Privacy Policy

Effective Date: May 15, 2026 · Last Updated: May 15, 2026

1. Introduction

This Privacy Policy describes how LeedWallet (“LeedWallet,” “we,” “us,” or “our”) collects, uses, discloses, and “sells” or “shares” (as those terms are defined under applicable privacy laws) personal information when individuals and real-estate investors interact with our websites, online intake funnels, dashboards, APIs, and related services (collectively, the “Services”); when we receive information about prospective borrowers from our referral partner Nation Capital; and when mortgage lenders, brokers, capital providers, or other DSCR loan buyers (“Lead Buyers”) register and use our Services to purchase Leads.

By using the Services or submitting an inquiry, you acknowledge the practices described in this Policy.

2. Scope and Audiences

This Policy covers:

(a) Prospective borrowers and investors (“Consumers”) who submit DSCR loan inquiries through our owned and operated funnels or through Nation Capital and whose information may be transmitted to up to three (3) Lead Buyers;

(b) Lead Buyers who register an account, purchase Leads, and use the Services; and

3. Information We Collect

3.1 Information from Consumers (up to 28 data points per Lead)

When a Consumer submits a DSCR or investment-property loan inquiry, we may collect: full name; email address; mobile and/or landline telephone number; current mailing or residential address; subject property address; property type (single-family, 2–4 unit, condo, short-term rental, or other); estimated AS-IS property value; purchase price (where applicable); requested loan amount (minimum $150,000); loan purpose (purchase, rate-and-term refinance, or cash-out refinance); estimated monthly rental income; estimated annual property taxes; estimated annual insurance; estimated HOA dues; estimated debt-service-coverage ratio (DSCR); estimated loan-to-value (LTV); occupancy designation; entity vs. individual borrower status; entity name; citizenship/residency status (where requested); a credit-score band reflecting a minimum credit floor of 670 verified through a soft credit pull at intake; preferred timeline to close; consent acknowledgments and TCPA disclosure responses; IP address; submission timestamp; provenance metadata (including TrustedForm, Jornaya, or equivalent consent certificate where available); and traffic-source/campaign parameters (UTM data).

A soft credit pull does not affect the Consumer's credit score and does not appear on the Consumer's consumer-report file as an inquiry visible to other lenders.

3.2 Information from Nation Capital and Other Referral Partners

We receive Consumer inquiry information from Nation Capital and other referral or co-registration partners with respect to individuals who submitted DSCR-related inquiries through those partners' channels and consented to onward sharing with LeedWallet and its Lead Buyers.

3.3 Information from Third-Party Verification Services

With Consumer consent obtained at our intake funnels, we (or our service providers) initiate a soft credit inquiry that returns a credit-score band, tradeline summaries, or fraud indicators. We may also use phone-verification, address-verification, and identity/anti-fraud services.

3.4 Information from Lead Buyers

Lead Buyers provide their business contact, billing, licensing identifiers (where applicable), and authorized-user information when they register. We also receive disposition and conversion feedback from Lead Buyers about Leads they purchase.

3.5 Information Collected Automatically

When you use the Services, we and our service providers automatically collect IP address; browser type and version; device identifiers and operating-system information; referring and exit URLs; pages viewed and actions taken; time stamps; cookie, pixel, and SDK identifiers; and similar telemetry.

3.6 Information We Do Not Knowingly Collect

We do not knowingly collect Social Security numbers, government-issued ID numbers, financial-account or card numbers, biometric data, precise geolocation, or special-category data through our public intake funnels.

4. How We Use Information

We use personal information to:

(a) operate, maintain, and improve the Services;

(b) verify Consumer eligibility for DSCR loan products, including the 670+ credit-band and $150,000 minimum-loan-amount floors;

(d) communicate with Consumers about their inquiry, including by phone, SMS, and email (consistent with consents obtained);

(e) bill Lead Buyers, manage Lead Buyer accounts, and provide customer support;

(f) maintain TCPA, FCRA, GLBA, and other regulatory compliance records, including consent certificates and audit trails;

(g) detect, investigate, and prevent fraud, security incidents, and abuse;

(h) perform analytics, reporting, and business operations;

(i) enforce our Terms of Use and other agreements; and

(j) comply with legal obligations and respond to lawful requests.

