Privacy Policy
Last updated: May 2026 · Effective for all users from May 1, 2026
Million Global Leads (“the Agency,” “we,” “us,” or “our”) operates milliongloballeads.com and provides generative engine optimization and digital marketing services. This Privacy Policy explains what personal data we collect, how we use it, with whom we share it, how long we retain it, and what rights you hold with respect to your personal data. Please read this policy carefully before using our website or engaging our services. By using milliongloballeads.com or submitting any form on this website, you acknowledge that you have read and understood this Privacy Policy.
Section 1: Information We Collect
We collect personal data through three primary means: information you provide to us directly, information collected automatically when you use our website, and information received from third parties. The following subsections describe each category in detail.
1.1 Information You Provide Directly
When you interact with milliongloballeads.com, you may provide us with personal data through the following actions: submitting a contact form on our website; booking a free 15-minute GEO visibility briefing or discovery call; purchasing a digital product such as the AI Search Readiness Kit; responding to an email, SMS message, or outreach communication from our team; participating in a client onboarding process; engaging with our team via email at contact@milliongloballeads.com; or submitting an inquiry through any third-party form embed or CRM widget hosted on our website.
The categories of personal data collected through these direct interactions include: your full name; your professional email address; your business phone number; your business name and industry; your business website URL; your geographic location including city and country; the nature of your marketing inquiry or service interest; any additional information you voluntarily include in a free-form contact or message field; and, where applicable, payment information processed through our third-party payment processor.
We do not require you to provide personal data to browse the public content of milliongloballeads.com. Personal data collection is triggered only when you actively submit a form, make a purchase, or initiate contact with our team.
1.2 Information Collected Automatically
When you visit milliongloballeads.com, certain technical and behavioral data is collected automatically by our website infrastructure and analytics tools. This automatically collected data includes: your Internet Protocol (IP) address or approximate geographic location derived from your IP address; the type and version of browser you are using; your operating system and device type (desktop, tablet, or mobile); the web pages you visit on our site, including the URLs of pages viewed and the order in which they are visited; the date and time of each page visit; the referring URL or search engine query that directed you to our site; time spent on individual pages and overall session duration; and scroll depth and click interaction data collected in aggregate for page performance analysis.
This automatically collected data is used in aggregate and anonymized form to understand how visitors use our website, identify content that is performing well or poorly, and improve the overall user experience. We do not use automatically collected data to build individual-level behavioral profiles for advertising purposes.
1.3 Information from Third Parties
In certain circumstances, we may receive information about you from third-party sources. These sources include: referral partners who introduce potential clients to our services; professional networking platforms such as LinkedIn, where your public profile information may be reviewed in connection with outbound prospecting or client research; our GoHighLevel CRM platform, which may aggregate interaction data from email and SMS campaign engagement; and Google Analytics and similar web analytics platforms that provide aggregated audience data about visitors to our website. We handle all third-party sourced data in accordance with the terms of this Privacy Policy and applicable data protection law.
Section 2: How We Use Your Information
We use the personal data we collect for the following purposes:
- (a)Service Delivery: To provide the services you have engaged us for, including communicating with you about your engagement, delivering Deliverables, configuring technical systems on your behalf, and managing your account throughout the duration of your service agreement.
- (b)Inquiry Response: To respond to contact form submissions, booking requests, service inquiries, and general questions submitted through the website or via email. We aim to respond to all inquiries within one business day.
- (c)Marketing Communications: To send you marketing emails, educational content, case study announcements, service updates, and promotional materials, where you have opted in to receive such communications or where we have a legitimate interest in communicating with you as a prospective or current client. You may opt out of marketing communications at any time.
- (d)Website Improvement: To analyze how visitors use milliongloballeads.com, identify pages or content that require improvement, and optimize the performance, structure, and user experience of the website based on aggregate usage data.
- (e)Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests, including tax obligations, anti-money laundering requirements, and any other regulatory compliance obligations applicable to our business operations.
- (f)Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, unauthorized access to our systems, and other illegal or harmful activities that may affect our clients, our team, or the integrity of our service delivery.
- (g)Contract Performance: To perform our obligations under any Service Agreement executed with you, including processing payments, issuing invoices, managing service timelines, and resolving disputes or inquiries related to your engagement.
We do not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances. We do not use your personal data to build advertising audience segments for third-party platforms without your explicit opt-in consent.
