# ProspectMiner Subscriber Privacy Policy
Effective Date: October 1, 2025
Last Updated: January 25, 2026
Applies to: Subscribers and prospective subscribers of ProspectMiner LLC's services. This policy does NOT apply to consumer prospects or leads delivered through ProspectMiner; consumer-facing privacy practices are governed by the separate Privacy Policy located at https://privacy.prospectminer.io/.
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## 1. Who We Are
ProspectMiner LLC ("ProspectMiner," "Company," "we," "us," or "our") is a Nevada limited liability company with its principal mailing address at PO Box 10547, Zephyr Cove, NV 89448. ProspectMiner operates a subscriber-facing platform that connects licensed mortgage and lending professionals with exclusive, qualified consumer leads, and provides ancillary subscription services described in the Subscriber Agreement.
This Subscriber Privacy Policy describes how we collect, use, disclose, retain, and protect information about Subscribers, prospective Subscribers, and visitors to the subscriber-facing portions of our website and services (collectively, "Subscriber Data" or "Your Information").
## 2. Scope and Acknowledgment
By creating an account, accessing the Service, or providing information to ProspectMiner as a Subscriber or prospective Subscriber, you acknowledge and agree to this Subscriber Privacy Policy in its entirety. If you do not agree, you must not access or use the Service.
This policy is governed by the laws of the State of Nevada, without regard to conflict-of-laws principles. To the maximum extent permitted by law, you waive any conflict-of-laws argument that another jurisdiction's privacy law applies to ProspectMiner's processing of your information, except where such waiver is prohibited by the law of your domicile.
## 3. Information We Collect
We collect, generate, and process the following categories of information about you:
### 3.1 Information You Provide Directly
- Identifying information: legal name, business name, business address, billing address, email address, phone number, NMLS license number, professional credentials, state(s) of licensure, federal tax identification information
- Account credentials: username, password (stored hashed), security questions
- Payment information: credit card last four digits, billing zip code, payment method type, billing history. Full payment card numbers are processed by our payment processor (currently Stripe) and are never stored on ProspectMiner's systems
- Communication data: emails, support tickets, chat messages, SMS, voice calls, voicemails, recorded interactions with our team
- Tax and compliance documentation: W-9 forms, license certifications, insurance certificates, training records you submit
### 3.2 Information We Collect Automatically
- Device data: IP address, device type, operating system, browser type and version, screen resolution, language settings, time zone, mobile network information
- Usage data: pages viewed, features used, click streams, dwell time, search queries, referring URLs, exit pages, login times, session duration
- Log data: server logs, error logs, access logs, audit logs of every action you take in the platform
- Cookies and similar technologies: session cookies, persistent cookies, web beacons, pixel tags, local storage objects, device fingerprints
- Communication metadata: timestamps, sender/recipient identifiers, channel (email/SMS/voice), delivery status, open/click data for marketing communications
### 3.3 Information We Collect From Third Parties
- Background and licensing verification data: NMLS database lookups, state regulator websites, credit bureau verifications (where consented)
- Channel partner referrals: information your channel partners (e.g., NAF, Rate, LoanDepot, SmartFi) provide to us when referring you to ProspectMiner
- Public records: business filings, professional license records, court records relevant to compliance
- Data enrichment vendors: business contact information, firmographic data, intent signals
### 3.4 Information From Third-Party Social Media Services
ProspectMiner allows you to create an account and log in to use the Service through the following Third-Party Social Media Services:
- Google
- Facebook
- Instagram
- X (Twitter)
- LinkedIn
If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal Data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities, or your contact list associated with that account.
You may also have the option of sharing additional information with ProspectMiner through your Third-Party Social Media Service's account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving ProspectMiner permission to use, share, and store it in a manner consistent with this Privacy Policy.
