls and provider safeguards without unsupported certifications or "100% secure" claims.]

Information may be processed where we and our service providers operate. Where required, we use an applicable lawful mechanism and safeguards for international transfers. Mere use of the Service is not a substitute for a required transfer mechanism or consent.

[PENDING: Confirm the countries and transfer arrangements.]

Your choices and rights

Depending on applicable law and our role, you may be entitled to request access, a copy, correction or deletion; withdraw consent; object to or restrict certain processing; or opt out of applicable sale, sharing, targeted advertising or qualifying automated decisions. You may also have a right to appeal a decision or complain to a regulator. These rights depend on the law that applies to you.

To submit a request, use our privacy rights page. We may ask for information reasonably needed to verify identity, authority and the request, but we will not ask you to send passwords or complete payment-card numbers. We respond within applicable legal timeframes and explain a denial and available review route where required.

[PENDING: Confirm the jurisdictions served and add any mandatory state, national, authorized-agent or appeal disclosures. Do not invent jurisdictions or mandatory procedures.]

You can manage app permissions through device settings and unsubscribe from marketing using the instructions in that communication. Withdrawing marketing consent does not stop necessary service communications.

[CONDITIONAL — PENDING: Add an actual preference-center link and Global Privacy Control treatment only after verifying they work.]

Children and policy updates

The Service is intended for business users and is not directed to children. If you believe a child provided information to us, contact us so we can investigate and take appropriate action.

[PENDING: Customer-uploaded records concerning minors require separate treatment. Adult account eligibility is not proof that no minor's information is processed.]

We will update the effective date when this Policy changes and provide additional notice or obtain consent where required. We will not rely on a policy update alone to authorize a materially different use that requires consent.

Contact

KRussCo LLC • 629 Maple Valley Drive #102, Farmington, MO 63640

Privacy inquiries: legal@theleadtoolbox.com • Telephone: (573) 515-2065

[PENDING: Confirm the current operator, public address, monitored inbox and phone. These are candidates from existing documents, not verified for this app.]