Privacy Policy

This Privacy Policy describes how adsystems.io LLC, doing business as “PolicyClover” (“PolicyClover,” “we,” “us,” or “our”) collects, uses, shares, and protects information about individuals (“you”) who visit our websites, interact with our ads or forms, or otherwise provide information to us in the United States.

We operate a marketing and lead generation platform that connects consumers interested in life insurance products with independent, licensed insurance agents and agencies in the United States.

By using our websites, filling out our forms, or otherwise providing your information, you agree to this Privacy Policy.

1. Scope; US-Only Service

PolicyClover is intended only for U.S. residents age 18 or older. We do not knowingly collect personal information from individuals under 18, and we do not offer services outside the United States.

Because we may “sell” or “share” personal information (as those terms are used under the California Consumer Privacy Act / California Privacy Rights Act, “CCPA/CPRA”), this Policy includes additional information for California residents.

2. Personal Information We Collect

We collect information in three primary ways:

• Information you provide directly (through our forms or communications)
• Information we collect automatically (via cookies, pixels, and similar technologies)
• Information we obtain from third-party data providers (enrichment)

2.1 Information You Provide

When you interact with PolicyClover, you may provide:

• Contact Information – name, email address, phone number
• Employment / Occupation – job/occupation or type of work
• Location – state (sometimes directly on the form)
• Other information you choose to provide in free-text fields or during calls/messages with our team or our partners

2.2 Information Collected Automatically

When you visit our sites or forms, we automatically collect:

• Device and usage data – IP address, browser type, device type, operating system, referring/exit pages, timestamps
• Online identifiers and activity – cookies, pixels, session IDs, page views, clicks, conversions, and interactions with our ads and pages

We and our advertising/analytics partners (e.g., Meta, TikTok, Google, analytics tools) use this to measure performance, prevent fraud, and improve our campaigns.

2.3 Information from Third-Party Data Providers (Enrichment)

After you submit a form, we may obtain additional information about you from data providers and consumer reporting agencies, such as:

• Address information – street address, city, ZIP code
• Approximate age or age band
• Approximate personal or household income band
• Approximate credit-related attributes, such as a modeled credit score range or segment
• Phone and email intelligence – line type (mobile/VOIP), carrier, email status, fraud or spam risk

We use this enriched data to:

• Validate the accuracy of the information you provided
• Evaluate eligibility and fit for insurance products
• Score and route leads to appropriate insurance partners
• Detect and prevent fraudulent or invalid leads

We treat this enriched data as part of your personal information under this Policy.

2.4 Use and Processing of Collected Information

Note that under some legislations, we may be allowed to process your information until you object to such processing (for example, by opting out), without having to rely on consent or any other legal basis listed in that legislation. In any case, we will be happy to clarify the specific legal basis that applies to any particular processing of your personal information, including whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract. You further understand that any credit‑related inquiries we make in connection with our services are soft inquiries only and will not harm your credit in any way whatsoever.

3. How We Use Your Information

We use the information we collect for purposes including:

Lead Generation and Matching

• Evaluating whether you may be a good fit for certain life insurance offerings
• Connecting you with licensed life insurance agents/agencies who may contact you about their products

Communications

• Calling or texting you (including using automated dialing systems, AI-generated or prerecorded messages, and SMS) to respond to your request, confirm details, or connect you with a licensed agent
• Sending emails or texts with information you requested or related offers (where permitted)

Data Enrichment, Scoring, and Routing

• Validating and enriching your data using third-party providers
• Scoring and routing leads based on age, income band, geography, occupation, and other attributes

Advertising, Analytics, and Optimization

• Measuring and improving performance of our ads and funnels
• A/B testing pages and creative to reduce friction and improve relevance
• Preventing invalid or fraudulent traffic/leads

Legal, Compliance, and Security

• Recording consent and call/text interactions (e.g., via TrustedForm or similar tools)
• Complying with applicable laws and regulations
• Protecting our rights, customers, partners, and systems

We do not use your information to make binding credit decisions, issue loans, or offer credit products ourselves.

4. How We Share and “Sell” Information

4.1 Sharing with Insurance Partners (Lead Buyers)

PolicyClover’s core business is generating and distributing insurance leads. When you submit your information, we share or sell your information to:

• Licensed life insurance agents and agencies in the United States

So they can contact you (by phone, text, email) to discuss life insurance options, including Indexed Universal Life (IUL) and related products.

In some cases today, a lead is sold or assigned to one exclusive buyer; in the future, we may:

• Resell leads as aged leads, and/or
• Distribute a lead to multiple buyers, where permitted and disclosed

From a CCPA/CPRA standpoint, providing your information to these third-party agents/agencies in exchange for value may be considered a “sale” or “sharing” of personal information.

Once an Insurance Partner receives your information, their use and handling of your information is governed by their own privacy policies and practices, not this Privacy Policy.

4.2 Sharing with Service Providers and Vendors

We also share information with third parties that help us operate our platform and services, including:

• Lead routing and marketplace platforms (e.g., systems like LeadProsper)
• Data enrichment and consumer data providers (e.g., providers similar to LeadFi)
• Consent capture, fraud detection, and security tools (e.g., tools similar to TrustedForm, Anura, Twilio)
• Marketing, analytics, and CRM platforms (e.g., Meta, TikTok, Google, Airtable, Cometly, GoHighLevel, Make/Zapier, email/SMS platforms)

These companies are contractually limited in their ability to use your information except to provide services to us or on our behalf.

4.3 Other Sharing

We may also share information:

• With our affiliates (other brands/DBAs of adsystems.io LLC)
• In connection with a business transaction, such as a merger, acquisition, reorganization, or sale of assets
• When required by law, regulation, or legal process, or to protect our rights, property, safety, or those of others

We do not sell your information to generic data brokers for unrelated marketing purposes.

5. Cookies, Pixels, and Tracking Technologies

We and our partners use cookies, pixels, and similar technologies to:

• Recognize your browser or device
• Measure and improve ad performance
• Track conversions and user flows through our funnels
• Detect and prevent fraud

You can usually control cookies through your browser settings and device controls. However, disabling cookies may affect site functionality or measurement.

Some of our advertising partners may allow you to opt out of behavioral advertising through their own tools or industry-wide mechanisms (e.g., NAI or DAA opt-outs).

6. Your Privacy Rights

6.1 California Residents (CCPA/CPRA)

If you are a California resident, you may have the following rights (subject to certain exceptions):

• Right to Know
• Right to Delete
• Right to Correct
• Right to Opt-Out of “Sale” or “Sharing” — submit a request on our Do Not Sell or Share My Personal Information page
• Right to Non-Discrimination

Because we sell leads to insurance partners, and may use third-party ad/analytics tools, we may be considered to “sell” or “share” your personal information under CCPA/CPRA.

We may need to verify your identity before responding. You may also designate an authorized agent to make requests on your behalf.

6.2 Other US Residents

Depending on your state, you may have similar rights to access, delete, or opt out of certain uses of your personal information. You can contact us using the information above to submit such a request, and we will handle it in accordance with applicable law.

7. Data Retention

We retain personal information for as long as reasonably necessary to:

• Fulfill the purposes described in this Policy
• Comply with legal, regulatory, or contractual obligations (including recordkeeping for consent and lead sales)
• Resolve disputes and enforce agreements

We may retain aggregated or de-identified information indefinitely, which we do not treat as personal information.

8. Data Security

We use reasonable physical, technical, and administrative safeguards designed to protect personal information from unauthorized access, use, or disclosure. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Children’s Privacy

Our services are not directed to or intended for individuals under 18. We do not knowingly collect personal information from anyone under 18. If we become aware that a child under 18 has provided personal information, we will take steps to delete it and, where appropriate, terminate the account or lead.

10. Do Not Track

Some browsers transmit “Do Not Track” signals. Our sites do not currently respond to Do Not Track signals. We treat all users according to the practices described in this Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will change the “Last Updated” date at the top. If we make material changes, we may also provide additional notice (e.g., on our website or by email). Your continued use of our services after any changes means you accept the updated Policy.

12. Contact Us