Privacy Policy

Effective Date: November 29, 2025 | Last Updated: October 1, 2026

Ascend Leads, LLC ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, website, and services (collectively, the "Service"). Please read this Privacy Policy carefully. By using the Service, you consent to the data practices described in this policy.

Table of Contents

1. Information We Collect
2. How We Use Your Information
3. Information Sharing and Disclosure
4. Third-Party Services and Integrations
5. Data Security
6. Data Retention
7. Your Privacy Rights
8. Children's Privacy
9. Sensitive Data and Regulatory Compliance
10. Cookies and Tracking Technologies
11. International Data Transfers
12. California Privacy Rights (CCPA)
13. Changes to This Policy
14. Contact Us

1. Information We Collect

1.1 Information You Provide

We collect information you voluntarily provide when using the Service, including:

Account Information

• Name, email address, phone number
• Username and password
• Agency or organization name
• Job title and role
• Profile photo
• Billing address

Professional Information (for Educators)

• Resume and work history
• Education credentials and certifications
• Teaching specialties and subjects
• Availability and scheduling preferences
• Hourly rates and compensation information
• Background check consent and results (where applicable)
• Professional references

Financial Information

• Payment card information (processed securely by Stripe or PayPal)
• Bank account information for direct deposit (processed by our payroll partners)
• Tax identification information (SSN/EIN for payroll purposes)
• Billing and invoice history

Communications

• Messages sent through the Service
• Support requests and correspondence
• Survey responses and feedback

1.2 Information Collected Automatically

When you use the Service, we automatically collect certain information, including:

Device and Usage Information

• IP address
• Device type and operating system
• Browser type and version
• Pages visited and features used
• Time and date of access
• Referring website or application
• Click patterns and navigation paths

Location Information

• General location based on IP address
• Precise location (with your consent) for features like clock-in/clock-out geolocation verification

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Background check providers (with your consent)
• Identity verification services
• Payment processors (Stripe, PayPal)
• Payroll providers (Gusto) when you connect your account
• Accounting software (QuickBooks) when you enable integration
• Educational institutions or agencies that invite you to join

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Provide and Operate the Service

• Create and manage your account
• Process transactions and payments
• Match educators with job opportunities
• Generate and manage invoices
• Process payroll and compensation
• Enable scheduling and timesheet management
• Facilitate communication between users

2.2 Improve and Personalize the Service

• Analyze usage patterns and trends
• Develop new features and functionality
• Personalize your experience
• Conduct research and analytics

2.3 Communication

• Send service-related notifications
• Respond to your inquiries and support requests
• Send marketing communications (with your consent)
• Notify you of changes to the Service or policies

2.4 Security and Compliance

• Detect and prevent fraud and abuse
• Enforce our terms and policies
• Comply with legal obligations
• Protect the rights and safety of users

3. Information Sharing and Disclosure

We do not sell your personal information.

We may share your information in the following circumstances:

3.1 With Your Agency or Organization

If you are an Authorized User of an Agency, your Agency Administrator may have access to your profile information, timesheets, schedules, and other work-related data as necessary for their business operations.

3.2 Between Users

Certain information may be visible to other users as part of the Service's functionality. For example, educators' profiles may be visible to agencies and schools seeking to hire them.

3.3 With Service Providers

We share information with third-party vendors who assist us in providing the Service, including:

• Cloud hosting providers (data storage)
• Payment processors (transaction processing)
• Email service providers (communications)
• Analytics providers (usage analysis)
• Customer support tools

These service providers are contractually obligated to protect your information and may only use it for the purposes we specify.

3.4 For Legal Reasons

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with a legal obligation, subpoena, or court order
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Investigate potential violations of our terms
• Detect, prevent, or address fraud or security issues

3.5 Business Transfers

If we are involved in a merger, acquisition, financing, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.

3.6 With Your Consent

We may share your information for other purposes with your explicit consent.

