1. OVERVIEW

Contractors Growth LLC ("CGP," "we," "us," or "our") is an Illinois limited liability company operating at cgpsystems.io. This Privacy Policy describes the categories of information we collect, how we use and share that information, the security measures we implement, and the rights available to you regarding your information. This Policy applies to information collected from clients, website visitors, and individuals whose information is processed in the course of CGP's lead generation operations.

2. INFORMATION WE COLLECT

2.1 From Clients. We collect the following categories of information from clients during onboarding and in the course of providing services:

Full legal name and contact information, including email address and phone number

Legal business name and registered business address

Employer Identification Number (EIN)

Service area designations

Payment information (processed through third-party payment processors; CGP does not store full payment card numbers or CVV codes)

Campaign preferences, history, and performance data

Communications and correspondence with CGP

2.2 From Homeowners (Campaign Recipients). In the course of operating SMS marketing campaigns on behalf of clients, CGP may process the following categories of information about homeowner contacts:

Name

Phone number

Residential address

Email address (where available)

Response and campaign interaction data

This information is processed solely to facilitate lead generation services on behalf of the applicable client. CGP does not use homeowner contact data for any independent commercial purpose.

2.3 Website Visitors. CGP may collect standard analytics data from visitors to cgpsystems.io, including IP address, browser type, device type, pages visited, and time on site, through cookies and third-party analytics tools.

3. HOW WE USE INFORMATION

We use collected information to:

Provide, operate, and manage lead generation services on behalf of clients

Register and operate 10DLC SMS campaigns on behalf of clients using client business identity

Process payments and manage billing and collections

Communicate with clients regarding campaigns, accounts, and services

Maintain internal records and audit logs for compliance and dispute resolution

Improve our services, operations, and systems

Comply with legal and regulatory obligations

Investigate and defend against legal claims

4. EIN USAGE

Client EINs are collected solely for the purpose of registering 10DLC SMS campaigns with telecommunications carriers and their authorized aggregators on the client's behalf. EINs are stored with access controls limiting access to authorized CGP personnel on a need-to-know basis. CGP does not share EINs with any third party except telecommunications carriers and aggregators as required for campaign registration. EINs are not used for any commercial, marketing, or other purpose beyond campaign registration.

5. DATA SHARING

CGP does not sell client data or homeowner data to any third party. We may share information as follows:

5.1 Service Providers. CGP shares information with third-party vendors and service providers who assist in delivering our services, including: telecommunications carriers and SMS aggregators (for campaign registration and message delivery); payment processors (for transaction processing); CRM and marketing automation platforms; cloud storage and productivity platforms; and data sourcing and analytics vendors. These providers are authorized to use shared information only to the extent necessary to perform services for CGP and are prohibited from using it for their own commercial purposes.

5.2 International Service Providers and Contractors. CGP utilizes service providers and independent contractors located outside the United States. As a result, personal information — including homeowner contact data processed in connection with campaign operations — may be transferred to, stored in, or processed in countries outside the United States that may have different or less comprehensive data protection laws than the laws of your state or country. Where such transfers occur, CGP takes reasonable steps to implement appropriate contractual and operational safeguards to protect transferred information consistent with applicable law. By engaging CGP's services, Client acknowledges and consents to these international transfers to the extent they occur in connection with service delivery.

5.3 Legal and Regulatory Authorities. CGP may disclose information to law enforcement, regulatory agencies, courts, or other governmental authorities when required by applicable law, regulation, subpoena, court order, or other legal process, or when CGP reasonably believes disclosure is necessary to protect CGP's legal rights, the safety of any person, or the integrity of our operations.

5.4 Business Transfers. In the event of a merger, acquisition, reorganization, or sale of all or substantially all of CGP's assets, client and operational information may be transferred to the successor entity, provided that the successor assumes obligations consistent with this Privacy Policy.

6. SMS CAMPAIGN OPT-OUT

Homeowners who receive SMS messages as part of campaigns operated by CGP on behalf of clients may opt out of further communications at any time by replying STOP to any message received. Opt-out instructions are included in campaign messaging where required by applicable law. Opt-out requests are processed through CGP's SMS platform infrastructure and honored promptly in accordance with TCPA requirements and telecommunications carrier rules. Opt-out records are maintained in CGP's systems and are not overridden. Homeowners who have opted out will not receive further SMS messages in connection with CGP-operated campaigns unless they affirmatively re-engage.

7. DATA SECURITY

CGP implements commercially reasonable technical and organizational security measures designed to protect client and homeowner information from unauthorized access, disclosure, alteration, loss, or destruction. These measures include role-based access controls, secure credential management, vendor vetting, and ongoing monitoring of our operational environment. However, no electronic transmission or storage system is completely secure, and CGP cannot guarantee the absolute security of any information. In the event of a data security incident that affects your personal information and triggers notification obligations under applicable law, CGP will notify affected clients as required.

8. DATA RETENTION

CGP retains client information for as long as necessary to: provide and manage services; comply with legal and regulatory obligations; resolve disputes; and enforce agreements. Upon termination of services, client data may be retained for up to twenty-four (24) months for compliance and dispute resolution purposes, after which it is securely deleted or anonymized. Homeowner contact data processed in connection with completed or terminated campaigns is retained for the minimum period required by applicable law and securely disposed of thereafter.

9. STATE-SPECIFIC PRIVACY RIGHTS

9.1 California Residents — CCPA/CPRA. If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know: You may request that CGP disclose the categories and specific pieces of personal information collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share information.

Right to Delete: You may request deletion of personal information CGP has collected about you, subject to certain legal exceptions.

Right to Correct: You may request correction of inaccurate personal information CGP holds about you.

Right to Opt-Out of Sale or Sharing: CGP does not sell personal information. CGP does not share personal information for cross-context behavioral advertising purposes.

Right to Limit Use of Sensitive Personal Information: To the extent CGP processes sensitive personal information as defined under the CPRA (such as EINs), its use is limited to purposes necessary for service delivery and as otherwise permitted by law.

Non-Discrimination: CGP will not discriminate against any individual for exercising their CCPA/CPRA rights.

To exercise any of these rights, submit a verifiable request to [email protected]. CGP will verify your identity before processing any request and will respond within 45 calendar days, with up to a 45-day extension where permitted by law.

9.2 Virginia Residents — CDPA. If you are a Virginia resident, you have the right under the Virginia Consumer Data Protection Act to: access and obtain a copy of your personal data; correct inaccuracies in your personal data; delete personal data provided by or obtained about you; opt out of the sale of personal data, targeted advertising, and certain profiling. To exercise these rights, contact [email protected]. CGP will respond within 45 days.

9.3 Colorado Residents — CPA. If you are a Colorado resident, you have the right under the Colorado Privacy Act to: access, correct, and delete your personal data; obtain a portable copy of your personal data; and opt out of the processing of personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. Contact [email protected] to exercise these rights.

9.4 Texas Residents — TDPSA. If you are a Texas resident, you have rights under the Texas Data Privacy and Security Act to access, correct, delete, and obtain a copy of your personal data, and to opt out of the sale of personal data and targeted advertising. Contact [email protected].

9.5 Connecticut Residents — CTDPA. If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act to access, correct, delete, and obtain a copy of your personal data and to opt out of certain processing activities. Contact [email protected].

9.6 Florida — SMS Communications. CGP's SMS marketing campaigns may be subject to the Florida Telephone Solicitation Act (Fla. Stat. § 501.059). Homeowners in Florida receiving SMS messages through CGP-operated campaigns may opt out at any time by replying STOP.

9.7 Other State Residents. Residents of states with enacted comprehensive consumer privacy legislation not specifically listed above may have rights similar to those described in this Section. CGP is committed to honoring applicable consumer privacy rights regardless of jurisdiction. Contact [email protected] with any privacy-related request.

10. YOUR RIGHTS — ALL USERS

Regardless of your state of residence, you may submit a request to access, correct, or delete your personal information by contacting us at [email protected]. All verifiable requests will receive a response within 30 days (or 45 days for California residents where additional time is permitted by law). CGP may request reasonable information to verify your identity before processing any request.

11. COOKIES & TRACKING TECHNOLOGIES

CGP's website (cgpsystems.io) may use cookies and similar tracking technologies for analytics, functionality, and performance purposes. You may control or disable cookies through your browser settings. CGP does not engage in cross-site behavioral advertising and does not sell data collected through cookies.

12. CHILDREN'S PRIVACY

CGP's services are directed exclusively to business entities and business owners. CGP does not knowingly collect personal information from individuals under the age of 18. If CGP becomes aware that it has collected personal information from a minor, CGP will take steps to delete that information promptly.

13. CHANGES TO THIS POLICY

CGP reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to clients via email to the address on file or by posting an updated policy at cgpsystems.io with a revised effective date. Continued use of CGP's services following the effective date of any changes constitutes acceptance of the updated Policy.

14. GOVERNING LAW

This Privacy Policy is governed by and construed in accordance with the laws of the State of Illinois.

15. CONTACT

For all privacy-related questions, rights requests, data deletion requests, or to report a privacy concern, contact us at:

Contractors Growth LLC [email protected] cgpsystems.io