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WIZRD Leads Privacy Policy

Last updated: 2026-07-03 · Version 1.0 (DRAFT for Roy + outside counsel review)

Plain English summary

  • WIZRD Leads runs Facebook and Instagram ads for you and sends you seller leads. To do that, we handle your business information, your Meta ad-account data, and the seller-lead details our ads generate (name, phone, email, property address).
  • We do not sell your personal information. We do not sell or share your leads' information. We never share your mobile number with anyone for their marketing.
  • If you give us your mobile number and agree, we may text you about your account and our service. You can stop anytime by replying STOP.
  • You can ask us what we hold about you, ask us to correct it, or ask us to delete it. Email privacy@wizrdleads.com and we respond within thirty days.
  • We use trusted vendors to run the service (hosting, AI, messaging, payments). They are listed in Section 5. Meta is not one of our vendors; Meta is the platform you advertise on, and Meta has its own privacy policy.

This Privacy Policy explains what personal information Closers Consulting Group, LLC (doing business as WIZRD Leads, referred to as "WIZRD Leads," "we," "us," or "our") collects, why we collect it, who we share it with, and what rights you have. It applies to people who become WIZRD Leads clients, people who fill out a form or book a call on our website, and the seller leads our ads generate for our clients.

It does not cover websites operated by other companies that we link to. It does not cover the separate WIZRD software operated by MetaWiz LLC / ROAS WIZ INC., which has its own privacy policy at metawizrd.com/privacy.


1. Who we are and our role

The WIZRD Leads service is operated by Closers Consulting Group, LLC, a limited liability company formed in the State of [PLACEHOLDER: state of formation. Assume Florida unless told otherwise], with an address at [PLACEHOLDER: CCG registered address]. Closers Consulting Group, LLC is the entity responsible for personal information processed through the Service.

For any privacy question, deletion request, or access request, write to privacy@wizrdleads.com. For legal notice, write to legal@wizrdleads.com. For general help, write to support@wizrdleads.com. [PLACEHOLDER: confirm these inboxes exist and are monitored before publishing.]

Our role, in plain terms. Because WIZRD Leads is a done-for-you advertising agency, not a pure software tool, our role under privacy law is different for different kinds of data:

  • For your client account information (your name, business, email, phone, billing details), we are the controller. We decide how we use it to serve you.
  • For the seller-lead information our ads generate (the seller's name, phone, email, and property details), WIZRD Leads and you act as independent controllers. We determine how the leads are generated, collected through the ad forms, and routed to you; you determine how you follow up with and use those leads after they reach your CRM. Each of us is responsible for our own handling of that data.
  • For data that lives inside Meta's platform, Meta is a separate controller under Meta's own privacy policy. We access it on your authorization to run your campaigns.
  • For the people who opt in on our website to book a call, we are the controller of the contact details they give us.

Section 5 explains the vendors that process data on our behalf.


2. What we collect

We collect the categories below. Each has a purpose and a retention window (Section 9). We do not collect anything outside this list without telling you first.

2.1 Account information

When you become a client or book a call, we collect your name, email address, business name, phone number, and the details you give us about your business and markets. We use this to set up your engagement, communicate with you, and provide the Service.

2.2 Meta ad-account data we access on your behalf

When you connect your Meta ad account, we access the data we need to build, launch, manage, and report on your campaigns through Meta's authorized access (OAuth). This includes ad-account identifiers, campaign structure and performance data, creative assets, the Facebook Pages and lead forms tied to your ads, and the lead-form responses your ads generate. We never receive or store your Meta account password.

2.3 Creative assets

We create and store the ad images, videos, copy, headlines, and lead forms used in your campaigns. If you provide brand assets or content, we store those too.

2.4 Seller-lead information

When your ads generate a lead, we collect the information the seller submits, which typically includes the seller's name, phone number, email address, and property address, along with the seller's answers to your lead-form questions. We route this to your CRM. We handle it to deliver leads to you and to verify the Performance Guarantee; we do not sell it and we do not use it to train any AI model.

2.5 Device and cookie data

When you visit our website, we collect basic device data through cookies and similar technologies, including your IP address, browser type, operating system, the pages you visit, and the actions you take. Section 6 explains our cookie practices.