You acknowledge that whether ProspectMiner uses these Third-Party Social Media Services on your behalf, or whether you yourself use these services in connection with your account, the privacy policies, terms of service, and data practices of those Third-Party Social Media Services continue to apply to information processed through them. ProspectMiner has no control over, and assumes no responsibility for, the privacy practices of any Third-Party Social Media Service. Links to the relevant policies are provided in Section 7.
### 3.5 Information About Your Use of AI Features
Where you interact with AI-powered features of the Service, we collect your inputs (text, voice, file uploads), the AI's outputs returned to you, contextual metadata, and any feedback or corrections you provide. This information is used to operate the AI features, improve our services, monitor compliance, and as further described in Section 6.
## 4. How We Use Your Information
We use Subscriber Data for any lawful purpose, including but not limited to:
- Providing, maintaining, and improving the Service and our products
- Provisioning and managing your account, including authentication, account recovery, and security
- Processing payments, billing, fee adjustments, refunds, chargebacks, and collections
- Verifying your identity, licensure, and eligibility to use the Service
- Communicating with you about the Service, including service announcements, security notifications, billing communications, customer support responses, and policy updates
- Marketing and promoting our products and services to you, including via email, SMS, in-platform messaging, postal mail, telephone, and other channels permitted by law
- Personalizing your experience with the Service
- Conducting analytics, market research, and service improvement
- Detecting, preventing, investigating, and responding to fraud, abuse, security incidents, intellectual property violations, illegal activity, or violations of our agreements or policies
- Complying with applicable legal, regulatory, audit, tax, accounting, and reporting obligations
- Establishing, exercising, or defending legal claims
- Conducting due diligence and supporting corporate transactions including mergers, acquisitions, asset sales, financings, restructurings, bankruptcies, and similar events
- Training, fine-tuning, evaluating, validating, and improving ProspectMiner's proprietary artificial intelligence and machine learning models, except where such use is prohibited by law in your jurisdiction
- Enforcing our Terms of Use, Subscriber Agreement, and other contractual obligations
- Any other lawful business purpose that ProspectMiner determines is consistent with the operation of the Service
## 5. Legal Bases for Processing (For EU/UK/EEA Subscribers)
If the General Data Protection Regulation (GDPR), the UK GDPR, or equivalent data protection law applies to our processing of your information, we rely on one or more of the following legal bases:
- Contract: Processing necessary to perform our contract with you, including delivering the Service
- Legitimate Interests: Processing necessary for our legitimate interests in operating, securing, and improving the Service, marketing our products, preventing fraud, and defending our legal rights, balanced against your interests and fundamental rights
- Consent: Where we ask for and you provide specific consent (which you may withdraw at any time)
- Legal Obligation: Processing necessary to comply with a legal obligation
- Vital Interests: Processing necessary to protect your vital interests or those of another natural person
- Public Task: Where applicable
Where we rely on legitimate interests, you may object to that processing. We may continue processing if we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if processing is necessary for the establishment, exercise, or defense of legal claims.
## 6. Use of Your Data in AI and Machine Learning Systems
You expressly acknowledge and agree that ProspectMiner may use Subscriber Data, including the contents of your communications with us and your interactions with the Service, in the following AI-related ways:
(a) Operation of AI features. Routing your inputs through and storing outputs from third-party AI providers (such as Anthropic, OpenAI, Google, or other model providers) for the purpose of delivering AI features within the Service.
(b) Compliance and quality review. Analyzing your account activity, communications, and platform usage using automated AI-assisted compliance and quality review systems (the "Review System") to detect violations of the Subscriber Agreement, identify quality issues, monitor for fraud or abuse, and generate findings, recommendations, and audit records. The Review System may make automated assessments that influence ProspectMiner's actions toward your account, including flagging your account for human review or automated suspension where authorized by the Subscriber Agreement.
(c) Training and improvement. Training, fine-tuning, evaluating, and improving ProspectMiner's proprietary AI and machine learning models using Subscriber Data, including but not limited to: account configuration patterns, communication patterns with our team, support interactions, platform usage patterns, conversion outcomes you self-report, and aggregated metrics. We will not use your raw consumer-prospect lead data (the names, contact information, and qualification data of leads delivered to you) to train general-purpose models, but we reserve the right to use de-identified, aggregated, and anonymized data derived from that activity.
(d) Third-party AI processor restrictions. Where we use third-party AI providers (e.g., Anthropic Claude), we contractually require those providers not to retain your data for training their general-purpose models beyond ephemeral processing windows necessary to deliver responses, except where you have separately consented to such retention.
(e) No promise of human review. Decisions made by the Review System or other automated systems may not be subject to human review unless required by applicable law (such as GDPR Article 22). Where required by law, you may request human review of specific automated decisions affecting you by contacting [email protected].
(f) AI is provided as-is. AI-powered features may produce inaccurate, incomplete, or outdated information. ProspectMiner makes no representation or warranty regarding the accuracy of AI outputs and disclaims all liability arising from your reliance on them, except as required by applicable law.
## 7. Third-Party Services and Their Privacy Policies
ProspectMiner uses the following third-party service providers in the operation of the Service. Each provider has its own privacy policy that governs its handling of information, and you acknowledge that those policies apply in addition to this one. ProspectMiner is not responsible for the privacy practices of these third parties; we encourage you to review their policies.
| Provider | Purpose | Privacy Policy |
|---|---|---|
| Stripe | Payment processing, subscription billing | https://stripe.com/privacy |
| Supabase | Database, authentication infrastructure | https://supabase.com/privacy |
| n8n / hosted automation provider | Workflow automation | https://n8n.io/legal/privacy/ |
| Google (Workspace, Analytics, Login) | Email, analytics, social login | https://policies.google.com/privacy |
| X (Twitter) | Social login, social media presence | https://x.com/en/privacy |
This list may be updated from time to time as ProspectMiner changes service providers. The current list will always be accessible at https://subscriberprivacy.prospectminer.io/. ProspectMiner is not obligated to provide individual notice when adding or changing service providers, except where required by applicable law.
## 8. Disclosure of Information
We may disclose Subscriber Data to:
- Service providers and processors who perform functions on our behalf (such as those listed in Section 7)
- Channel partners who refer subscribers to us, where such disclosure is consistent with the referral relationship
- Professional advisors including legal counsel, accountants, auditors, insurers, and consultants
- Affiliates and subsidiaries of ProspectMiner
- Acquirers and successors in interest in connection with a merger, acquisition, asset sale, financing, restructuring, bankruptcy, dissolution, or similar transaction
- Law enforcement, regulatory authorities, courts, and government agencies in response to legal process, subpoenas, court orders, or where ProspectMiner reasonably believes disclosure is necessary to comply with law, protect ProspectMiner's rights or property, prevent fraud or harm, or protect the safety of any person
- Other parties with your consent or at your direction
## 9. Sale or Sharing of Personal Information
ProspectMiner does not sell Subscriber Data in exchange for monetary consideration. ProspectMiner reserves the right to share Subscriber Data with third parties for cross-context behavioral advertising, business operations, and service improvement purposes, which may constitute "sharing" or "sale" under certain state privacy laws (including the California Consumer Privacy Act as amended by the California Privacy Rights Act). Where such sharing applies to you and your jurisdiction grants opt-out rights, you may exercise those rights as described in Section 12.
## 10. Cookies and Tracking Technologies
ProspectMiner and our service providers use cookies, web beacons, pixels, local storage, and similar tracking technologies to operate the Service, remember your preferences, analyze usage, and deliver advertising. You can manage cookie preferences through your browser settings, but disabling cookies may impair the functionality of the Service.
For California residents, our Cookie Notice and Do Not Track signal handling are described separately at https://subscriberprivacy.prospectminer.io/cookies/.