5. How We Disclose, Sell, and Share Personal Information

5.1 Sales and Sharing to Lead Buyers

We sell Consumer personal information to Lead Buyers for monetary consideration. When a Consumer's inquiry meets our buyer-eligibility criteria, we transmit the data fields described in Section 3.1 to up to three (3) Lead Buyers — typically licensed mortgage lenders, brokers, investors, capital providers, or their authorized agents — each of which pays LeedWallet a flat fee (currently $95 per Lead). Once a Lead has been distributed to three (3) Lead Buyers, the Lead will not be sold or transferred to any additional Lead Buyer. Under the CCPA/CPRA and similar state privacy laws (including the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, and analogous laws), this transfer constitutes a “sale” of personal information and, where applicable cookie- or pixel-based identifiers are involved, may also constitute “sharing” for cross-context behavioral advertising purposes.

5.2 Categories of Personal Information Sold or Shared

In the twelve (12) months preceding the Effective Date, we have sold or shared the following categories of personal information to Lead Buyers and, in the case of advertising/measurement cookies, to advertising partners:

identifiers (name, address, email, phone, IP);
characteristics protected under certain laws (where voluntarily provided);
commercial information (loan, property, and product preferences);
internet or other electronic-network activity information (form-submission metadata);
professional or employment information (for entity borrowers and Lead Buyers);
inferences drawn from the above (e.g., estimated DSCR, eligibility band); and
financial information related to the requested DSCR loan inquiry.

5.3 Other Disclosures

We also disclose personal information to:

(a) service providers and processors acting on our behalf under written contracts that restrict their use of the information — including hosting, analytics, identity-verification, soft-credit-pull vendors, communications platforms, payment processors, fraud-prevention vendors, and consent-documentation services such as TrustedForm or Jornaya;

(b) affiliates under common control with us;

(d) government authorities and other parties where required by law, subpoena, court order, or to protect the rights, property, or safety of LeedWallet, its users, or others; and

(e) acquirers and successors-in-interest in connection with a merger, acquisition, reorganization, financing, bankruptcy, or asset sale.

5.4 Minors

We do not knowingly sell or share the personal information of Consumers we actually know to be under sixteen (16) years of age.

6. Cookies and Similar Technologies

We and our service providers use cookies, web beacons, pixels, SDKs, and similar technologies to operate the Services, remember your preferences, measure performance, attribute marketing, and detect fraud. Categories include strictly necessary, functional, analytics (including Google Analytics), and advertising/measurement cookies.

You can control cookies through your browser settings and through industry opt-out tools offered by the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA). We honor the Global Privacy Control (“GPC”) signal as a valid opt-out of sale and sharing for the browser or device transmitting the signal.

Our websites currently do not respond to “Do Not Track” signals other than GPC.

7. Third-Party Services

We engage third-party service providers including, without limitation:

(a) soft-credit and identity-verification providers for credit-band and fraud screening;

(b) hosting and infrastructure providers for the Services;

(d) communications providers for email, SMS, and voice delivery;

(e) consent-documentation services (such as TrustedForm and Jornaya) for TCPA proof of consent; and

(f) payment processors for Lead Buyer billing.

Their handling of personal information is governed by their respective privacy policies and by the contracts we have in place with them.

8. Data Retention

We retain personal information for as long as needed to fulfill the purposes described in this Policy, including to operate the Services, complete transactions, maintain records required by TCPA, FCRA, GLBA, AML/KYC, tax, and other applicable laws, resolve disputes, and enforce our agreements. As a general matter:

(a) inquiry records and consent metadata are retained for at least five (5) years following submission to evidence TCPA consent;

(b) Lead Buyer account records are retained for the duration of the relationship plus seven (7) years; and

When retention is no longer required, we will delete or de-identify the information.

9. Security

We maintain administrative, technical, and physical safeguards reasonably designed to protect personal information against unauthorized access, use, alteration, or destruction, including encryption in transit, access controls, vendor due diligence, and a written incident-response program. However, no method of electronic transmission or storage is one-hundred-percent secure, and we cannot guarantee absolute security. You provide information at your own risk and should notify us promptly at admin@leedwallet.com if you believe your information has been compromised.

10. Your Privacy Rights

Subject to applicable law and verification of your identity, you may have the following rights with respect to personal information about you:

Right to Know / Access. Confirm whether we process personal information about you and obtain the categories and specific pieces collected, the sources, the purposes, and the categories of third parties to whom we have disclosed, sold, or shared it.
Right to Delete. Request that we delete personal information collected from you, subject to legal exceptions.
Right to Correct. Request correction of inaccurate personal information.
Right to Portability. Receive personal information in a portable, machine-readable format.
Right to Opt Out of Sale or Sharing. Direct us to stop selling or sharing your personal information (see Section 11).
Right to Limit Use of Sensitive Personal Information. Where applicable.
Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.
Right to Appeal. Residents of states that provide an appeal right (including Virginia, Colorado, Connecticut, and Texas) may appeal our decision regarding a privacy-rights request by replying to our response email or by writing to admin@leedwallet.com with “Privacy Appeal” in the subject line.