Section 3: Legal Basis for Processing Personal Data
For individuals located in the European Economic Area (EEA), the United Kingdom, or other jurisdictions subject to data protection laws that require a documented legal basis for personal data processing, we rely on the following legal bases for each category of processing:
- Contractual Necessity
- We process your personal data where processing is necessary for the performance of a contract to which you are a party, including all processing required to deliver our services to you under a signed Service Agreement or in response to your pre-contractual inquiry about our services.
- Legitimate Interests
- We process certain personal data on the basis of our legitimate business interests, including: maintaining and improving our website and service quality; conducting outreach to prospective clients who have expressed interest in our services; analyzing aggregate usage data to inform content and product decisions; and protecting the security and integrity of our systems. We conduct a balancing test to ensure our legitimate interests do not override your rights and freedoms.
- Consent
- Where we send marketing communications to individuals who are not existing clients, we obtain your prior consent before doing so. You may withdraw your consent to receive marketing communications at any time by clicking the unsubscribe link in any email we send or by contacting us directly.
- Legal Obligation
- We process personal data where we are required to do so by applicable law, including tax law, anti-money laundering regulations, and other regulatory compliance obligations.
Section 6: Data Retention
We retain personal data for the minimum period necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. The following retention periods apply to each data category:
- Active Client Data
- Personal data associated with active service engagements is retained for the duration of the engagement plus seven (7) years following the termination of the last active service agreement between the parties, to satisfy applicable tax, accounting, and legal record-keeping requirements.
- Prospective Client Inquiry Data
- Personal data submitted through contact forms, booking requests, or inquiry communications by individuals who do not subsequently enter into a Service Agreement is retained for a period of up to two (2) years from the date of last interaction, after which it is securely deleted from our systems unless you have opted in to ongoing marketing communications.
- Marketing Consent Records
- Records of your consent to receive marketing communications, including the date, method, and scope of consent provided, are retained for a period of three (3) years following your last consent action or your opt-out, whichever is later, to demonstrate compliance with applicable data protection law.
- Website Analytics Data
- Aggregate, anonymized analytics data collected via Vercel Analytics is retained indefinitely in aggregate form as it does not constitute personal data. Individual session data, where applicable, is retained for a maximum of twenty-six (26) months in accordance with standard analytics platform data retention settings.
- Financial and Payment Records
- Records associated with transactions, invoices, and payment histories are retained for a minimum of seven (7) years from the transaction date in compliance with United States federal and California state tax and financial record-keeping requirements.
Upon the expiration of the applicable retention period, we securely delete or permanently anonymize personal data in a manner that prevents its reconstruction. If you wish to request early deletion of your personal data, please refer to the rights described in Section 9 of this Privacy Policy.
Section 7: Data Security
We implement appropriate and proportionate technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include: transport layer security (TLS/HTTPS) encryption for all data transmitted to and from milliongloballeads.com; password management policies and multi-factor authentication requirements for all team members with access to personal data; role-based access controls that limit access to personal data to team members who require access to fulfill their job responsibilities; secure data processing agreements with all third-party service providers that handle personal data on our behalf; and regular review of security practices and procedures in line with evolving industry standards.
We do not store payment card data. All payment card transactions are processed exclusively through PCI-DSS compliant third-party payment processors, and raw card data is transmitted directly to the payment processor without passing through our systems.
While we implement commercially reasonable security measures, no system of security is impenetrable, and we cannot guarantee absolute security of any data transmitted over the internet or stored in electronic systems. In the event of a security incident that affects personal data, we will respond in accordance with the notification obligations described in Section 16 of this Privacy Policy.
Section 8: International Data Transfers
Million Global Leads is headquartered in San Francisco, California, United States. If you are accessing milliongloballeads.com from outside the United States, or if you are a client located in a country outside the United States, your personal data may be transferred to and processed in the United States, where data protection laws may differ from those in your home jurisdiction.
For individuals located in the European Economic Area or the United Kingdom, where personal data is transferred to the United States, we ensure that such transfers are made in compliance with applicable data transfer mechanisms. These mechanisms may include: standard contractual clauses approved by the European Commission; reliance on the adequacy decision applicable to the recipient country; or other transfer mechanisms recognized under the General Data Protection Regulation (GDPR) and its UK equivalent.
Our third-party service providers, including GoHighLevel and Vercel, may also process data in data centers located in the United States and other countries. We ensure that contractual data processing agreements with these providers include appropriate transfer mechanism protections where required by applicable law. For further information about the international transfer mechanisms we rely upon, please contact us using the information provided in the Contact section of this Privacy Policy.
Section 9: Your General Data Rights
Regardless of your geographic location, you have the following general rights with respect to personal data held by Million Global Leads:
- Right to Access
- You may request a copy of the personal data we hold about you. We will provide this information within the timeframe required by applicable law, typically within thirty (30) days of a verified request.