2.6 Support and communications

When you contact us by email, text, phone, or an in-app widget, we keep a record of the message and our reply. We use it to help you and to improve the Service.

2.7 SMS and call logs

We use a messaging and voice vendor (Twilio) to send and receive texts and, where applicable, calls related to your account and our service. We keep logs of these messages and calls, including the phone numbers, timestamps, and content, to operate the service, confirm delivery, and keep records of consent and opt-outs.

2.8 Payment data

When you pay for the Service, our payment processor ([PLACEHOLDER: Stripe or Whop, confirm]) handles the payment. It receives your billing details and card information. We see your billing email, your plan, and whether a payment succeeded. We never see your full card number or your card security code. Your Meta ad spend does not flow through our payment processor or through us; Meta charges it directly to the payment method in your own Meta ad account.


3. How we use it

We use account information to set up and run your engagement, communicate with you, and bill you. We use Meta ad-account data and creative assets to build, launch, manage, optimize, and report on your campaigns. We use seller-lead information to deliver leads to you and to verify the Performance Guarantee. We use device and cookie data to keep our site secure, fix problems, and improve performance. We use support communications and SMS and call logs to help you, operate the messaging service, and keep consent and opt-out records. We use payment data to process your payments and send receipts.

If you opt in to text messages, we use the mobile number you give us only to send you the account and service messages you agreed to, such as appointment confirmations, reminders, and follow-ups about the Service. Message frequency varies with your account activity, and message and data rates may apply. You can stop these texts at any time by replying STOP, and you can reply HELP for help. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

We do not sell your personal information, and we do not sell or share it for cross-context behavioral advertising. We do not use seller-lead data to build profiles we share outside WIZRD Leads. If we ever want to use your data for a new purpose not covered here, we will tell you first.


4. Controller and processor roles for the agency model

Because we generate and route the seller-lead data, and because we run the ads that create it, WIZRD Leads takes on more responsibility than a pure software tool would. This section sets out who is responsible for what.

  • We are a controller of the seller-lead data we generate and route. We decide what data the ad forms collect, we operate the campaigns that generate it, and we route it to you. We are responsible for handling it lawfully up to the point it reaches your CRM.
  • You are a controller of the seller-lead data once it reaches your CRM. You decide how to follow up with and use it. You are responsible for your follow-up under the TCPA, the FTSA, CAN-SPAM, and other laws (see the Terms). You are also responsible for having a lawful basis and any required disclosures for your own use of that data.
  • We are the controller of your client account data and of the details you give us to run the Service.
  • Meta is a separate controller for data inside its platform.

Where the law treats us and you as joint controllers of the seller-lead data, we each remain responsible for our own use of it, and this policy governs our use. Your own privacy notice governs yours.


5. Who we share with

We share your data only with the vendors we need to run the Service. Each vendor is a subprocessor working under a written contract that requires it to handle your data consistent with this policy, process it only on our instructions, keep it confidential, apply strong security, and support your data-subject rights. Our current vendors are:

  • Anthropic (AI inference that helps generate and analyze campaigns). Under our agreement, your data is not used to train its models.
  • Supabase (managed database that stores account records, campaign metadata, and leads).
  • Vercel (website and application hosting and edge delivery).
  • Railway (backend application and background-job hosting).
  • Clerk (sign-in and authentication; we never see your plain-text password).
  • [PLACEHOLDER: payment processor, Stripe or Whop, confirm] (payment processing; receives billing and card data; we never see your full card number or security code).
  • Resend (transactional email such as receipts and account notices).
  • Twilio (text messaging and voice for account and service communications and consent records).
  • Sentry (error and performance monitoring; personal information is minimized before it reaches this vendor).

[PLACEHOLDER: if WIZRD Leads sends SMS or manages leads through Close CRM or any CRM other than the WIZRD software, add that vendor here and in the A2P records. Confirm whether the sending platform is Twilio directly, Close CRM, or the WIZRD software.]

Most of these vendors process data in the United States. We may add or replace a vendor as the Service evolves; when we make a material change to this list, we will update this policy and, for active clients, give at least thirty days' notice.