Authorized Agents. You may designate an authorized agent to make a request on your behalf by providing written authorization. We may require independent verification of your identity.

How to Submit a Request. Send your request to admin@leedwallet.com with the subject line “Privacy Rights Request,” including sufficient detail to verify your identity and route the request. We will respond within the timeframes required by applicable law (generally 45 days, extendable once).

11. How to Opt Out of Sale and Sharing

Because our business model involves selling and sharing personal information with up to three (3) Lead Buyers per inquiry, you may opt out at any time by:

(a) emailing admin@leedwallet.com with the subject “Do Not Sell or Share My Personal Information”;

(b) using the “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” link in our website footer; and/or

An opt-out submitted after we have already transmitted your inquiry to one or more Lead Buyers cannot recall those prior transfers but will prevent future sales or shares of your information by LeedWallet. To stop contact you have already received from a Lead Buyer, you must also contact that Lead Buyer directly and request placement on their internal do-not-call and do-not-contact lists.

12. GLBA Notice for Financial Information

LeedWallet may be a “financial institution” under the Gramm-Leach-Bliley Act (“GLBA”) by virtue of its role connecting Consumers seeking DSCR loans with Lead Buyers. Much of the information collected in connection with a DSCR loan inquiry is “nonpublic personal information” (“NPI”) regulated by the GLBA and the FTC's Privacy Rule and Safeguards Rule.

We disclose NPI to nonaffiliated third parties (the Lead Buyers) for the purpose of allowing them to evaluate and offer financial products to you. You have the right to opt out of this sharing at any time by emailing admin@leedwallet.com or using the opt-out mechanisms in Section 11. We maintain administrative, technical, and physical safeguards as required by the GLBA Safeguards Rule (16 C.F.R. Part 314).

Lead Buyers receiving NPI from LeedWallet are contractually limited under 15 U.S.C. § 6802(c) and 16 C.F.R. § 313.11 to using NPI only in the ordinary course of business to carry out the activity for which the Lead was provided. To the extent GLBA exemptions apply at the data or entity level, certain state-law privacy rights described in Section 10 may not apply to GLBA-regulated information; we honor those rights with respect to information that is not GLBA-exempt.

13. Do Not Call and Do Not Email

If you no longer wish to receive marketing calls, SMS messages, or emails from LeedWallet, you may:

(a) reply “STOP” to any text message from us;

(b) click “unsubscribe” in any marketing email from us; or

Once processed, we will add you to our internal do-not-contact suppression list and cease marketing communications, though we may continue to send transactional or legally required messages. To stop contact from Lead Buyers that have already received your information, you must contact those Lead Buyers directly; LeedWallet is not able to suppress Lead Buyer outreach on their behalf.

14. Children's Privacy

The Services are intended solely for adults aged eighteen (18) or older engaged in real-estate investment activity and are not directed to children. We do not knowingly collect personal information from children under thirteen (13) (or under sixteen (16) for purposes of sale or sharing under applicable state laws). If we learn we have collected such information, we will promptly delete it.

15. International Users and Data Transfers

The Services are operated from, and intended for users located in, the United States. If you access the Services from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, which may have data-protection laws different from those of your jurisdiction. By using the Services, you consent to such transfer and processing. We do not knowingly market to or accept inquiries from residents of the European Economic Area, the United Kingdom, or Switzerland.

16. Lead Buyer Information

This Policy also applies to information we collect from Lead Buyers and their authorized users. We use that information to provision and bill Accounts, deliver Leads, communicate about service updates, perform analytics, prevent fraud, comply with law, and enforce our agreements. We do not “sell” Lead Buyer business contact data in the ordinary course but may disclose it to service providers, affiliates, advisors, government authorities (as required), and acquirers as described in Section 5.3.

17. Changes to This Policy

We may update this Policy from time to time. The “Last Updated” date above indicates the most recent revision. Material changes will be communicated by posting a prominent notice on the Services or, where required by law, by direct notice. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.

18. Contact Us

Questions, requests, or complaints regarding this Privacy Policy or our information practices, including requests to exercise privacy rights or opt out of sale or sharing, should be directed to:

LeedWallet — admin@leedwallet.com