Privacy Policy

Last Updated: August 18, 2026 · Effective: August 18, 2026

This Privacy Policy is published by Kleer Circle, LLC (“Kleer Circle,” “we,” “us,” or “our”) and applies to kleercircle.com and any subdomains, landing pages, application forms, scheduling/booking flows, and content we control (collectively, the “Site”). See also our Terms & Conditions.

B-1. SCOPE

B-1.1This Privacy Policy describes how Kleer Circle collects, uses, shares, and retains personal information through the Site, our application forms, call-booking flows, email and SMS communications, and advertising. It does not cover the practices of Partners or other third parties, who have their own policies.

B-2. INFORMATION WE COLLECT

B-2.1Information You Provide. When you submit an application form, book a call, enroll, or communicate with us, we may collect: name; email address; phone number; state/location; investment goals and timeline; financial qualification information you choose to provide (such as income range, liquid capital available, credit score range, financing readiness, and existing property ownership); scheduling details; and the contents of your messages, calls (which may be recorded with notice/consent as required by law), emails, and texts.

B-2.2Information Collected Automatically. When you use the Site we and our vendors automatically collect: IP address, device and browser type, pages viewed, referring URLs, UTM parameters (source, medium, campaign, content, term), click and scroll activity, and identifiers set by cookies, pixels, and similar technologies.

B-2.3Information from Third Parties. We may receive information from advertising platforms (e.g., Meta), analytics providers, scheduling and form vendors, payment processors, and data-enrichment or lead-verification services.

B-3. TRACKING TECHNOLOGIES AND ADVERTISING

B-3.1Pixels and Server-Side Tracking. We use the Meta (Facebook/Instagram) Pixel and the Meta Conversions API (CAPI), which sends event data (such as page views, form submissions, and call bookings, together with hashed identifiers like email or phone) from our servers to Meta, as well as Google tags and analytics tools. These technologies help us measure ads, build audiences, and improve the Site.

B-3.2UTM Tracking. We append and store UTM parameters and related attribution data to understand which campaigns and creatives lead to applications and enrollments, and we may associate that attribution data with your contact record in our CRM.

B-3.3Retargeting and Custom Audiences. We may use collected identifiers (including hashed email addresses and phone numbers) to build custom and lookalike audiences on advertising platforms and to show you retargeted ads on other sites and apps.

B-3.4Your Choices. You can limit tracking via browser cookie controls, the opt-outs at platforms’ ad-preference pages, and industry tools (e.g., YourAdChoices). The Site does respond to Global Privacy Control signals.

B-4. HOW WE USE INFORMATION

B-4.1We use personal information to: evaluate applications and program fit (including financial-readiness screening); schedule and conduct calls; provide and administer the program; send transactional and marketing communications; run, measure, and optimize advertising; personalize content; make referrals to Partners you ask about or that we disclose; comply with law; enforce agreements; and protect against fraud and abuse.

B-5. EMAIL MARKETING (CAN-SPAM)

B-5.1If you provide your email, we may send you marketing emails about the program, events, and content. Consistent with the CAN-SPAM Act, our marketing emails identify us as the sender, include our physical mailing address, use truthful subject lines, and include a working unsubscribe link. We honor opt-outs within ten (10) business days. Transactional and relationship emails (receipts, scheduling, program logistics) may continue after a marketing opt-out.

B-6. TEXT MESSAGES (TCPA / SMS CONSENT)

B-6.1Program Description. We operate a business phone line that sends automated and templated text messages — for example, application follow-ups, call reminders, missed-call auto-replies, and marketing messages.

B-6.2Consent. By providing your phone number and checking the SMS consent box on our forms, you consent to receive autodialed and prerecorded/automated calls and text messages from or on behalf of Kleer Circle at that number, including marketing messages. Consent is not a condition of purchasing any good or service. Message frequency varies; message and data rates may apply.

B-6.3Opt-Out and Help. Reply STOP to cancel at any time (we will send a single confirmation message) and HELP for help, or contact sales@kleercircle.com. We honor opt-outs promptly and maintain an internal do-not-text list.

B-7. HOW WE SHARE INFORMATION

B-7.1We share personal information with:

Service Providers. Vendors who process data for us — hosting, CRM, scheduling, form, email/SMS platforms, payment processors, analytics, and ad-measurement providers — under contracts limiting their use of the data.
Advertising Platforms. Meta and other platforms via pixels, CAPI, and audience uploads as described in Section B-3.
Service Partners. With your direction or consent, referral Partners (lender, CPA, cost segregation firm, legal provider, designer, insurance agent, real estate agents, property managers — including our affiliates) so they can contact and serve you. Partners use your information under their own privacy policies.
Affiliates. Our affiliated companies.
Legal and Safety. Authorities or other parties when required by law, subpoena, or to protect rights, safety, or property, or in connection with a merger, financing, or sale of the business.

B-7.2We do not sell personal information for money.

B-8. DATA RETENTION

B-8.1We retain personal information for as long as needed for the purposes above: prospect/lead records for 24 months after last interaction; client records for the duration of the engagement plus 7 years for legal, accounting, and tax purposes; SMS consent and opt-out records for at least 4 years; and we then delete, aggregate, or de-identify the data.

B-9. SECURITY

B-9.1We use reasonable administrative, technical, and organizational safeguards appropriate to the sensitivity of the data, including access controls and encryption in transit. No system is completely secure, and we cannot guarantee absolute security. Please do not submit full account numbers, Social Security numbers, or other sensitive identifiers through Site forms.

B-10. CHILDREN

B-10.1The Site is intended for adults and is not directed to children under 18. We do not knowingly collect personal information from anyone under 18; if you believe we have, contact us and we will delete it.

B-11. CHANGES TO THIS POLICY

B-11.1We may update this Policy from time to time. We will post the revised version with a new “Last Updated” date and, for material changes, provide additional notice (such as email) where required by law.

B-12. CONTACT US

B-12.1Kleer Circle, LLC — Attn: Privacy — 855 Healey Homestead Circle, Alpine, UT 84004 — sales@kleercircle.com — 801-647-2055.