LEAD DELIVERY COMPLIANCE POLICY

Learn How We Validate, Verify, and Deliver Leads in a Compliant and Transparent Manner

See how we validate, verify, and deliver leads with full transparency, quality controls, and industry-standard compliance.

Last Updated: 26.11.2025
This Lead Delivery Compliance Policy (“Policy”) applies to all lead generation activities conducted by LeadClicks™, including CPL (Cost Per Lead), CPA (Cost Per Acquisition), Pay Per Call, and any other performance marketing engagements.

The purpose of this Policy is to ensure:

• Ethical lead generation
• Regulatory compliance
• Transparency
• Lead quality
• Protection for both the Client and LeadClicks
• Prevention of fraud or invalid traffic


By working with LeadClicks, Clients acknowledge and agree to this Policy.

DEFINITIONS

“Lead” – A user submission containing contact or qualifying data.
“Call Lead” – A qualified inbound call meeting duration + targeting rules.
“Conversion” – A measurable event such as a form submit, call, signup, or acquisition.
“Client” – Business purchasing leads or calls.
“Publisher/Traffic Source” – Any partner, ad platform, or channel delivering leads.
“Invalid Lead/Call” – A lead/call that does NOT meet compliance requirements.
“Validation Window” – Time allowed for Client to dispute invalid leads.

ACCEPTABLE SOURCES OF LEADS

LeadClicks generates leads using:
• Google Ads
• Meta Ads (Facebook/Instagram)
• TikTok Ads
• Bing/Microsoft Ads
• Twitter/X Ads
• YouTube Ads
• Native Ads (Taboola/Outbrain)
• Landing pages owned/managed by LeadClicks
• First-party lead funnels
• Call routing systems
• Server-side tracking systems


LeadClicks does NOT buy third-party co-reg lists or use unapproved traffic sources. Any traffic source outside LeadClicks’ internal ecosystem requires written Client approval.

SUBJECT MATTER & DURATION OF PROCESSING

Subject Matter

LeadClicks processes Personal Data only for the purpose of delivering:
• Lead generation (CPL, CPA, Pay Per Call)
• Paid media campaigns
• Tracking & analytics
• SEO services
• Landing page + funnel management
• CRM integrations
• Call tracking
• Conversion attribution
• Reporting & optimization

Duration

Processing continues for the duration of the Main Agreement and terminates when:
• Services end
• Data is returned or deleted
Unless retention is legally required.

PROHIBITED LEAD SOURCES

LeadClicks strictly prohibits:
• Purchased email lists
• Scraped or harvested data
• Incentivized leads
• Forced clicks
• Fake user submissions
• Bots or automated form-filling
• Spam calls or robocalls
• IVR spoofing
• Misleading ads
• Fake job postings, contests, or giveaways
• Cloaking or deceptive funnels
• Unapproved affiliate traffic


Violation results in immediate termination of source and invalidation of leads.

LEAD GENERATION COMPLIANCE

LeadClicks follows:
✔ GDPR (EU)
✔ CCPA/CPRA (California)
✔ TCPA (Telephone Consumer Protection Act – USA)
✔ CAN-SPAM (USA)
✔ DNC (Do Not Call) regulations
✔ NDNC/DND (India)
✔ PDPA (Singapore)
✔ LGPD (Brazil)
✔ POPIA (South Africa)
✔ Australian Privacy Act
✔ CASL (Canada)
All leads and calls must originate from:
• Users who voluntarily opt-in
• Valid consent forms
• Compliance-approved funnels
• Disclosures matching industry requirements
LeadClicks can provide sample disclosures upon request.

LEAD DELIVERY FORMAT

LeadClicks may deliver leads via:
• API
• CRM integrations (HubSpot, Salesforce, Zoho, Pipedrive, etc.)
• Webhook
• Email
• Spreadsheet or batch file
• Call routing platform
• Dialer integrations
Lead delivery method is defined in the Client’s onboarding process.

LEAD VALIDATION RULES (CPL / CPA)

A valid lead must:
• Contain accurate contact details (phone/email)
• Match geo-targeting parameters
• Match demographic or qualification filters agreed with the Client
• Be generated voluntarily by a real user
• Originate from a LeadClicks-managed funnel
• Pass bot/spam detection
• Not be a duplicate of another delivered lead
• Match all industry-specific rules (finance, insurance, legal, etc.)
Once LeadClicks validates the lead internally, it is marked as Billable unless disputed by the Client.