- Right to Correction
- You may request that we correct any inaccurate or incomplete personal data we hold about you. We will update records promptly upon receipt of a verified correction request.
- Right to Deletion
- You may request that we delete your personal data where we no longer have a lawful basis for retaining it, where you have withdrawn consent that was the sole basis for processing, or where deletion is required by applicable law. We will fulfill deletion requests subject to any overriding legal retention obligations.
- Right to Opt Out of Marketing
- You may opt out of receiving marketing communications from Million Global Leads at any time by clicking the unsubscribe link in any marketing email, by replying to an SMS with “STOP,” or by contacting us directly at contact@milliongloballeads.com. Processing of your opt-out request will be completed within ten (10) business days.
- Right to Data Portability
- Where technically feasible and legally required, you may request that we provide your personal data in a structured, commonly used, and machine-readable format, or that we transmit it directly to another data controller.
To exercise any of the rights listed in this Section, please submit a written request to contact@milliongloballeads.com with the subject line “Data Rights Request.” We will verify your identity before processing any request and will respond within the applicable legal deadline.
Section 10: GDPR Rights for EEA and UK Residents
If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) and its applicable national implementations provide you with the following additional rights over your personal data:
- Right to Restrict Processing
- You may request that we restrict the processing of your personal data in circumstances where you contest the accuracy of the data, where the processing is unlawful but you prefer restriction over deletion, or where we no longer need the data but you need it for the establishment, exercise, or defense of a legal claim.
- Right to Object
- You may object to the processing of your personal data where the processing is based on our legitimate interests or on the performance of a task in the public interest. We will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defense of legal claims.
- Right to Withdraw Consent
- Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Lodge a Complaint
- If you believe that our processing of your personal data infringes GDPR, you have the right to lodge a complaint with the supervisory authority in your Member State of habitual residence, place of work, or place of the alleged infringement. In the United Kingdom, the relevant authority is the Information Commissioner’s Office (ICO) at ico.org.uk.
- Rights in Relation to Automated Decision-Making
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Million Global Leads does not engage in fully automated decision-making processes that produce such effects without human review.
Section 11: CCPA Rights for California Residents
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information. This Section describes those rights and how to exercise them.
- Right to Know
- You have the right to request that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting or sharing the information, the categories of third parties with whom we share the information, and the specific pieces of personal information we have collected about you.
- Right to Delete
- You have the right to request the deletion of personal information we have collected about you, subject to certain exceptions permitted by law, including retention obligations required for completing a transaction, detecting security incidents, or complying with legal obligations.
- Right to Correct Inaccurate Information
- You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which we process it.
- Right to Opt Out of Sale or Sharing
- Million Global Leads does not sell personal information as defined by the CCPA. We do not share personal information with third parties for cross-context behavioral advertising. If our practices change, we will provide the required opt-out mechanism at that time.
- Right to Limit Use of Sensitive Personal Information
- We do not collect sensitive personal information as defined by the CPRA, including government-issued identification numbers, financial account details, precise geolocation data, racial or ethnic origin, religious beliefs, genetic data, biometric data, or health information, in the ordinary course of our business operations.
- Right to Non-Discrimination
- We will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge you different prices, or provide you a different level of quality of services as a result of your exercising a CCPA right.
To exercise your CCPA rights, please submit a verifiable consumer request to contact@milliongloballeads.com. We will respond to verifiable requests within the timeframes required by California law, which is forty-five (45) days from receipt of the request, with one possible extension of an additional forty-five (45) days where reasonably necessary.
Section 12: Third-Party Links and External Services
milliongloballeads.com contains links to third-party websites, resources, platforms, and services that are not owned or operated by Million Global Leads. These include links to our social media profiles, links to third-party tools referenced in our educational content, and links to partner platforms mentioned in our service descriptions. When you click on a link to a third-party website, you leave milliongloballeads.com and your interaction with that website is governed by the privacy policy and terms of service of that third party.
Million Global Leads has no control over and assumes no responsibility for the content, privacy practices, security measures, or data handling practices of any third-party websites or services. We encourage you to review the privacy policy of every website you visit before submitting any personal information. The inclusion of a link on milliongloballeads.com does not constitute an endorsement of the linked website or its privacy practices.
