1. Scope and who this policy covers
This Privacy Policy explains how DN Dialer ("DN Dialer," "we," "us," or "our") collects, uses, discloses, and protects personal information through our website, lead marketplace, dialer software, and related services (collectively, the "Service"). It applies to three groups of people: (a) consumers who submit a life insurance quote request through our landing pages or an integrated ad source; (b) agency users — agency owners and agents who create accounts to buy leads and use the dialer; and (c) visitors who browse our public website without submitting information.
2. Information we collect
We collect the following categories of information:
- Consumer quote-request information: first and last name, phone number, email address, state and ZIP code, date of birth, requested coverage amount, insurance product of interest, and any notes you provide.
- Consent and compliance metadata: the exact timestamp of your consent, the web page URL where you submitted your request, the version of the disclosure language you were shown, and the IP address recorded at submission. We retain this record to demonstrate compliance with the Telephone Consumer Protection Act ("TCPA") and to honor opt-out requests.
- Agency user account information: name, email address, phone number, role (agency owner or agent), hashed password credentials, and agency affiliation.
- Call and activity data: call attempts, call duration, call outcome and disposition, call recordings (see Section 6), inbound call center availability status, and deal/commission records entered by agency users.
- Payment information: processed directly by Stripe, Inc., our third-party payment processor. We do not store full payment card numbers on our servers. We retain limited billing metadata (subscription status, invoice history, and the last four digits of a payment method, where provided by Stripe).
- Automatically collected information: IP address, browser type and version, device identifiers, referring/exit pages, and usage data collected through standard web server logs and, if enabled, analytics cookies.
3. Sources of information
We obtain information directly from you when you:
- Submit a quote request through our landing pages;
- Respond to a third-party advertisement or lead-generation postback integrated with our Service;
- Create an agency account, invite an agent, or use the dialer; or
- Contact us directly.
We may also receive information from vetted third-party lead vendors and advertising networks who represent to us that they have obtained proper consent for the communications described in this policy before transferring a record to us.
4. How we use information
- To generate and sell insurance leads to licensed agencies for the purpose of contacting the consumer about the product they requested information on;
- To operate the lead marketplace, power dialer, inbound call center, deal tracking, and commission ledger features of the Service;
- To verify phone numbers and detect invalid or fraudulent submissions before a lead is sold;
- To process payments and manage subscriptions;
- To maintain records demonstrating TCPA consent and to honor Do Not Call and opt-out requests;
- To detect, investigate, and prevent fraud, abuse, and security incidents;
- To comply with legal obligations, respond to lawful requests, and enforce our Terms of Service; and
- To communicate with you about your account, the Service, or your quote request.
5. Legal basis and consent (TCPA)
Before any consumer information is entered into our marketplace, the capture form requires an affirmative, unchecked-by-default checkbox providing prior express written consent, consistent with the standard set out in 47 C.F.R. § 64.1200(f)(9), for DN Dialer and its licensed agency partners to contact the consumer using an automatic telephone dialing system, an artificial or prerecorded voice, and/or SMS text messages, at the phone number provided, regarding life insurance products — including where that number is registered on the National Do Not Call Registry. Consent is not made a condition of receiving any product or service, as required by the same rule.
You may revoke consent at any time, through any reasonable means, including by replying "STOP" to a text message, verbally informing an agent during a call, or contacting us using the information in Section 19. We record revocation requests and propagate a Do Not Call flag to the purchasing agency or agencies.
6. Call recording and monitoring
Calls placed or received through the Service may be recorded for quality assurance, training, and compliance purposes. Some states — including California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Montana, Nevada, New Hampshire, Pennsylvania, and Washington — require the consent of all parties to a call before it may be recorded ("two-party" or "all-party consent" states). Agencies using the Service are responsible for providing any state-required recording disclosure at the start of a call. Recordings are stored and made accessible only to the agency that owns the lead and to DN Dialer personnel for platform support and compliance review.
8. Data retention
We retain consumer consent records for as long as necessary to demonstrate TCPA compliance, which we treat as a minimum of five years from the date of last contact, or longer if required by an applicable state insurance recordkeeping law. Call recordings are retained according to the storing agency's configuration, subject to a platform maximum. Account data is retained for the life of the account and a reasonable period thereafter for legal, tax, and dispute-resolution purposes.
9. Your privacy rights
Regardless of your state of residence, you may contact us to:
- Request that your phone number be flagged Do Not Call across our platform;
- Request a copy of the personal information we hold about you;
- Request correction of inaccurate information;
- Request deletion of your information, subject to our legal retention obligations described in Section 8; and
- Ask which agency or agencies purchased your information.
We will respond to verified requests within 45 days.
10. Additional disclosures for California residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), gives you the right to: know what personal information we collect, use, disclose, and (if applicable) sell or share; request deletion; request correction; opt out of the sale or sharing of personal information and of the use of sensitive personal information for cross-context behavioral advertising; limit the use of sensitive personal information; and not be discriminated against for exercising these rights. You may designate an authorized agent to submit a request on your behalf.
Sales/sharing disclosure: in the preceding 12 months, we have disclosed the categories of personal information described in Section 2 to the categories of recipients described in Section 7. We do not knowingly sell or share the personal information of consumers we know to be under 16 years of age.
11. Additional disclosures for other U.S. states
Residents of states with comprehensive consumer privacy laws currently in effect — including Colorado, Connecticut, Utah, and Virginia, among others — have similar rights to access, correct, delete, and obtain a portable copy of their personal information, and to opt out of targeted advertising, the sale of personal data, and certain profiling. Contact us using Section 19 to exercise these rights; we will identify and apply the protections of your specific state of residence.
12. Do Not Track signals
Our Service does not currently respond to "Do Not Track" browser signals. Some browsers offer a Global Privacy Control ("GPC") signal, which we treat as a valid opt-out-of-sale/ sharing request under the CCPA/CPRA where technically detectable.
13. Children's privacy
The Service is not directed to individuals under the age of 18, and life insurance products offered through the Service are not marketed to minors. We do not knowingly collect personal information from children under 13 within the meaning of the Children's Online Privacy Protection Act ("COPPA"). If we learn that we have inadvertently collected such information, we will delete it promptly.
14. Financial and insurance information (GLBA-related)
Licensed insurance agencies using the Service are themselves subject to the Gramm-Leach-Bliley Act ("GLBA") and applicable state insurance privacy regulations with respect to nonpublic personal financial information they collect from consumers during underwriting. DN Dialer acts as a technology service provider to those agencies; we require agencies to maintain their own compliant privacy notices and safeguards for information collected after a lead is transferred to them.
15. Data security
We use industry-standard administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit (TLS), encrypted database connections, hashed password storage, and role-based access controls scoped to each agency's own data. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
16. International users
The Service is intended for use by consumers and licensed agencies within the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, which may not have data protection laws equivalent to those of your home jurisdiction.
17. Third-party links and services
Our website may link to third-party sites, and we integrate third-party services (Twilio, Stripe) that have their own privacy policies. We are not responsible for the privacy practices of third parties.
18. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be reflected by an updated "Last updated" date at the top of this page, and where required by law, we will provide additional notice.
19. Contact us
Privacy questions, data requests, or Do Not Call requests — reach out via our Contact page.