LEAD DISPUTE & VALIDATION WINDOW

Clients have a limited time to dispute leads.
Default validation window: 48–72 hours
(Exact window defined in IO or contract)
After the window:
• All leads are considered approved and billable
• No retroactive adjustments will be made
Accepted dispute reasons are listed below.

ACCEPTABLE DISPUTE REASONS (CPL / CPA)

A Client may dispute a lead ONLY if:
• Phone number invalid or unreachable
• Email invalid
• Duplicate lead delivered by LeadClicks
• Lead submitted outside target geo
• Lead did not submit form voluntarily
• Fraudulent/bot traffic discovered
• Lead contains incomplete mandatory fields
• Consumer denies submitting request (verifiable)
LeadClicks will investigate each dispute.

REJECTED DISPUTE REASONS (Not Acceptable)

Clients cannot dispute leads for:
• “Lead did not convert to sale”
• “Lead no longer interested”
• “Client could not contact lead”
• “Lead changed their mind”
• “Client did not follow up fast enough”
• “Client’s CRM failed to record the lead”
• “Not a good fit for the product/service (unless pre-filtered)”
• “Sales team unavailable to respond”
Performance marketing does not guarantee sale outcomes.

PAY PER CALL COMPLIANCE

Pay Per Call leads must:
• Meet minimum call duration (e.g., 30/45/60/90 sec)
• Originate from approved geos
• Match service category
• Be first-time callers
• Occur within approved business hours (if applicable)
• Be answered by the Client or call center
Calls may be invalidated if:
• Caller hangs up before minimum duration
• Spam or wrong number
• Repeat caller
• IVR or robodialer detected
• Caller outside approved geo
• Client’s line was busy or unavailable
If the Client does not answer calls, they remain billable unless otherwise agreed.

PROOF OF QUALITY & TRACKING

LeadClicks uses:
• Call recordings
• Call metadata (duration, timestamp, caller ID)
• Pixel-based tracking
• Server-side events
• CRM logs
• Lead form time stamps
• IP address screening
• Bot & spam detection
• Duplicate prevention systems
All validation data is available upon request.

FRAUD & COMPLIANCE PROTECTION

LeadClicks monitors:
• Bot traffic
• Fake email/phone patterns
• Suspicious user behavior
• Repeated IP submissions
• High-volume invalid calls
• Funnels used by publishers
• Ad source quality
LeadClicks reserves the right to:
• Pause campaigns
• Ban traffic sources
• Block IP ranges
• Investigate fraud
• Require re-verification
• Terminate relationships with abusive Clients or publishers

CLIENT RESPONSIBILITIES

Client agrees to:
• Provide accurate filters, qualification rules, and geo-targeting
• Answer calls during business hours (for Pay Per Call)
• Maintain compliance for their industry
• Communicate disputes within the validation window
• Not resell leads without written permission
• Securely store and use leads according to law
• Not misuse or spam leads
Client is solely responsible for:
• Sales follow-up
• Conversion outcomes
• CRM failures
• Internal compliance
• Delivering services to leads

INTELLECTUAL PROPERTY & LEAD OWNERSHIP

• Leads are delivered exclusively to the Client.
• Client owns the leads once delivered.
• LeadClicks retains ownership of all funnels, tracking setups, landing pages, and advertising materials.
• Clients may NOT share, resell, or redistribute leads unless contractually allowed.

TERMINATION FOR NON-COMPLIANCE

LeadClicks may immediately terminate lead delivery if the Client:
• Violates privacy laws
• Sells or redistributes leads
• Fails to pay invoices
• Misrepresents services to leads
• Violates TCPA, DNC, CAN-SPAM, GDPR, or other laws
• Engages in unethical or fraudulent behavior
All leads delivered prior to termination remain billable.

GOVERNING LAW

This Policy is governed by:
State of Florida
All disputes will be resolved in that jurisdiction.

CONTACT INFORMATION

For compliance or lead-quality questions:
LeadClicks™ — Compliance & Quality Assurance
Email: connect@leadclicks.co
Address: 4604 49th St N #5270, Saint Petersburg, FL 33709