We also share data when the law requires it, when we need to defend our legal rights, when it is needed to prevent fraud or protect the security of the Service, or when a court or regulator orders us to. We will tell you first unless we are legally prohibited.

Meta is not our subprocessor. Meta is the platform you advertise on. Your relationship with Meta is governed by Meta's own terms and privacy policy. We access your Meta ad account on your authorization to run your campaigns; Meta is a separate controller of the data inside its platform.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.


6. Cookies, tracking, and Global Privacy Control

We use cookies and similar technologies to keep our website working, to keep you signed in where applicable, to protect against cross-site request forgery, and to understand how visitors use the site. We may use a privacy-respecting analytics tool on our website. [PLACEHOLDER: confirm whether the wizrdleads.com site runs the Meta Pixel or any advertising pixel. If it does, disclose it here, collect consent where required, and confirm the pixel is compatible with the "no sale or share" statements above.]

We honor the Global Privacy Control browser signal (the Sec-GPC header) as a valid opt-out request for the sale or sharing of personal information under California law and equivalent state laws. You can also manage cookies through your browser settings; clearing cookies may sign you out and reset your preferences.


7. Your privacy rights

You have rights over the personal information we hold. The specific rights depend on where you live, and we honor each right below regardless of where you live.

7.1 California residents (CCPA and CPRA)

If you live in California, you have the right to know what personal information we collect, to delete it, to correct it, to opt out of the sale or sharing of it, to limit our use of sensitive personal information, and not to be discriminated against for exercising these rights (Cal. Civ. Code 1798.100 and following). We do not sell or share your personal information, and we do not use sensitive personal information beyond providing the Service. We honor Global Privacy Control. To exercise a right, email privacy@wizrdleads.com. We respond to verifiable requests within forty-five days, extendable by another forty-five days when we need more time. You can use an authorized agent, whose authority we will verify.

7.2 European Union, EEA, and UK residents (GDPR and UK GDPR)

If you live in the EU, the EEA, or the UK, you have the rights to access, rectify, erase, restrict, port, and object to processing of your data, and not to be subject to solely automated decisions with legal or similarly significant effects (GDPR Articles 15 through 22). WIZRD Leads operates in the United States, so if you sign up from these regions your data is transferred to the United States under Standard Contractual Clauses and, where available, the EU-US Data Privacy Framework. We process your data on the legal bases of contract performance, our legitimate interests (running and improving the Service and preventing fraud), and consent where you give it. You may complain to your local supervisory authority. To exercise a right, email privacy@wizrdleads.com. We respond within one month, extendable by two more months for complex requests.

7.3 Residents of other US states

If you live in Virginia, Colorado, Connecticut, Texas, Florida, or another state with a comprehensive privacy law, you have rights similar to the California rights above. Email privacy@wizrdleads.com and we respond within the timeline your state's law requires, generally forty-five days.

7.4 Everyone

Wherever you live, you can request a copy of your data, ask us to correct or delete it, or ask a question by emailing privacy@wizrdleads.com from the email on file. We verify your identity, then respond within thirty days.


8. Data deletion

You can request deletion of your personal data at any time by emailing privacy@wizrdleads.com from the email on file. We will verify the request and confirm completion within thirty days.

When we delete your data, we remove it from our active systems within thirty days and apply the deletion against backups on our standard backup rotation, with controls that prevent deleted data from coming back into live systems.

We may keep a limited subset of data past a deletion request when the law requires it. Financial records are kept for seven years for tax purposes. Consent and opt-out records for text messaging are kept as long as needed to prove compliance. A limited record may be kept for fraud prevention.

Seller leads. Once a seller lead reaches your CRM, you are a controller of it, and deleting your WIZRD Leads account does not automatically delete leads already in your own systems. A seller who wants their data deleted can contact us at privacy@wizrdleads.com, and we will delete what we hold and, where required, coordinate with the client who received the lead.