## 11. Data Retention
We retain Subscriber Data for as long as necessary to provide the Service, comply with our legal obligations, resolve disputes, enforce our agreements, defend against legal claims, and operate our business. Specific retention periods vary by data category and may include:
- Account data: retained for the duration of your subscription plus seven (7) years after termination, or longer where required by law or for legal claims
- Communication records: retained for at least seven (7) years for compliance and audit purposes
- Payment and billing records: retained for at least seven (7) years for tax and accounting purposes
- Compliance and audit records: retained for at least ten (10) years
- Backup copies: may persist longer than primary records due to backup rotation cycles
Where you exercise a right of erasure under applicable law, we will delete or de-identify your personal data within the timeframe required by that law, subject to legal exceptions permitting continued retention.
## 12. Your Privacy Rights
The rights available to you depend on your jurisdiction. ProspectMiner is committed to honoring privacy rights as required by applicable law. To exercise any of the rights below, contact [email protected].
### 12.1 California Residents (CCPA, CPRA, CalOPPA)
You have the right to:
- Know what personal information we collect, use, disclose, and sell or share
- Access a copy of your personal information
- Delete your personal information, subject to legal exceptions
- Correct inaccurate personal information
- Opt out of the sale or sharing of your personal information
- Opt out of automated decision-making technology where required
- Limit the use and disclosure of sensitive personal information
- Non-discrimination for exercising your rights
To submit a request, email [email protected] or use our online form at https://subscriberprivacy.prospectminer.io/request/. You may designate an authorized agent to submit requests on your behalf, with appropriate verification.
For purposes of CalOPPA, ProspectMiner does not honor browser-based "Do Not Track" signals at this time, except where Global Privacy Control (GPC) signals are received in compliance with CCPA regulations.
### 12.2 Virginia, Colorado, Connecticut, Utah, and Other US State Privacy Laws
Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (Texas Data Privacy and Security Act), Oregon (Oregon Consumer Privacy Act), Montana (Montana Consumer Data Privacy Act), Iowa (Iowa Consumer Data Protection Act), Tennessee (Tennessee Information Protection Act), Indiana (Indiana Consumer Data Protection Act), Delaware (Delaware Personal Data Privacy Act), New Jersey (NJ Privacy Act), New Hampshire, Maryland, Minnesota, Rhode Island, and other US states with comprehensive privacy laws have rights generally including:
- Right to confirm processing
- Right to access personal data
- Right to correct inaccuracies
- Right to delete personal data
- Right to portability
- Right to opt out of targeted advertising, sale of personal data, and certain profiling
- Right to appeal denial of a privacy request
To exercise any of these rights, contact [email protected].
### 12.3 Nevada Residents
Nevada residents have the right under NRS Chapter 603A to opt out of the sale of certain "covered information" (as defined in the statute). To exercise this right, email [email protected] with the subject line "Nevada Sale Opt-Out."
ProspectMiner is a Nevada-domiciled LLC and conducts privacy operations in accordance with Nevada law, which may, where applicable and permissible, govern certain aspects of our processing where extraterritorial application of other states' laws is not legally compelled.
### 12.4 EU/UK/EEA Residents (GDPR, UK GDPR)
If you are located in the European Union, the United Kingdom, or the European Economic Area, you have the rights granted to data subjects under the GDPR or UK GDPR, including:
- Right of access (Article 15)
- Right to rectification (Article 16)
- Right to erasure / right to be forgotten (Article 17)
- Right to restriction of processing (Article 18)
- Right to data portability (Article 20)
- Right to object to processing (Article 21)
- Rights related to automated decision-making and profiling (Article 22)
- Right to withdraw consent at any time (where processing is based on consent)
- Right to lodge a complaint with a supervisory authority
ProspectMiner does not currently offer services targeted to EU residents but may do so in the future for insurance and merchant cash advance lead products. Where ProspectMiner processes personal data of EU/UK/EEA residents, the relevant rights under GDPR or UK GDPR will apply.