4. Third-Party Services and Integrations

4.1 Payment Processing - Stripe and PayPal

We use Stripe and PayPal for payment processing. When you make a payment or connect a payment account, your payment information is collected and processed directly by the processor that handles it. We do not store complete credit card numbers on our servers. Please review Stripe's Privacy Policy and PayPal's Privacy Statement.

4.2 Payroll Integration - Gusto

Agencies may connect the Service to Gusto for payroll management. When enabled, we may share employee information, timesheets, and compensation data with Gusto. Please review Gusto's Privacy Policy.

4.3 Accounting Integration - QuickBooks

Agencies may connect the Service to QuickBooks for accounting purposes. When enabled, we may share invoice, payment, and financial data with QuickBooks. Please review Intuit's Privacy Policy.

4.4 Authentication

We use Supabase for authentication services. Your authentication credentials are securely managed according to industry standards.

5. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication with password hashing
• Role-based access controls
• Regular security assessments and audits
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

• Active accounts: Data is retained while your account is active
• After account closure: We may retain certain data for up to 7 years for legal, tax, and regulatory compliance
• Financial records: Retained as required by tax and accounting regulations
• Backup copies: May be retained for up to 90 days after deletion

You may request deletion of your personal data at any time, subject to our legal retention requirements.

7. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

7.1 Access and Portability

You have the right to request a copy of your personal information in a structured, commonly used, machine-readable format.

7.2 Correction

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings.

7.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (such as when we need to retain data for legal compliance).

7.4 Restriction and Objection

You may request that we restrict processing of your personal information or object to certain processing activities.

7.5 Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time.

7.6 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@warleyhub.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

8. Children's Privacy

The Service is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@warleyhub.com.

9. Sensitive Data and Regulatory Compliance

9.1 Industry-Specific Compliance

We understand that Agencies using our Service may handle sensitive data protected under various regulatory frameworks, including but not limited to FERPA (education), HIPAA (healthcare), ABA Ethics Rules (legal), and other industry-specific regulations. We are committed to supporting our customers' compliance obligations under their applicable regulatory framework.

9.2 Sensitive Data Protections

• We use sensitive data only to provide the Service as directed by the Agency
• We do not use sensitive data for advertising or marketing purposes
• We do not sell sensitive data
• We implement appropriate security measures to protect sensitive data
• We provide mechanisms for data access and deletion requests
• We promptly notify customers of any data breach involving sensitive data

9.3 Data Processing Agreement

Organizations may request a Data Processing Agreement (DPA) that outlines our obligations regarding sensitive data under their applicable regulatory framework. Please contact us at privacy@warleyhub.com to request a DPA.

10. Cookies and Tracking Technologies

10.1 Types of Cookies We Use

• Essential Cookies: Required for the Service to function (authentication, security)
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand how users interact with the Service

10.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. However, disabling cookies may affect the functionality of the Service.

10.3 Do Not Track

We currently do not respond to "Do Not Track" signals. However, you can manage your tracking preferences through your browser settings.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws than your country.

When we transfer data internationally, we implement appropriate safeguards, such as Standard Contractual Clauses approved by relevant authorities, to protect your information.

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

12.1 Right to Know

You have the right to request information about:

• Categories of personal information we collect
• Specific pieces of personal information we have collected
• Categories of sources from which we collect information
• Purposes for collecting information
• Categories of third parties with whom we share information

12.2 Right to Delete

You have the right to request deletion of personal information we have collected, subject to certain exceptions.

12.3 Right to Opt-Out of Sale

We do not sell personal information. If this changes, we will provide a "Do Not Sell My Personal Information" link.

12.4 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

12.5 Categories of Personal Information

In the past 12 months, we have collected the following categories of personal information:

12.6 Authorized Agent

You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top
• Sending you an email notification (for material changes)

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes constitutes your acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For data subject access requests or to exercise your privacy rights, please email:
privacy@warleyhub.com

We will respond to all legitimate requests within 30 days. If we need additional time, we will notify you of the reason and extension period.

By using WarleyHub, you acknowledge that you have read and understood this Privacy Policy.