Privacy Policy

Last Updated: June 20, 2026

1. Information We Collect

From Clients (Account Information)

• Name
• Email address
• Phone number
• Business name
• Billing information
• Login credentials

From Leads (Originating Data)

Verity Growth generates leads through online advertising and landing page forms. When an individual submits a form, we collect:

• Name, phone number, and email address
• Information voluntarily provided in the form (e.g., insurance interest, location, or related details)
• Technical data such as IP address and form-submission metadata, for fraud prevention and verification (e.g., SMS verification)

Lead Data Within the Platform

Once a lead is sold to a Client, the Client may add notes, status updates, and communication history to that lead's record within the Platform. This client-generated activity data is controlled by the Client, not by Verity Growth.

2. How We Collect and Use Lead Information

At the point of collection (our advertising and landing pages), we obtain the individual's consent to be contacted regarding insurance products and to have their information provided to a licensed, independent insurance agent for that purpose. We use this information to:

• Verify and qualify the lead (including SMS verification) prior to sale
• Sell the lead, on an exclusive basis, to a single licensed Client agent selected by Verity Growth
• Maintain records of leads sold for accounting, dispute resolution, and regulatory compliance
• Detect and prevent fraud or duplicate submissions

We do not sell or provide a Lead's information to more than one Client. Once a lead is sold, responsibility for further use of that individual's information — including all direct communication — transfers to the purchasing Client, as described in Section 3.

3. How We Use Client Account Information

We use Client account information to:

• Provide access to the Platform and deliver purchased leads
• Process payments and provide customer support
• Improve the Platform and our services
• Communicate service updates
• Enforce our Terms of Use, verify licensing, and prevent fraud or misuse

We do not sell Client account information to third parties.

4. Lead Data & Ownership Once Sold

Leads delivered through the Platform:

• Become the responsibility of the Client who purchases them, including all compliance obligations described in Section 6
• Are stored within the Platform for tracking and account history purposes
• Are exclusive — each lead is delivered to one Client only and is never resold, shared, or redistributed to any other Client

Verity Growth is not responsible for how Clients contact or communicate with leads after sale. Clients are solely responsible for complying with CASL, the Do Not Call List rules, PIPEDA and provincial privacy laws, insurance regulations, and all consent and opt-out requests.

5. Data Storage & Security

We take reasonable technical and organizational measures to protect personal information, including:

• Secure, encrypted hosting and database infrastructure
• Authentication systems and account login protection
• Restricted, role-based database access

Our infrastructure, including database hosting, is provided by third-party providers (such as Cloudflare). Personal information may accordingly be stored or processed in Canada, the United States, or other countries where our service providers maintain infrastructure, and may therefore be subject to the laws of those jurisdictions, including lawful access by foreign authorities.

No system is 100% secure, and we cannot guarantee absolute security of any information transmitted to or stored by us.

6. Client Responsibilities

Clients using Verity Growth agree that they are solely responsible for:

• All communication with leads after purchase
• Maintaining their own consent and contact records
• Handling unsubscribe and do-not-contact requests promptly and in accordance with CASL
• Insurance regulatory compliance and data protection for any data exported from the Platform
• Proper, lawful use of lead data
• Compliance with all applicable federal and provincial laws

Verity Growth acts solely as a lead generation and software delivery platform and does not direct, control, or supervise a Client's communications with leads.

7. Sharing of Information

We may share personal information only where necessary, with:

• Payment processors, to process billing
• Hosting and infrastructure providers (e.g., Cloudflare), to operate the Platform
• CRM and software infrastructure providers that support the Platform
• The single Client agent who purchases a given lead
• Legal or regulatory authorities, where required by law or legal process

We do not sell personal information to third parties for their own independent marketing purposes.

8. Your Privacy Rights

Individuals (including Leads and Clients) have the right, subject to applicable law, to:

• Request access to the personal information we hold about them
• Request correction of inaccurate or incomplete information
• Withdraw consent to future contact or processing, subject to legal or contractual restrictions
• File a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial regulator

To exercise any of these rights, contact us using the information in Section 14. Note that withdrawing consent to be contacted by Verity Growth does not affect, and cannot retroactively withdraw, consent already given to a Client who has separately and lawfully obtained it; such requests must be directed to that Client as well.

9. Data Breach Notification

In the event of a breach of security safeguards involving personal information under our control that creates a real risk of significant harm to an individual, we will notify affected individuals and report to the Office of the Privacy Commissioner of Canada, in each case as and to the extent required by PIPEDA.

10. Data Retention

We retain account information, lead data, activity history, and billing records for as long as reasonably necessary for the purposes described in this Policy. Data may be retained after account cancellation for legal compliance, dispute resolution, accounting records, and fraud prevention, and thereafter securely deleted or anonymized.

11. Account Security

Clients are responsible for:

• Keeping login credentials secure and confidential
• All activity occurring under their account
• Any unauthorized access resulting from password sharing
• Managing access permissions for their own team members

12. Platform Analytics and Cookies

We may collect anonymous or aggregated data, such as login activity, Platform usage, lead status updates, feature usage, and system performance data, used solely to operate, maintain, and improve the Platform. Our website may also use cookies or similar tracking technologies to support advertising, analytics, and landing-page form functionality; you can control cookies through your browser settings.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated "Last Updated" date. Continued use of the Platform or our website following any update constitutes acceptance of the revised Policy.

14. Contact Us

For privacy questions, access/correction requests, or complaints, contact: