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ULTIM LEADS · VERSION 2026-10-19.1

Privacy notice

Your customer data remains yours. This notice explains our role, necessary processing and your choices.

Effective October 19, 2026 · Contact the company

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Who we are and our roles

ULTIM Leads is operated by GEM Marketing Group, LLC, under the ULTIM Marketing brand (ULTIM, we, us). We determine how account administration, service billing, security and our own business communications are handled. For customer workspace content, the customer generally determines the purposes and lawful basis and ULTIM processes that information on its behalf under the Data processing agreement. Particular processing may create independent legal responsibilities that cannot be changed merely by a contract.

Customer data belongs to the customer

As between ULTIM and the customer, the customer retains its rights in leads, contact details, messages, emails, call records, recordings, transcripts, documents, extracted information, agent configuration and related workspace content. Individuals retain their privacy and other legal rights. Hosting or processing content does not transfer its ownership to ULTIM. We do not sell customer workspace content or use it to build advertising audiences.

What we receive

We process account and business details; authentication identifiers; user roles; configuration and instructions; imported or manually entered leads; communications and contact permissions; recordings and transcripts where enabled; attachments and information extracted from them; AI suggestions; team decisions; integration identifiers; and delivery or automation events. Technical, security, acceptance and usage records may include timestamps, IP addresses where logged, browser information and provider charges. Information comes from you, authorized users, people contacting your business, connected providers, website forms and integrations you enable.

How information is used

Processing supports authentication, workspace access, configured follow-up, communication delivery, history, document and audio understanding, AI responses, operational recovery, billing, fraud prevention, legal obligations and support. AI features send relevant content and instructions to configured AI providers. Outputs can be incorrect; the customer must review consequential facts, assessments and decisions. ULTIM does not use customer workspace content to train its own general-purpose models. Provider processing and retention depend on the service, contract and account configuration; this notice is not a promise of zero retention by every provider.

Limited operational and support access

Routine access to lead content by ULTIM personnel is not our business purpose. Authorized personnel may access the minimum reasonably necessary to deliver the service, investigate a customer support or recovery request, address failures or security incidents, enforce lawful-use restrictions or comply with law. Customer requests should identify the workspace and issue without sharing passwords. Access remains subject to confidentiality and applicable authorization; this notice is not permission for unrestricted browsing of customer records. Recovery depends on available records and backups and cannot be guaranteed.

Sharing and service providers

Content is shared with authorized workspace users and providers needed for enabled features, as described in Service providers, including hosting, authentication, telephony, messaging, AI and connected services. We may disclose necessary information to advisers under confidentiality, in a lawful business reorganization with appropriate safeguards, or to comply with binding legal process, protect rights or investigate abuse. We assess legal requests and limit disclosure; where permitted and appropriate, we notify the affected customer. We do not sell or share messaging opt-in information with unrelated parties for their marketing. Necessary messaging providers may process it to deliver the customer’s authorized messages.

Location and international processing

The service is initially offered to businesses operating in the United States. Providers may process information in the United States or other locations depending on feature and configuration. No particular data residency is promised without a written agreement. If a use requires international-transfer safeguards, regional hosting or another legal instrument, contact us before enabling that use. A US account does not automatically satisfy every foreign privacy law.

Retention and deletion

Workspace history, including archived conversations, is retained to provide the service until deleted under available controls, a verified instruction or an agreed retention schedule. Archive, pause, cancellation and deletion are different actions. Account, billing, consent, security and legal records may remain where reasonably necessary for their purposes or required by law. Backups and provider copies have separate lifecycles and may not disappear immediately. See Data requests & deletion for requests and coordination. We do not promise a universal retention period or unlimited archival recovery.

Privacy rights and requests

Depending on applicable law, individuals may have rights of access, correction, deletion, portability, restriction, objection or appeal, and withdrawal of consent. Contact the business that collected your information for workspace-content requests; ULTIM assists that business and routes requests where appropriate. For ULTIM account or administrative information, contact us directly. We verify identity and authority proportionately, respond within applicable legal deadlines and explain permitted limitations or denials and available appeal routes. Optional marketing consent is not required to exercise a right.

Children, sensitive information and security

The service is for business users aged 18 or older, not directed to children. Do not knowingly submit children’s information without the authority and safeguards required for the use. Minimize sensitive information; health, financial or legally privileged content may require additional arrangements. See Security & HIPAA before submitting protected health information. Security measures reduce risk but cannot eliminate it.

Changes and contact

Material changes will have a new revision and be communicated through the service or account contact as appropriate; renewed agreement will be requested when required. Contact details appear below. Cookies & storage describes browser storage separately.

Version 2026-10-19.1 · Print or save a copy for your records. Previous versions are available on request.