Data Processing Agreement

This Data Processing Agreement ("DPA") is entered into between HMD Consulting Group, LLC DBA Clear Choice Marketing Group ("Company") and the buyer ("Buyer") accessing the lead marketplace platform at leads.clearchoicemg.com.

Purpose

This DPA governs the processing of consumer personal data shared through the Platform in accordance with applicable data protection laws, including the California Consumer Privacy Act (CCPA) and, where applicable, the General Data Protection Regulation (GDPR).

Data Sources

Consumer personal data available on the Platform may originate from:

• Company-owned and operated websites, landing pages, and marketing campaigns.
• Third-party publishers and affiliate partners operating under written data sharing and compliance agreements with the Company.
• Inbound call and live transfer sources where consumers initiate contact through Company or publisher phone campaigns.

Data Shared with Buyers

The Company may share the following with approved Buyers:

• First name, last name.
• Phone number, email address.
• Geographic data including state and ZIP code.
• Vertical-specific data such as estimated debt amount, insurance type, loan amount, and tax liability.
• Lead source identifier, consent record, and opt-in timestamp.

Buyer Obligations

By purchasing leads, Buyer agrees to:

• Process personal data only for the legitimate business purpose for which it was purchased.
• Implement appropriate technical and organizational security measures.
• Not sell, rent, or share consumer personal data with unauthorized third parties.
• Honor all consumer data subject requests including access, deletion, and correction.
• Notify the Company within 72 hours of any data breach involving purchased leads.
• Delete or de-identify consumer data when no longer needed.

Company Obligations

The Company agrees to:

• Ensure consumer data is collected with proper consent through owned properties and require the same of all publishers and affiliates.
• Maintain consent records and lead source documentation available to Buyers upon request.
• Notify Buyers of any known data quality or consent deficiencies.
• Cooperate with Buyers in responding to regulatory inquiries.

Sub-Processors

• Stripe for payment processing.
• Supabase for database, authentication, and data storage.
• Vercel for hosting and infrastructure.
• GoHighLevel (GHL) for CRM and lead routing automation.

Data Retention

Buyers should retain consumer lead data only as long as necessary for the intended business purpose. Buyers are solely responsible for their own data retention, archival, and deletion policies.

Governing Law

This DPA is governed by the laws of the State of California. Any disputes shall be resolved in Ventura County, California.

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