Privacy Policy

X5 Ventures LLC, doing business as REI Leads (“REI Leads,” “we,” “us,” or “our”), operates reileads.com and the REI Leads platform, including the client dashboard, lead delivery tools, integrations, and related services (together, the “Platform”). This Privacy Policy explains how we collect, use, share, and protect personal information from the people who use the Platform on behalf of a business.

This policy applies to:

• Real estate investors, investment companies, and other businesses that purchase leads or subscribe to services from REI Leads (“Clients”);
• Employees, owners, agents, and other individuals who act on behalf of a Client or a prospective Client;
• Anyone who visits reileads.com, requests information, attends a demo, or communicates with us about our services.

This policy does not cover consumer data. REI Leads generates leads from homeowners and property sellers through separate consumer-facing websites and marketing channels. The collection, use, and sharing of that information is governed by our Consumer Privacy Policy. Nothing in this document describes or limits how consumer lead data is handled.

This policy is part of, and incorporated into, our Terms of Service and any Client agreement you have with us. Capitalized terms not defined here have the meaning given in those documents.

Before the details, here is what we want every Client to know:

The rest of this policy explains how we live up to those commitments.

We use the information described above to:

• Create and manage your account and verify your identity and business status;
• Deliver purchased leads to you through the dashboard, email, text, or your connected systems;
• Route and price leads according to your preferences, budget, and markets;
• Bill you, process payments, apply credits and refunds, and maintain accounting records;
• Provide customer support and respond to your questions and requests;
• Send transactional messages about your account, lead deliveries, billing, and service changes;
• Send marketing communications about REI Leads products, features, and offers, which you can opt out of at any time;
• Improve the Platform, lead quality, routing, and the client experience, including through aggregate analysis of Performance Data;
• Detect and prevent fraud, abuse, security incidents, and violations of our Terms;
• Comply with legal obligations, enforce our agreements, and protect our rights and the rights of others.

We do not use Client information to make decisions about you that have legal or similarly significant effects without human involvement.

We do not sell Client information. We share it only in the following circumstances:

• Service providers. With vendors who perform services for us, such as cloud hosting, payment processing, email and SMS delivery, customer support tools, analytics, and accounting. These providers are bound by contract to use your information only to provide services to us and to protect it appropriately.
• Payment processors. With our payment processors to complete transactions you initiate. See Section 3.3.
• At your direction. With your CRM or other systems you choose to connect, and with any other party when you ask us to share.
• Legal and compliance. When required by law, subpoena, court order, or government request, or when we believe disclosure is necessary to comply with law or protect the rights, property, or safety of REI Leads, our Clients, or the public.
• Security and fraud. As needed to investigate or prevent fraud, abuse, security incidents, or violations of our Terms.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business. If that happens, your information will remain subject to this policy until it is updated with notice to you.
• Affiliates. With companies under common ownership with REI Leads, who will handle your information consistent with this policy.

We may share aggregated or de-identified information that cannot reasonably be used to identify you or your business, such as market-level lead volume and conversion benchmarks, with partners, in marketing materials, or publicly. We will not attempt to re-identify de-identified data.

Advertising cookies are a separate matter. If you visit reileads.com, third-party advertising and analytics providers may collect information through cookies and pixels as described in Section 8. Some U.S. state laws treat that kind of disclosure as “sharing” or a “sale,” even though no money changes hands and no account or lead data is involved. Section 8 explains how to opt out.

• We use Performance Data to evaluate lead quality, process credit requests, improve our lead sources, and improve how leads are scored and routed across the Platform.
• We do not disclose your individual Performance Data to any other Client. Another Client will never see which leads you bought, what you did with them, or what you closed.
• We may use Performance Data in aggregate, combined with data from many Clients, to publish benchmarks or improve our models. Aggregate data does not identify you, your business, or your specific transactions.
• We do not sell Performance Data or use it to market our leads to any party other than you.

When you connect a third-party system to REI Leads, two things happen: we push lead data into that system on your behalf, and we hold the credentials that make that possible. We protect those credentials as described in Section 3.4. Once a lead is delivered into your system, that system's provider handles the data under its own terms and privacy policy, not ours. You are responsible for the security of your own connected systems and for any access you grant to others within them.

You can review and disconnect any integration from your dashboard at any time. Disconnecting stops future deliveries and triggers deletion of the associated credentials.

If you provide a mobile number and opt in, we may send you text messages about lead deliveries, account activity, and, with separate consent, marketing offers. Message frequency varies. Message and data rates may apply. Reply STOP to stop and HELP for help.

We do not sell, rent, or share mobile phone numbers, text message opt-in data, or text message content with any third party for their own marketing or promotional purposes. We share mobile numbers only with the SMS delivery providers we use to send messages, and they are contractually prohibited from using that information for any other purpose. You may remove your numbers at any time via the portal.

We maintain administrative, technical, and physical safeguards designed to protect Client information, including:

• Encryption of data in transit (TLS) and at rest;
• Role-based access controls and least-privilege access for our staff;
• Hashed password storage and support for multi-factor authentication;
• Encrypted storage of integration credentials;
• Logging and monitoring of access to production systems;
• Use of PCI-DSS compliant payment processors so that card numbers never enter our environment.

No system is perfectly secure. If we learn of a security incident that affects your personal information, we will notify you without undue delay and in any event within the time required by applicable law, and we will tell you what happened, what information was involved, and what we are doing about it.

We keep Client information for as long as your account remains in our system. In general:

• Account and contact information: for the life the account remains in the system (active or canceled);
• Integration credentials: deleted when the integration is disconnected or the account is closed;
• Support communications: indefinitely;
• Security and access logs: indefinitely;
• Marketing consent and opt-out records: for as long as needed to honor your choices and demonstrate compliance.

We serve real estate investors across Canada, and we handle Canadian Clients' personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, including Quebec's Act respecting the protection of personal information in the private sector (Law 25).

• Consent: we collect, use, and disclose personal information with your consent, which may be express or, where reasonable, implied from the business relationship. You may withdraw consent at any time, subject to legal and contractual limits, and we will explain the consequences of doing so.
• Purpose limitation: we collect only what is needed for the purposes described in this policy and do not use it for new purposes without telling you and, where required, obtaining your consent.
• Access and correction: you may request access to the personal information we hold about you, ask how it has been used and to whom it has been disclosed, and request correction of inaccurate information. We will respond within 30 days.
• Cross-border storage: your information is stored and processed in the United States and may be accessed by U.S. authorities under U.S. law. By using the Platform you acknowledge this transfer.
• Electronic messages:we send commercial electronic messages only with consent that complies with Canada's Anti-Spam Legislation (CASL). Every message includes our identification and an unsubscribe mechanism that we honor within 10 business days.

If you are not satisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information.

The Platform is a business service and is not intended for anyone under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us information, contact us and we will delete it.

REI Leads is based in Texas. Information is stored and processed in the United States. If you access the Platform from outside the U.S., you understand that your information will be transferred to, stored in, and processed in the United States, where privacy laws may differ from those in your jurisdiction.

The Platform may link to third-party websites, tools, or services, including your connected CRM and our payment processors. We are not responsible for their privacy practices. Review their policies before providing information to them.

We may update this policy as our practices, technology, or the law change. When we do, we will update the “Last updated” date above. If a change materially affects how we use or share Client information, we will give you advance notice by email to the address on your account, by a notice in the dashboard, or both, before the change takes effect. Your continued use of the Platform after the effective date means you accept the updated policy.

Questions, requests, or concerns about this policy can be sent to: