Privacy Policy
1. INTRODUCTION AND SCOPE
pagaleads.com ("Paga Leads," "we," "us," or "our") is a specialist lead generation service connecting California workers who have experienced potential wage violations, employment law violations, or personal injury incidents with licensed California attorneys ("Participating Law Firms").
This Privacy Policy governs the collection, use, storage, transfer, and deletion of personal information obtained through our websites, landing pages, intake funnels, qualification quizzes, and all related digital properties (collectively, the "Platform").
This Policy is designed to satisfy all disclosure obligations of pagaleads.com under the following applicable laws and regulatory frameworks:
• California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), Cal. Civ. Code §1798.100 et seq.
• Federal Telephone Consumer Protection Act (TCPA), 47 U.S.C. §227, including 2025 FCC consent revocation updates effective April 11, 2025
• Federal CAN-SPAM Act, 15 U.S.C. §7701 et seq.
• Federal Trade Commission Act (FTC Act), 15 U.S.C. §41 et seq., including FTC guidelines on endorsements and deceptive advertising
• California Business & Professions Code including §6155 (attorney referral services)
• California Civil Code §1798.82 (data breach notification)
• California Invasion of Privacy Act (CIPA)
• Meta Platform advertising policies including Employment Special Ad Category requirements
• California Rules of Professional Conduct Rules 7.1–7.3 (attorney advertising and solicitation — applicable to Participating Law Firms)
By submitting information through our Platform or by contracting to receive leads from our Platform, you acknowledge and agree to the practices described in this Policy.
2. INFORMATION WE COLLECT
A. Information Provided by Consumers (Lead Submitters)
We collect the following categories of personal information from individuals who submit inquiries through our Platform:
Identifiers:
• Full name
• Email address
• Phone number
• General geographic location (city, county, zip code)
Employment and Professional Information:
• Current or former employer name and industry
• Job title or role
• Employment status (current or former employee)
• Nature of alleged wage or employment law violation
• Approximate dates of employment
• Whether the individual has personally experienced a qualifying violation (required under post-2024 PAGA reform standing requirements)
Incident Information (Slip & Fall Leads):
• Date and general location of incident
• Nature of injury reported by the claimant
• Whether medical treatment was sought
• Confirmation that incident occurred on third-party premises
• Confirmation that incident occurred within California's 2-year statute of limitations for personal injury
Consent and Compliance Records:
• TrustedForm certificate URL (ActiveProspect)
• Timestamp of form submission
• IP address at time of submission
• The exact consent language displayed to and agreed to by the individual at point of submission
• Session interaction record (where TrustedForm session recording is active)
Device and Technical Information:
• Browser type and version
• Device type and operating system
• IP address
• Referring URL and page URL at time of submission
• Mobile network information where applicable
We do not collect Social Security numbers, financial account numbers, government-issued identification numbers, full medical records, or sensitive health information through our Platform.
B. Information Provided by Participating Law Firms (Business Clients)
We may collect the following information from law firms and attorneys who contract with us to receive leads:
• Contact information: name, email address, phone number, firm name, and mailing address
• Business information: firm size, practice areas, geographic coverage, lead volume requirements
• Account information: username, password, and other registration details
• Payment information: billing details processed securely through Stripe (we do not store full card numbers)
• Communication data: information provided when contacting our support team or account management
• Webhook and CRM integration credentials provided for lead delivery purposes
C. Information Collected Automatically
When any user accesses our Platform, we automatically collect certain information, including:
• Usage Data: pages viewed, links clicked, time spent on pages, and other usage statistics
• Device Information: IP address, browser type, operating system, device identifiers
• Cookies and Tracking Technologies: we use cookies, web beacons, Meta Pixel, and similar technologies to collect information about browsing activity and campaign performance. You can control cookies through your browser settings.