Section 13: Children’s Privacy
milliongloballeads.com and all services provided by Million Global Leads are directed exclusively at business professionals and are not intended for use by individuals under the age of eighteen (18). We do not knowingly collect, process, or retain personal data from individuals under eighteen years of age. If we become aware that personal data from a person under eighteen has been submitted to our systems, we will take immediate steps to delete that data from our records. If you are a parent or guardian and believe that your child has submitted personal data to Million Global Leads without your consent, please contact us immediately at contact@milliongloballeads.com so we can take appropriate action.
Section 14: Marketing Communications
We may send you marketing emails, educational newsletters, case study announcements, and service-related updates where you have provided consent, where we have a legitimate interest based on an existing or recent business relationship, or where permitted by applicable law. Every marketing email we send includes a clearly visible unsubscribe link at the footer of the message. Clicking the unsubscribe link will remove your email address from our marketing distribution list within ten (10) business days.
Where we use SMS marketing, we will only send SMS messages to phone numbers for which we have obtained prior express written consent in compliance with the Telephone Consumer Protection Act (TCPA) and applicable state laws. You may opt out of SMS communications at any time by replying “STOP” to any SMS message from Million Global Leads. Standard message and data rates from your mobile carrier may apply.
Transactional communications related to your active service engagement, including service updates, invoice notifications, and account-related alerts, are not subject to marketing opt-out controls and will continue to be sent for the duration of your engagement regardless of your marketing communication preferences.
Section 15: Analytics and Website Performance Data
We use Vercel Analytics as our primary website analytics platform. Vercel Analytics is designed to collect anonymized, aggregate page view and interaction data without using cookies or storing personally identifiable information at the individual visitor level. The data collected by Vercel Analytics includes: page view counts per URL; referrer source categories; device type distributions; and geographic distribution by country. This data is used exclusively for internal website improvement purposes and is not shared with third parties for advertising or commercial profiling.
We may also use Google Analytics for additional traffic analysis on select pages. Where Google Analytics is active, it collects session and behavior data that is subject to Google’s own privacy policy and data retention settings. We have configured Google Analytics with IP anonymization enabled where technically applicable. You may opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.
Section 16: Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, Million Global Leads will take the following steps: assess the nature, scope, and likely consequences of the breach without undue delay upon becoming aware of it; take immediate remedial action to contain the breach and prevent further unauthorized access or disclosure; notify the appropriate supervisory authority within seventy-two (72) hours of becoming aware of the breach, where required by applicable data protection law; and notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.
Notification to affected individuals will be provided via email to the address on file and will include: a description of the nature of the breach; the categories and approximate volume of personal data records affected; the likely consequences of the breach; and the measures taken or proposed to address the breach and mitigate its possible adverse effects.
Section 17: Client Business Data and Campaign Data
In the course of providing services, Million Global Leads may access, process, or store business data belonging to our clients, including: client customer lists and contact databases managed within GoHighLevel CRM; website analytics data from client Google Analytics or Search Console properties; advertising account data from client Google Ads or Meta Ads Manager accounts; and business performance data shared by clients for campaign strategy and reporting purposes.
All client business data is treated as strictly confidential in accordance with the confidentiality provisions of our Terms of Service. Client business data is used exclusively for the purpose of delivering the contracted services and is not used for any internal Million Global Leads purpose, is not shared with any third party beyond the service providers required to deliver the contracted services, and is not retained beyond the periods required by our legal obligations or specified in the Service Agreement.
Where clients are controllers of personal data belonging to their own customers and Million Global Leads processes that data on their behalf as a data processor, the parties will execute a Data Processing Agreement (DPA) if required by applicable law, particularly where clients are subject to GDPR requirements. Please contact us at contact@milliongloballeads.com to request a DPA.
Section 18: Changes to This Privacy Policy
We reserve the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will update the effective date at the top of this page and, where required by applicable law or where we determine appropriate, notify active clients via email. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Continued use of milliongloballeads.com or our services following the publication of a revised Privacy Policy constitutes your acceptance of the revised terms. The current version of this Privacy Policy is always accessible at milliongloballeads.com/privacy.
Contact
For all privacy-related questions, requests to exercise your data rights, Data Processing Agreement inquiries, or concerns about our data handling practices, please contact our privacy team using the following information:
Privacy Inquiries: contact@milliongloballeads.com (subject line: “Privacy Request”)
Phone: +1-346-641-4736
Postal Address: 490 Post St, Ste 500 PMB 2304, San Francisco, CA 94102, United States
Data Controller: Million Global Leads, operated by Hitesh Lamba
Contact Page: milliongloballeads.com/contact
We aim to respond to all privacy-related requests and inquiries within two (2) business days of receipt. For requests requiring identity verification before processing, we will confirm receipt immediately and request the necessary verification documentation promptly.
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