Rapid Response Marketing, LLC — operating Xy7Elite.com and Elite-Calls.com. This policy supersedes the Privacy Policy dated September 14, 2016.

1. Who This Policy Covers

This Privacy Policy describes how Rapid Response Marketing, LLC ("Rapid Response," "we," "us") collects, uses, discloses, and protects personal information. It applies to:

• Xy7Elite.com — our performance marketing network for publishers and advertisers
• Elite-Calls.com — our pay-per-call marketing services
• any other website, landing page, or service that links to this policy (collectively, the "Sites")

It covers both consumers who submit information or place calls through our Sites and campaigns, and business users — publishers, advertisers, and partners — who hold accounts with us.

If you are a California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or other state privacy law resident, Section 9 sets out your rights and how to exercise them.

2. Summary

We are a marketing company. Our business is connecting consumers who are actively seeking products or services — such as insurance quotes, home services, or benefits information — with the companies that provide them.

That means: if you submit a form or place a call through one of our campaigns, we share your information with the companies you asked to hear from, and with a limited number of service providers who help us deliver and verify that connection. We describe exactly who, and why, below.

We do not sell information about you that you did not submit to us in connection with a request. We do not knowingly collect information from children. You can opt out of the sale or sharing of your personal information at any time using the methods in Section 10.

3. Personal Information We Collect

Identifiers. Name, postal address, email address, telephone number, IP address, and unique online or device identifiers.

Commercial and transactional information. Products or services you inquired about, campaign or offer identifiers, the publisher or source that referred you, and records of the connections we made on your behalf.

Internet and network activity. Browser type, operating system, referring URL, pages viewed, timestamps, and interactions with our Sites and landing pages, collected through cookies, pixels, and similar technologies.

Audio information. Recordings and, in some cases, transcripts of telephone calls placed to or from our campaigns. See Section 6.

Consent and compliance records. The webpage or script through which you provided consent, the timestamp and IP address associated with it, the disclosure text you were shown, and related records we retain to demonstrate compliance with telemarketing law.

Approximate location. Derived from your IP address or the postal code or state you provide.

Sensitive personal information. Certain campaigns relate to health insurance, Medicare, Affordable Care Act coverage, or disability benefits. Where you provide it, we may collect information such as age, general health-related interest, or eligibility indicators. We collect this only to route your inquiry to a licensed agent or provider, and we do not use or disclose it for purposes beyond that without your consent. See Section 10 for your right to limit its use.

Business account information. For publishers and advertisers: business name, contact details, tax identification information, and payment details necessary to process amounts owed. We do not collect government identification numbers, financial account numbers, or precise geolocation from consumers through our campaigns.

4. Where We Get It

• Directly from you — forms you complete, calls you place or accept, and account information you provide.
• From our publishers and traffic partners — where you responded to an advertisement or landing page operated by a partner who then transmits your inquiry to us. We contractually require these partners to obtain lawful consent and to provide the consent records described in Section 3.
• Automatically — through cookies, pixels, and server logs when you visit our Sites.
• From verification and compliance vendors — such as phone number validation, litigator and do-not-call scrubbing, and lead verification services.

5. How We Use Personal Information

• To connect you with the advertiser, insurer, agent, or service provider you requested
• To verify that your inquiry is genuine and that consent was properly obtained
• To monitor and score call quality, agent performance, and campaign compliance
• To operate, secure, troubleshoot, and improve our Sites and services
• To calculate amounts owed to publishers and amounts billable to advertisers
• To respond to your questions and privacy requests
• To detect and prevent fraud, abuse, and unauthorized activity
• To comply with law, respond to legal process, and enforce our agreements

We do not use automated decision-making that produces legal or similarly significant effects about you, and we do not use consumer data or call recordings to train artificial intelligence or machine learning models.

6. Call Recording and Monitoring

Calls placed to or from our campaigns may be recorded and monitored for quality assurance, compliance verification, training, and dispute resolution. Where recording occurs, you are notified at the start of the call and may decline to proceed.

Recordings and any transcripts are treated as confidential information. They are accessible only to personnel and approved service providers with a business need, are retained only as long as required for the purpose collected or by contract, and are not sold.

7. How We Share Personal Information

With the companies you asked to hear from. When you submit a request or place a call, we transmit your information to one or more advertisers, insurers, licensed agents, or service providers matched to your inquiry. Once transmitted, that company's own privacy policy governs its use of your information. This transfer is the core of our service, and under several state privacy laws it constitutes a "sale" or "sharing" of personal information. You may opt out — see Section 10.

With service providers. Companies that host our systems, route and record calls, validate telephone numbers, scrub against do-not-call and litigator lists, verify leads, and provide analytics. These vendors are contractually restricted to processing personal information only on our instructions and only to deliver the service.

With publishers and traffic partners. Limited to what is required to reconcile and pay for traffic — typically call connection, duration, and originating telephone number for calls the partner itself originated. Partners are bound by confidentiality obligations and do not receive call recordings, transcripts, or other publishers' data.

For legal and safety reasons. In response to subpoenas, court orders, regulatory demands, or lawful requests; to establish, exercise, or defend legal claims; to investigate suspected fraud or violations of our terms; and where required by applicable law.

In a corporate transaction. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this policy or notice of any material change.

We do not disclose personal information to third parties for their own independent marketing purposes except as described in this section.

8. Cookies and Tracking

We and our partners use cookies, pixels, web beacons, and similar technologies to operate our Sites, measure campaign performance, and attribute conversions. Most browsers allow you to refuse or delete cookies; some features may not function if you do.

We honor Global Privacy Control (GPC) signals as a valid opt-out of sale and sharing for the browser transmitting the signal, where required by law.

9. Your Privacy Rights

Depending on your state of residence, you may have the right to:

• Know and access — the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients
• Delete — request deletion of personal information we hold about you
• Correct — request correction of inaccurate personal information
• Opt out of sale or sharing — direct us to stop selling or sharing your personal information, including for cross-context behavioral advertising
• Limit use of sensitive personal information — restrict our use of sensitive personal information to what is necessary to provide the service
• Portability — receive a copy in a portable format
• Appeal — where your state provides it, appeal a decision we make about your request
• Non-discrimination — we will not deny service, charge a different price, or provide a different quality of service because you exercised a privacy right

Legal bases and exemptions. We may decline a request where an exemption applies, including where retention is required to comply with telemarketing recordkeeping obligations or to establish or defend legal claims. Where we decline, we will tell you why.

10. How To Exercise Your Rights

Email: privacy@xy7elite.com
Mail: Rapid Response Marketing, LLC, Attn: Privacy, 7500 W. Lake Mead Blvd. #9-463, Las Vegas, NV 89128
Phone: (702) 848-3954

To opt out of sale or sharing, email privacy@xy7elite.com with the subject line "Do Not Sell or Share My Personal Information" and include the telephone number and email address you used, or transmit a Global Privacy Control signal from your browser.

To limit the use of sensitive personal information, email privacy@xy7elite.com with the subject line "Limit the Use of My Sensitive Personal Information."

Verification. We will ask you to provide information matching what we hold — typically the telephone number and email address associated with your inquiry — so we can confirm your identity before acting. We use that information only to verify your request.

Authorized agents may submit requests on your behalf with written authorization signed by you, and we may contact you to confirm.

Timing. We acknowledge requests within 10 business days and respond within 45 days, extendable by a further 45 days where permitted, with notice to you.

11. Telephone Contact, Consent, and Do Not Call

Where you provided consent to be contacted by telephone or text, you may revoke that consent at any time by telling the caller, replying STOP to a text message, or emailing privacy@xy7elite.com. Revocation takes effect promptly and applies to future contact.

We maintain an internal do-not-call list, honor the National Do Not Call Registry, and require our publishers and traffic partners to obtain and evidence lawful prior express written consent before transmitting an inquiry to us.

To be added to our internal do-not-call list, email privacy@xy7elite.com with the subject line "Do Not Call."

12. Retention

We retain personal information only as long as necessary for the purpose collected, to meet contractual obligations to our clients, and to satisfy legal and telemarketing recordkeeping requirements — including retaining consent records for the period required to demonstrate compliance. When no longer required, information is deleted or destroyed in accordance with our internal disposal procedures.

13. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including multi-factor authentication on systems holding personal information, access limited to those with a business need, encrypted transmission, use of company-managed devices, and a documented incident response process. No system is completely secure, and we do not guarantee absolute security.

14. Children

Our Sites and services are directed to adults. We do not knowingly collect personal information from anyone under 16. If we learn we have collected such information, we will delete it. We do not sell or share the personal information of consumers we know to be under 16.

15. Other Websites

Our Sites and campaigns contain links to, and transmit inquiries to, companies we do not control. This policy does not govern their practices. We encourage you to review the privacy policy of any company you are connected with.

16. Data Location

We are based in the United States and our systems are operated in the United States. Certain service providers and call center partners may operate outside the United States, and personal information may be processed by them in the course of delivering services. Where that occurs, those partners are bound by contractual confidentiality and data protection obligations.

17. Changes To This Policy

We may update this policy to reflect changes in our practices or applicable law. We will revise the "Last updated" date above and, where changes are material, post notice on our Sites. Your continued use after an update indicates acceptance of the revised policy.

18. Contact Us

Rapid Response Marketing, LLC
Attn: Privacy
7500 W. Lake Mead Blvd. #9-463
Las Vegas, NV 89128
Email: privacy@xy7elite.com
Phone: (702) 848-3954