D. Information from Third Parties
We may receive supplemental information from the following third-party sources:
• Meta Platforms (Facebook/Instagram): advertising delivery data, lead form completions, and campaign performance data
• TrustedForm / ActiveProspect: independent consent certificate data generated at point of form submission
• GoHighLevel: CRM workflow and automation data
• Analytics providers: anonymised usage and traffic data
3. HOW WE USE YOUR INFORMATION
We use the information we collect for the following specific purposes:
• Lead Qualification and Delivery: to evaluate whether an individual may have a qualifying legal claim and to transfer their contact information and claim details to a single Participating Law Firm for the purpose of an attorney consultation
• Provide and Improve Services: to deliver leads, process transactions, monitor lead quality, and improve our Platform
• Communication: to respond to enquiries, send service updates, and provide customer and account support
• Compliance Documentation: to generate and retain TrustedForm consent certificates and internal lead delivery records for quality assurance and dispute resolution
• Marketing to Law Firms: to send promotional materials, service updates, and newsletters to Participating Law Firms (firms may opt out at any time)
• Analytics: to analyse usage patterns, track campaign performance, and optimise our Platform and advertising
• Legal Compliance: to comply with applicable federal and California state legal obligations and to enforce our Terms of Service
• Fraud Prevention: to detect, prevent, and address fraudulent lead submissions, bot activity, and other harmful activities
We do NOT use personal information collected from consumers for:
• General marketing or advertising purposes unrelated to the individual's submitted legal inquiry
• Sale to data brokers, list brokers, or third-party marketing companies
• Profiling or automated decision-making unrelated to lead qualification
• Any purpose materially different from those disclosed at the point of collection
4. TCPA CONSENT, FCC COMPLIANCE, AND COMMUNICATION
A. Prior Express Written Consent
Before any consumer's personal information is transferred to a Participating Law Firm, pagaleads.com obtains prior express written consent (PEWC) from the individual as required under the TCPA (47 U.S.C. §227) and applicable FCC regulations.
Consent is obtained through clear and conspicuous disclosure language displayed immediately adjacent to the form submission button on every intake page. This consent language includes explicit disclosure that:
• The individual is consenting to be contacted by a California-licensed attorney regarding their potential legal claim
• Contact may be made by telephone call, automated dialling system, pre-recorded message, or SMS text message
• Consent is not a condition of receiving any service
• The individual may revoke consent at any time
• The specific attorney or law firm that will contact them is identified or described
Important 2025 FCC Update: The FCC's one-to-one consent rule was struck down by the Eleventh Circuit Court of Appeals in January 2025. However, the FCC's separate 2025 TCPA updates around consent revocation took effect on April 11, 2025. pagaleads.com honours all consent revocation requests within 10 business days as required under updated TCPA regulations.
B. Consent Revocation
Consumers may revoke their consent to be contacted at any time by:
• Replying STOP to any SMS message received
• Emailing [email protected] with the subject line: Revoke Consent
• Calling our compliance line and requesting removal
Upon receipt of a revocation request, pagaleads.com will notify the relevant Participating Law Firm within 24 hours. Participating Law Firms must honour revocation requests and cease all contact immediately. Revocation requests are processed within 10 business days in compliance with April 2025 FCC requirements.
C. Do Not Call Registry
pagaleads.com and Participating Law Firms must comply with both the Federal Do Not Call Registry and the California Do Not Call list. California maintains stricter rules than federal requirements. Participating Law Firms must maintain an internal Do Not Call list for a minimum of 10 years in accordance with California requirements.
D. Contact Timing
pagaleads.com delivers leads in real time at the moment of submission. Participating Law Firms are advised that TCPA risk and contact rate success both diminish significantly with contact delay. We strongly recommend initial contact within 5 minutes of lead delivery and only during TCPA-approved hours (8am–9pm local time of the recipient).
5. LEAD DISTRIBUTION, EXCLUSIVITY, AND LAW FIRM DISCLOSURE
A. Lead Distribution to Participating Law Firms
pagaleads.com operates as a lead generation service. When a consumer submits their information through our intake Platform, we transfer that information to a single contracted Participating Law Firm for the purpose of an attorney consultation regarding their potential legal claim.
B. Exclusivity Commitment
Each lead generated through our Platform is delivered exclusively to one Participating Law Firm. We do not resell, redistribute, recycle, or repackage leads to multiple buyers. Each lead record is transmitted once, to one firm, in real time.
C. Consumer Consent to Transfer
By submitting information through our Platform, consumers expressly consent to having their personal information transferred to a California-licensed attorney or law firm for the purpose of receiving a confidential legal consultation regarding their submitted inquiry. This consent is documented by TrustedForm certificate at the moment of submission.
D. Nature of Service — We Are NOT a Lawyer Referral Service
pagaleads.com operates as a lead generation service and does not constitute a lawyer referral service as defined under California Business & Professions Code §6155. We do not recommend, endorse, or refer consumers to specific attorneys. We deliver contact information and documented consent records to law firms for their own independent follow-up. Participating Law Firms are solely responsible for determining whether to represent any individual whose information they receive.
6. HOW WE SHARE INFORMATION
We share personal information only in the following specific circumstances:
• Participating Law Firms: we share lead information exclusively with the single contracted law firm designated to receive each lead, strictly for the purpose of an attorney consultation related to the individual's disclosed legal matter
• Service Providers: we share limited information with third-party vendors who perform services on our behalf, including TrustedForm/ActiveProspect (consent documentation), GoHighLevel (CRM and workflow automation), Stripe (law firm payment processing only), Meta Platforms (advertising delivery), and email/SMS delivery providers. All service providers are engaged under contractual data processing obligations.
• Legal Compliance: we may disclose information to comply with legal obligations, respond to lawful requests from government authorities or courts, enforce our agreements, or protect our legal rights
• Business Transfers: in the event of a merger, acquisition, or sale of assets, consumer and law firm information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy
• With Explicit Consent: we may share information with third parties where explicit consent has been provided for that specific sharing
We do NOT sell or rent personal information to third parties for their independent marketing purposes. We do NOT share consumer personal information for cross-context behavioural advertising.
7. TRUSTEDFORM AND CONSENT DOCUMENTATION
pagaleads.com deploys TrustedForm technology (ActiveProspect) on every lead intake page. At the moment of every form submission, TrustedForm generates an independent, timestamped certificate that constitutes a third-party record of:
• The exact consent language the consumer was shown at point of submission
• The timestamp of the submission and consent event
• The IP address of the consenting party
• A session interaction record documenting the consumer's engagement with the intake page
• The URL of the page on which consent was obtained
Every lead delivered by pagaleads.com is accompanied by a TrustedForm certificate URL. Participating Law Firms are strongly advised to:
• Retain the TrustedForm certificate URL for every contact made with a pagaleads.com lead
• Store the certificate as part of their own compliance records
• Present the certificate in the event of any TCPA dispute or regulatory inquiry
The TrustedForm certificate is your primary independent defence in the event of a TCPA complaint. Do not discard it. Retain for a minimum of 5 years from date of lead receipt.
8. COOKIES AND TRACKING TECHNOLOGIES
We use cookies, web beacons, pixels, and similar technologies to collect information about usage of our Platform and to measure advertising campaign performance.
Types of Cookies We Use:
• Essential Cookies: necessary for the operation of our Platform and intake forms
• Analytics Cookies: help us understand how users interact with our Platform (Google Analytics, etc.)
• Advertising Cookies: Meta Pixel and similar technologies used to measure campaign performance and optimise lead generation advertising
• Preference Cookies: remember settings and preferences for returning visitors
You can control cookies through your browser settings. Note that disabling essential cookies may limit the functionality of our intake forms. Our Platform displays a cookie consent notice to users in jurisdictions where consent is required.
9. META ADVERTISING COMPLIANCE
Our lead generation advertising campaigns on Meta platforms (Facebook and Instagram) operate under Meta's Employment Special Ad Category where required by the nature of the lead vertical. Under this designation:
• We do not target audiences based on age, gender, zip code, or other characteristics prohibited under Meta's employment special ad category rules
• All campaigns are designated at the campaign level under the correct special ad category before deployment
• Ad creative and copy is reviewed against Meta's employment advertising policies prior to launch
• No consumer lead data is shared with Meta beyond standard advertising pixel events (page view, lead event)
This ensures leads generated through our Meta advertising campaigns are sourced through a compliant advertising pathway from the first consumer touchpoint, reducing downstream compliance exposure for Participating Law Firms.
10. CALIFORNIA CONSUMER PRIVACY RIGHTS (CCPA/CPRA)
California residents whose personal information we have collected have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):
Right to Know:
You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for collection, and the categories of third parties with whom we have shared it.