9. Data retention

We keep personal data only as long as we need it. Default windows:

  • Client account data: for the length of your engagement plus [PLACEHOLDER: retention window, for example twenty-four months] after it ends.
  • Campaign and performance data: [PLACEHOLDER: for example twenty-four months] after your account disconnects.
  • Seller-lead data we hold: [PLACEHOLDER: for example twelve months] after generation, unless you ask us to delete it sooner.
  • SMS and call logs and consent records: for the length of your engagement plus the period needed to prove compliance.
  • Support communications: [PLACEHOLDER: for example thirty-six months].
  • Financial records (invoices, receipts): seven years, to satisfy US tax law.
  • Backups: on our standard rotation cycle.

If you ask us to delete your account, we apply the deletion within thirty days as described in Section 8, subject to the legal-hold and tax carve-outs above.


10. Text messages, TCPA, and STOP / HELP

If you give us your mobile number and agree to receive texts, we may send you account and service messages from WIZRD Leads, which may include appointment confirmations, reminders, onboarding messages, and follow-ups about the Service. Message frequency varies with your account activity, and message and data rates may apply.

  • Reply STOP to any message to opt out of further texts.
  • Reply HELP for help.
  • Consent to receive marketing texts is not a condition of buying the Service.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. We share mobile information only with the vendors that help us deliver the messages (for example, our messaging vendor Twilio and, where applicable, our CRM), and only to operate the service, never for their own marketing.

If you are a WIZRD Leads client, your own follow-up texts and calls to your seller leads are your responsibility under the TCPA (47 U.S.C. 227), the Florida Telephone Solicitation Act (Fla. Stat. 501.059), the Telemarketing Sales Rule, and the CAN-SPAM Act, as described in our Terms. This Section 10 covers the messages WIZRD Leads sends, not the messages you send to your leads.


11. Children

WIZRD Leads is a business service for adults. We do not direct the Service at children under thirteen, and we do not knowingly collect personal information from children under thirteen. If you believe a child has given us personal information, email privacy@wizrdleads.com and we will delete it. In places where the child-protection age is higher than thirteen, the same rule applies at the higher age.


12. International transfers

WIZRD Leads operates in the United States, and processing happens on infrastructure in the United States. The vendors in Section 5 process data in the regions their contracts state. If you sign up from outside the United States, your data will be transferred to the United States. We rely on Standard Contractual Clauses for transfers from the EU, the UK, and Switzerland, and on the EU-US Data Privacy Framework where a vendor self-certifies under it. We will expand this section as we add regions or vendors.


13. Security

We protect your data with technical and organizational measures appropriate to the risk. Data is encrypted in transit (TLS 1.2 or higher) and at rest. We enforce separation so one client's data is not exposed to another client. Access tokens for your Meta ad account are stored encrypted. Sign-in and credential handling are performed by our authentication vendor, and we never see your plain-text password.

We monitor and log access to your data so we can investigate unusual activity. No system is perfect. If a breach happens that is likely to put your rights at risk, we will tell you without undue delay, and within seventy-two hours of becoming aware of it where the law requires it.


14. Automated decision-making and AI

We use software and AI tools, including the WIZRD software and an AI vendor (Anthropic), to help build, analyze, and optimize your campaigns and to help route and organize leads. These tools support our team; a human remains involved in running your account. We do not make decisions about you with legal or similarly significant effects using solely automated processing without a human in the loop.

We do not use your seller-lead data or your account data to train shared AI models. If you have questions about how AI is used in your account, or you want a human to review something, email privacy@wizrdleads.com and we will respond within thirty days.


15. Changes and contact

We will update this policy from time to time. For a material change, we will tell you at least thirty days before it takes effect by email to the address on file. For a non-material change (typo, clarification, vendor swap that does not change what we collect), we will update the policy and the "Last updated" line. Continued use after the effective date means you accept the updated policy.

For any privacy question, complaint, or request, contact us at:

Closers Consulting Group, LLC (d/b/a WIZRD Leads) [PLACEHOLDER: CCG registered address] United States

We read every email sent to these addresses and respond within thirty days, sooner when we can.


This Privacy Policy is between you and Closers Consulting Group, LLC (d/b/a WIZRD Leads). It is governed by the laws of the State of Florida, without regard to its conflict of laws provisions. Disputes are handled as described in our Terms of Service.