EU/UK/EEA Representative: [TO BE APPOINTED PRIOR TO ANY EU OPERATIONS]
EU/UK/EEA Data Protection Officer (where required): [TO BE APPOINTED PRIOR TO ANY EU OPERATIONS]
### 12.5 Other Jurisdictions
For residents of jurisdictions not enumerated above (including Canada, Brazil, Australia, and others), ProspectMiner will honor privacy rights as required by applicable law upon receipt of a verified request. Contact [email protected].
### 12.6 Verification of Requests
Before we fulfill any rights request, we will verify your identity to a degree of certainty appropriate to the request and the sensitivity of the data involved. We may decline requests we cannot verify, requests that are unfounded or excessive, requests that would adversely affect the rights of others, or requests subject to other legal exceptions.
### 12.7 Response Timeframes
We will respond to verified privacy rights requests within the timeframes required by applicable law (generally 30-45 days, with extensions permitted for complex requests). If we decline a request in whole or in part, we will explain our basis for declining and inform you of any appeal rights.
## 13. International Data Transfers
ProspectMiner is based in the United States. Information you provide will be transferred to and processed in the United States and any other country in which ProspectMiner or its service providers operate. By using the Service, you consent to such transfers.
Where required by law (including for transfers from the EU/UK/EEA to the United States), ProspectMiner relies on Standard Contractual Clauses, the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, or other lawful transfer mechanisms.
## 14. Security
ProspectMiner implements commercially reasonable administrative, technical, and physical safeguards designed to protect Subscriber Data from unauthorized access, use, disclosure, alteration, and destruction. However, no system is completely secure, and ProspectMiner cannot guarantee the absolute security of any information. You are responsible for safeguarding your own credentials and devices used to access the Service.
In the event of a confirmed data security incident affecting your personal information, ProspectMiner will provide notice as required by applicable law.
## 15. Children's Privacy
The Service is not directed to individuals under eighteen (18) years of age, and ProspectMiner does not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from someone under 18 without verifiable parental consent, we will delete that information.
## 16. Confidentiality of Subscriber Communications
Information you communicate to ProspectMiner support, sales, or other personnel may be retained, reviewed, and used by ProspectMiner for any business purpose described in this policy, including training of personnel and AI systems. Communications with ProspectMiner are not subject to attorney-client privilege, accountant-client privilege, or other professional confidentiality unless explicitly established by separate written engagement with a licensed professional.
## 17. Right to Update This Policy
ProspectMiner reserves the unilateral right to update, modify, replace, or discontinue this Subscriber Privacy Policy at any time, in its sole discretion, without prior notice except where notice is required by applicable law. The effective date and last-updated date at the top of this policy will reflect the most recent revision.
It is YOUR responsibility, as a Subscriber or prospective Subscriber, to review this Subscriber Privacy Policy periodically for changes. Your continued access to or use of the Service following the posting of an updated policy constitutes your binding acceptance of the updated terms.
ProspectMiner is not obligated to provide individualized notice of changes to this policy, except where required by applicable law. We may, in our discretion, provide notice through email, in-platform notification, posting at https://subscriberprivacy.prospectminer.io/, or other reasonable means.
If you do not agree to an updated policy, your sole remedy is to discontinue use of the Service and terminate your subscription in accordance with the Subscriber Agreement. Termination does not entitle you to a refund except as provided in the Subscriber Agreement, and amounts owed to ProspectMiner remain payable.
## 18. Severability and Conflict
If any provision of this Subscriber Privacy Policy is held to be invalid, illegal, or unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions will not be affected. To the extent permitted by law, any invalid provision will be reformed to the minimum extent necessary to make it valid and enforceable while preserving the parties' intent.
In the event of a conflict between this Subscriber Privacy Policy and the Subscriber Agreement, the Subscriber Agreement controls except with respect to specific privacy rights granted under applicable law that cannot be contractually waived.
## 19. Contact
For privacy questions, requests, or complaints, contact:
ProspectMiner LLC
Attn: Privacy
PO Box 10547
Zephyr Cove, NV 89448