Right to Delete:
You have the right to request deletion of personal information we hold about you, subject to certain exceptions where retention is required for legal compliance, fraud prevention, or to complete a transaction you have requested.
Right to Correct:
You have the right to request correction of inaccurate personal information we hold about you.
Right to Opt Out of Sale or Sharing:
We do not sell personal information as defined by the CCPA, nor do we share personal information for cross-context behavioural advertising. If this practice changes, we will update this Policy and provide a conspicuous opt-out mechanism prior to any such activity commencing.
Right to Limit Use of Sensitive Personal Information:
To the extent we collect any information qualifying as sensitive personal information under the CPRA, we use it solely for the purposes disclosed in this Policy.
Right to Portability:
You have the right to request a copy of your personal information in a portable, machine-readable format where technically feasible.
Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA/CPRA rights. Exercising your rights will not affect your ability to submit a legal inquiry through our Platform.
Categories of Personal Information We Collect (CCPA Categories):
• Identifiers: name, email, phone number, IP address
• Professional or employment-related information: employer, job title, employment history
• Commercial information: law firm account and transaction history
• Internet or network activity: browsing behaviour, usage data, device information
• Inferences drawn from personal information: lead qualification assessment
How to Submit a California Privacy Rights Request:
Email: [email protected] | Subject Line: California Privacy Rights Request
We will verify your identity before processing your request and will respond within 45 days. We may extend this period by a further 45 days where reasonably necessary and will notify you of any extension within the initial period.
11. DATA SECURITY
We implement the following technical and organisational security measures to protect personal information against unauthorised access, disclosure, alteration, or destruction:
• Encrypted data transmission via TLS/SSL on all Platform pages and intake forms
• Access controls limiting personal data access to authorised personnel only
• Lead data transmitted to Participating Law Firms via encrypted webhook or secure API connection
• No storage of full lead records in unencrypted formats
• Regular review of service provider security practices and data handling agreements
• Stripe PCI-DSS compliant payment processing for all law firm billing (no consumer payment data is collected)
No method of electronic transmission or storage is 100% secure. While we implement commercially reasonable security measures, we cannot guarantee absolute security.
Data Breach Notification: In the event of a data breach affecting California residents, we will provide notification in accordance with California Civil Code §1798.82 within the required timeframes. Participating Law Firms must notify pagaleads.com within 72 hours of becoming aware of any breach affecting personal information received from our Platform.
12. DATA RETENTION
We retain personal information for the following periods:
* Lead records and contact information: 4 years. Aligned with California wage claim statute of limitations
TrustedForm certificate URLs: 5 years. TCPA compliance documentation
Consent records: 5 years. TCPA and FCC compliance
Law firm account information: Duration of relationship + 3 years. Contractual and legal compliance
Payment records: 7 years. Tax and financial compliance
Technical and device data: 12 months. Security and fraud prevention
13. PARTICIPATING LAW FIRM OBLIGATIONS
Participating Law Firms that receive personal information through the pagaleads.com Platform acknowledge and agree to the following compliance obligations as a condition of their service agreement:
Independent TCPA Compliance:
Each Participating Law Firm is independently responsible for its own TCPA compliance in connection with all contacts made to pagaleads.com leads. The TrustedForm certificate provided with each lead documents the consumer's prior express written consent and must be retained as part of the firm's compliance records for a minimum of 5 years.
Consent Revocation Obligations:
Upon notification from pagaleads.com that a consumer has revoked consent, the Participating Law Firm must cease all contact with that individual immediately and update their internal Do Not Call and Do Not Contact records accordingly.
California Rules of Professional Conduct:
Each Participating Law Firm is independently responsible for compliance with the California Rules of Professional Conduct governing attorney advertising, solicitation, and communication with prospective clients, including Rules 7.1 through 7.3.
Data Use Limitations:
Personal information received from pagaleads.com may be used only for the purpose of evaluating and potentially representing the individual in connection with their disclosed legal matter. It may not be resold, transferred to third parties outside the firm, or used for any unrelated marketing purpose.
Data Security:
Participating Law Firms are responsible for maintaining appropriate technical and organisational security measures to protect personal information received from pagaleads.com in accordance with applicable law and California State Bar requirements.
