Forms part of: the Leadey Terms and Conditions
Provider: Octogle Technologies CO. L.L.C (Establishment No. 2881346; Trade Licence No. 1419977)
Reports of abuse: legal@leadey.io / hello@leadey.ai
Version: 1.0 Effective date: 18 June 2026
Why this policy matters. Leadey gives you powerful tools to call, text, email and message people at scale. Using them unlawfully can expose you, and us, to regulatory fines, carrier penalties and legal claims. You are responsible for every communication you send or attempt to send through the Service. This policy sets the minimum rules. Breaching it may lead to suspension or termination and may make you liable to indemnify Leadey under the Terms.
1. General prohibited uses
You must not use the Service to, or to assist anyone to:
- break any applicable law or regulation, or infringe anyone's rights (including privacy, data-protection, intellectual-property or contractual rights);
- send unlawful, fraudulent, deceptive, misleading, harassing, threatening, defamatory or obscene communications, or impersonate any person or organisation, or falsify sender or caller identity;
- distribute malware, run phishing or social-engineering campaigns, or attempt to gain unauthorised access to systems or data;
- send communications relating to prohibited or high-risk content (for example unlawful financial schemes, illegal products, adult content directed at minors) or to vulnerable individuals in breach of law;
- circumvent usage limits, rate limits, suppression mechanisms or security controls, or use the Service to benchmark or build a competing product;
- upload special category data or children's data except where lawful and properly configured, or process data you have no lawful right to process.
2. UK and EU outreach rules
2.1 Data protection (UK/EU GDPR)
- You must have a valid lawful basis (for example legitimate interests, supported by a balancing assessment, or consent) for processing the personal data of every End Contact, including data you import, scrape or enrich;
- You must provide End Contacts with the privacy information they are entitled to, including, where you did not collect the data from them directly, the information required by Article 14 (such as the source of the data), normally within one month;
- You must honour data-subject rights and objections promptly, and maintain suppression lists so that opt-outs are respected across future campaigns.
2.2 Live and automated calls (PECR)
- Screen all UK calling lists against the Telephone Preference Service (TPS) and Corporate TPS (CTPS) and re-screen at least every 28 days; do not call numbers registered on TPS/CTPS unless the subscriber has specifically consented to your calls;
- Maintain and honour your own internal do-not-call list; stop calling anyone who objects;
- Identify yourself on every call, present a valid caller line identity (CLI), and provide a contact address or number on request. Note that under the Data (Use and Access) Act 2025 an attempted call to a TPS/CTPS-registered number can itself be a breach, even if unanswered;
- Do not make automated (recorded-message) marketing calls without specific prior consent for that type of call; general marketing consent is not enough;
- Treat AI-generated voice and pre-recorded voicemail drops as automated calls requiring the appropriate consent and disclosures.
2.3 Email, SMS and messaging (PECR)
- Send marketing emails and texts to individuals only with consent or under the “soft opt-in” (your own customers, similar products, with an opt-out offered each time);
- Include the sender's identity and a simple, free way to opt out in every marketing message, and honour opt-outs promptly;
- Follow LinkedIn's own terms when sending LinkedIn messages through the integration; do not use automation in a way that breaches LinkedIn's rules.
3. United States outreach rules
3.1 Calls and texts (TCPA, TSR, DNC)
- Obtain prior express written consent (PEWC) where required for autodialled, AI-generated or pre-recorded marketing calls and texts to wireless numbers, and for pre-recorded marketing calls to residential lines;
- Scrub against the National Do-Not-Call Registry and applicable state DNC lists, and maintain an internal DNC list; honour opt-outs (revocable by any reasonable means) promptly, generally within 10 business days;
- Comply with calling-time restrictions, identification requirements and the Telemarketing Sales Rule, and with stricter state laws (for example Florida, Oklahoma, Washington and others);
- Note that AI-generated voices are treated as “artificial or prerecorded voice” calls under the TCPA.
3.2 Email (CAN-SPAM)
- Use accurate “From”, “To” and routing information and non-deceptive subject lines; identify the message as an advertisement where required;
- Include a valid physical postal address and a working opt-out mechanism; honour opt-out requests promptly (within 10 business days) and do not sell or transfer opted-out addresses.
3.3 State privacy laws
- Comply with CCPA/CPRA and other state privacy laws regarding the personal information of US contacts, including honouring access, deletion, correction and opt-out rights and not “selling” or “sharing” data unlawfully.
4. Call recording and monitoring
Where you record, transcribe or analyse calls using the Service: you are the controller of those recordings; you must have a lawful basis and a documented legitimate-interest assessment where you rely on legitimate interests; you must clearly notify all participants before recording begins; you must obtain consent where the law of the relevant jurisdiction requires it (including US all-party-consent states); and you must store, restrict access to, retain and delete recordings securely and lawfully.
5. Data sourcing, scraping and enrichment
When you use lead-sourcing, scraping or enrichment features, you are responsible for ensuring you have the right to collect and use the resulting data, for complying with the terms of any source, for having a lawful basis, and for meeting transparency obligations to the individuals concerned. Do not use the Service to compile or sell data in breach of law or third-party terms.
6. Deliverability, volumes and fair use
You must follow reasonable sending practices: warm up new domains and numbers, keep bounce, spam-complaint and abuse rates low, authenticate your sending domains (SPF, DKIM, DMARC), and respect any usage allowances and rate limits. We may throttle, limit or suspend activity that threatens deliverability, network integrity, or the reputation of shared infrastructure or other customers.
7. Monitoring, enforcement and consequences
We may set technical controls, monitor for abuse and investigate suspected breaches. Where we reasonably believe your use breaches this policy, the Terms or applicable law, or creates risk of harm, liability or carrier action, we may take steps proportionate to the issue, including warning you, throttling or limiting features, removing offending content or data, suspending all or part of the Service, releasing numbers, and terminating the Service. Where practicable we will give notice, but we may act immediately for serious or ongoing breaches or where required by law or a carrier. You will indemnify us for losses arising from your breach, as set out in the Terms.
8. Reporting abuse
If you believe the Service is being used in breach of this policy, or you have received an unwanted communication sent via Leadey, contact us at legal@leadey.io (or hello@leadey.ai, or by phone on +971 55 128 7871) with as much detail as possible (such as the number that called you, the sender, the date and time, and the content). We will investigate and act appropriately, and will route requests to the relevant customer where we act only as processor.
9. Changes
We may update this policy as laws, carrier rules and risks evolve. The current version is the one published on our website or made available in the Service. Material changes will be notified in line with the Terms.