Privacy Policy

Effective date: September 11, 2026  •  Last updated: September 11, 2026
Controller: TemamilaGroup LLC, a Nevada limited liability company, doing business as Creative Lead Flow
Mailing address: 816 West Francis Ave #1062, Spokane, WA 99205, United States
Privacy contact: support@creativeleadflow.com  •  (916) 514-2278

1. Scope

This Privacy Policy explains how TemamilaGroup LLC d/b/a Creative Lead Flow (“Creative Lead Flow,” “we,” “us”) collects, uses, shares, and protects personal information when you visit creativeleadflow.com, purchase or hold a membership, use our software tools, join our Whop or Telegram communities, attend our live sessions, or otherwise interact with us (together, the “Services”).

It does not apply to the independent practices of third parties whose platforms we use or link to. Those parties publish their own privacy policies, and we encourage you to read them.

2. Information we collect

2.1 Information you give us

2.2 Payment information

Payments are processed by Whop and Stripe. Your full payment card number, CVV, and full bank account details are collected and stored by those processors under their own security standards — we never receive or store them. We receive only limited transaction data such as the last four digits of the instrument, card brand, billing country, amount, and payment status.

2.3 Information collected automatically

When you use the Services we and our analytics partners may collect IP address, approximate location derived from IP, device and browser type, operating system, language, referring URL, pages and features viewed, time stamps, session duration, clicks, and error logs. See Section 7 for cookies and tracking.

2.4 Information from third parties

We may receive information about you from the platforms that deliver the Services — including Whop, Telegram, Zoom, Google, and advertising platforms such as Meta — and from partners who refer you to us. This may include your membership status, community activity, attendance, and conversion events.

2.5 Third-party data you process through our tools

Our tools let you work with property records, owner and lead information, agent contact details, and comparable-sales data sourced from public records and commercial data providers, as well as lists you upload yourself.

Important. Where you upload, import, or generate lists of sellers, owners, agents, or leads and use our tools to contact them, you are the controller of that data and we act as a processor on your behalf. You are responsible for having a lawful basis to collect and use it, for honoring opt-out and deletion requests directed to you, and for complying with Section 7 of our Terms of Service. We process such data only to provide the Services to you.

2.6 Sensitive information

We do not seek, and ask that you do not submit, Social Security numbers, government identification numbers, full financial account numbers, health information, or information about criminal history through our community channels or support tickets.

3. How we use information

We use personal information to:

• create and administer your account and deliver the Services you purchased;
• process payments, renewals, invoices, refunds, and chargebacks;
• provide access to community channels, live sessions, courses, and tools;
• respond to support requests, consultations, and questions;
• operate, secure, troubleshoot, and improve the Services, including analytics on feature usage;
• detect and prevent fraud, credential sharing, abuse, spam, and violations of our Terms;
• send transactional messages about your account, billing, access, and schedule changes;
• send marketing and educational communications where permitted, subject to your opt-out rights;
• measure and improve our advertising; and
• comply with legal obligations, respond to lawful requests, establish or defend legal claims, and enforce our agreements.

We do not use the content you upload into our tools to train publicly available AI models, and we do not sell your personal information.

4. Legal bases (for individuals in the EEA, UK, and Switzerland)

Where the GDPR or UK GDPR applies, we rely on the following bases: performance of a contract (delivering the membership you bought); legitimate interests (securing the Services, preventing abuse, analytics, direct marketing to existing customers); consent (non-essential cookies, certain marketing, recording where required); and legal obligation (tax, accounting, and compliance record-keeping). Where we rely on consent, you may withdraw it at any time without affecting prior processing.

5. How we share information

We do not sell personal information and we do not share it for cross-context behavioral advertising in the sense defined by California law. We disclose personal information only as follows.

5.1 Service providers

We use vendors who process data on our instructions and under contract. Current categories include:

5.2 Other members

Information you post in community channels, including your display name, photo, and messages, is visible to other members. Treat community spaces as semi-public. We cannot control what other members do with what you post.

5.3 Legal and protective disclosures

We may disclose information where we believe in good faith it is necessary to comply with law, subpoena, or court order; to enforce our Terms; to investigate fraud, security incidents, or abuse; or to protect the rights, property, or safety of Creative Lead Flow, our members, or the public.

5.4 Business transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction. We will require the recipient to honor this Policy or give you notice and a choice.

6. AI features

Our Real Estate AI assistant and certain automated features send the prompts and content you submit to third-party AI model providers to generate a response. We instruct those providers to process the content only to return output to you and not to train their general-purpose models on it. Do not submit information you would not want processed by a third-party provider. AI output may be inaccurate — verify before relying on it.

7. Cookies and tracking

We and our partners use cookies, pixels, local storage, and similar technologies to keep you logged in, remember preferences, measure traffic and feature usage, and measure the performance of our advertising. This includes advertising pixels such as the Meta pixel on our marketing pages.

You can control cookies through your browser settings and can opt out of many advertising cookies through industry tools such as the Digital Advertising Alliance opt-out page and Your Online Choices in the EU. Blocking essential cookies may break login and checkout. We honor Global Privacy Control signals where required by law.

8. Marketing communications

You may unsubscribe from marketing emails using the link in any message, reply STOP to marketing SMS, or write to support@creativeleadflow.com. We will continue to send transactional messages relating to your account, billing, and access, which you cannot opt out of while your membership is active.

9. Retention

We retain personal information for as long as your account is active and afterwards for as long as needed to fulfill the purposes described here, resolve disputes, and comply with legal, tax, and accounting obligations — typically seven (7) years for transaction and tax records. Community posts may persist after your account closes unless you ask us to remove them. Backups are purged on a rolling schedule.

10. Security

We use administrative, technical, and physical safeguards appropriate to the risk, including encryption in transit, access controls on a need-to-know basis, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Protect your account by using a unique password, enabling any available two-factor authentication, and never sharing your login.

If a breach affecting your personal information occurs, we will notify you and any regulator as required by applicable law.

11. Your rights and choices

11.1 All users

You may request access to, correction of, or deletion of your personal information, and may request a copy in a portable format, by writing to support@creativeleadflow.com. We will verify your identity before acting and will respond within the period required by applicable law. We will not discriminate against you for exercising these rights.

11.2 California residents (CCPA/CPRA)

You have the right to know the categories and specific pieces of personal information collected, the sources, the business purposes, and the categories of recipients; the right to delete; the right to correct; the right to opt out of sale or sharing; and the right to limit use of sensitive personal information. We do not sell or share personal information as those terms are defined by the CPRA, and we do not use or disclose sensitive personal information for purposes requiring a limitation right. You may use an authorized agent, with proof of authorization.

11.3 Other U.S. state residents

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana, have comparable rights of access, correction, deletion, portability, and opt-out of targeted advertising and profiling, plus the right to appeal a denial. To appeal, reply to our decision with “Privacy Appeal” in the subject line.

11.4 EEA, UK, and Swiss residents

You have the rights of access, rectification, erasure, restriction, portability, objection to processing based on legitimate interests, and the right not to be subject to solely automated decision-making producing legal effects. You may also lodge a complaint with your local supervisory authority.

12. International transfers

We are based in the United States and our providers operate primarily in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States, where data protection law may differ from that of your country. Where required, we rely on the European Commission’s Standard Contractual Clauses or another approved transfer mechanism. By using the Services, you acknowledge this transfer.

13. Children

The Services are for adults aged eighteen (18) and over. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, write tosupport@creativeleadflow.com and we will delete it.

14. Links to other sites

The Services contain links to third-party sites, tools, data providers, and partner offers. We are not responsible for their content or privacy practices. Review their policies before providing information.

15. Changes to this Policy

We may update this Policy. We will post the revised version with a new “Last updated” date and, where the change is material, notify you by email or in-app notice before it takes effect. Continued use after the effective date constitutes acceptance.