Breach Notification:
In the event of a data breach affecting personal information received from pagaleads.com, the Participating Law Firm must notify pagaleads.com within 72 hours of becoming aware of the breach and cooperate fully with any resulting notification obligations.
14. INTERNATIONAL USERS AND CROSS-BORDER TRANSFERS
Our Platform is operated in the United States and is directed at California residents and California-licensed attorneys. If you access our Platform from outside the United States, your information may be transferred to, stored, and processed in the United States.
pagaleads.com is operated by an entity with principal operations in Australia. All lead generation activity, consumer data collection, and attorney client relationships are conducted in accordance with California and federal United States law. By using our Platform or contracting to receive leads, all parties submit to California jurisdiction for all matters arising under this Policy.
By using our Services, you consent to the transfer of your information to the United States and acknowledge that data protection laws in the United States may differ from those in your country of residence.
15. GOVERNING LAW AND JURISDICTION
This Privacy Policy and all matters arising from or related to the collection, use, and transfer of personal information through our Platform shall be governed by and construed in accordance with the laws of the State of California, United States of America, without regard to its conflict of law provisions.
Any dispute arising under or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in Los Angeles County, California.
pagaleads.com acknowledges that its activities in generating leads from California residents and transferring those leads to California-licensed attorneys subjects it to California jurisdiction and applicable California consumer protection law regardless of the location of its principal place of business.
16. CHILDREN'S PRIVACY
Our Platform is not directed at individuals under the age of 18 and we do not knowingly collect personal information from minors. If we become aware that personal information has been collected from a minor we will delete it immediately. If you believe we have inadvertently collected information from a minor, please contact us at [email protected].
17. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, applicable law, or regulatory guidance. When we make material changes, we will:
• Update the "Last Updated" date at the top of this Policy
• Notify Participating Law Firms by email of any changes that affect their compliance obligations
Your continued use of our Platform or continued receipt of leads from our Platform following notification of material changes constitutes acceptance of the updated Policy.
19. ACCESSIBILITY
Paga Leads is committed to ensuring that our Platform, including all intake forms, lead qualification funnels, privacy notices, and consent mechanisms, is accessible to users with disabilities in accordance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, as adopted by reference under the Americans with Disabilities Act (ADA) Title III and the California Unruh Civil Rights Act (California Civil Code §51).
We design and maintain our digital properties to be perceivable, operable, understandable, and robust for users of assistive technologies including screen readers, voice navigation software, and keyboard-only navigation.
Accessibility of Privacy Rights Mechanisms
All mechanisms through which California residents may exercise their CCPA/CPRA rights, including rights requests, consent revocations, and Do Not Contact requests, are designed to be accessible to users with disabilities. If you experience any barrier in exercising your privacy rights through our standard online channels, please contact us by phone or written request and we will accommodate your request through an alternative accessible format at no disadvantage to you.
Reporting an Accessibility Barrier
If you encounter an accessibility barrier on any part of our Platform we want to know about it. Please contact us using any method listed in Section 18 with the subject line: Accessibility Issue. We will acknowledge accessibility reports within 2 business days and work to resolve identified barriers as promptly as practicable.
Known Limitations
We are actively working toward full WCAG 2.1 Level AA conformance across our Platform. Where third-party components integrated into our Platform — including consent documentation tools, CRM interfaces, and advertising pixels — introduce accessibility limitations outside our direct control, we document those limitations and work with our service providers toward remediation.
Ongoing Commitment
We conduct periodic accessibility reviews of our Platform and intake funnels and maintain an accessibility statement at pagaleads.com/accessibility documenting our current conformance status, known issues, and remediation roadmap.
19. CONTACT INFORMATION
For all privacy-related enquiries, rights requests, consent revocations, or compliance questions, please contact us through any of the following methods:
Email: [email protected]
Phone: [phone number] — available Monday to Friday during business hours Pacific Time
Website: www.pagaleads.com
Subject lines for written and email requests:
California Privacy Rights Request
Revoke Consent
Law Firm Compliance Enquiry|
Accessibility Issue
We aim to respond to all privacy enquiries within 2 business days and all formal rights requests within 45 days of receiving a verifiable request. Users who require an accessible format or alternative communication method to exercise their rights are encouraged to contact us by phone or written request and we will accommodate accordingly.
Paga Leads © 2026. All Rights Reserved