Caliber Capital Advisors ("Caliber," "we," "us," or "our") is a performance-based customer acquisition business operated by Caliber Wealth Group, LLC, a Delaware limited liability company. We source high-intent inbound phone calls and consumer data leads from publishers and media partners, and we route or resell that call and lead traffic to buyers (advertisers) in verticals including insurance, financial services, home services, legal, and home warranty. This Privacy Policy explains what personal information we collect, how we collect it, how we use and share it, and the choices and rights available to you.
01Scope of This Policy
This Policy applies to personal information we collect through our website, through phone calls we receive or facilitate, through lead generation forms hosted by us or our publisher partners, and through any other channel where we obtain information about a consumer in connection with our call and lead routing business. It applies whether you reached us directly or were referred to us by a publisher, media partner, or affiliate.
This Policy does not cover the privacy practices of the buyers, advertisers, publishers, or other third parties to whom your information may be routed or sold. Once your information is shared with a buyer or partner in accordance with this Policy, that party's own privacy policy governs its further handling of your information.
02Information We Collect
We collect the following categories of information:
Contact and Identifying Information
- Name, mailing address, email address, and phone number.
- Demographic details relevant to the vertical you are inquiring about, such as age range, homeownership status, or insurance type sought.
- Any other information you voluntarily submit on a lead form, such as details about your inquiry, coverage needs, or property.
Call Recordings and Call Metadata
- Audio recordings of inbound calls, where permitted and disclosed, including calls placed to tracking numbers used to measure call quality and source.
- Call metadata, including the calling number, called number, call duration, call disposition, timestamp, and the publisher or campaign source of the call.
Lead Form Data
- Information submitted through online forms, landing pages, or ping-post integrations operated by us or by our publisher network, including consent timestamps and the specific consent language presented at the point of collection.
Site Analytics and Cookie Data
- IP address, browser and device type, referring and exit pages, pages viewed, and approximate location derived from your IP address.
- Information collected through cookies, pixels, and similar tracking technologies, described further in the Cookies section below.
03How We Collect Information
We obtain information in two principal ways:
- Directly from you. When you call a tracking number associated with our campaigns, submit a lead form on our website, or otherwise contact us, we collect the information you provide.
- From publishers and media partners. Our publisher and media partner network generates calls and leads on our behalf through their own advertising, websites, and call centers. Those publishers collect information from consumers directly and transmit it to us, along with records evidencing the consent obtained at the point of collection. We require our publishers to obtain lawful consent before transmitting a call or lead to us, and we conduct ongoing compliance monitoring of publisher intake practices.
04How We Use Information
We use the information we collect to:
- Route and sell qualified calls and leads to buyers in the relevant vertical.
- Verify consent, screen for duplicate or fraudulent submissions, and confirm that a call or lead meets a buyer's accept criteria.
- Monitor, record, and review calls for quality assurance, dispute resolution, and compliance verification.
- Operate, maintain, and improve our website and lead intake systems.
- Communicate with you about your inquiry, including confirming that you were connected with a buyer.
- Detect, investigate, and prevent fraud, abuse, and violations of applicable law or our agreements with publishers and buyers.
- Comply with legal obligations and enforce our contractual rights.
05Sharing With Buyers and Partners
Sharing your information with buyers is central to how our business works. When you call or submit a lead in connection with a Caliber campaign, we share the relevant contact information, call recording or metadata, and lead form data with the buyer or buyers who purchase that call or lead. Depending on the vertical and the buyer's arrangement with us, a single call or lead may be routed to one buyer exclusively or offered to multiple prospective buyers through a real-time bidding process before being awarded to one.
We also share information with:
- Service providers who perform functions on our behalf, such as call tracking, hosting, analytics, consent verification, and payment processing, and who are contractually restricted from using your information for any purpose other than providing services to us.
- Publishers and media partners, to the extent needed to reconcile call and lead quality, resolve disputes, or verify consent records.
- Professional advisors and regulators, where necessary to comply with law, respond to legal process, or protect our rights.
- A successor entity, in the event of a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.
We do not sell your Social Security number, financial account numbers, or government identification numbers. We do not knowingly sell health information beyond what you affirmatively disclose in connection with an insurance inquiry you have initiated.
06Calls, Text Messages, and TCPA Consent
Because our business depends on inbound calls and, in some campaigns, outbound or automated communications, we take consent seriously under the Telephone Consumer Protection Act (TCPA) and related state telemarketing laws.
- Where a campaign involves autodialed calls, prerecorded or artificial voice calls, or text messages to a consumer's phone, we and our publisher partners obtain prior express written consent before any such communication is placed, in the form and manner required by applicable law.
- Consent records, including the specific disclosure language shown to the consumer and the timestamp of consent, are retained and made available to buyers and, where required, to regulators, to substantiate that a call or lead was lawfully generated.
- Inbound calls that you place to a tracking number are recorded where disclosed at the start of the call, consistent with applicable state two-party or one-party consent recording laws.
- You may revoke consent to receive future calls or texts at any time by following the instructions in the message you received, by replying "STOP" where applicable, or by contacting us using the details in the Contact Us section below.
07Cookies and Tracking Technologies
Our website uses cookies, pixels, and similar technologies to operate the site, measure traffic and campaign performance, attribute calls and leads to the correct publisher source, and, in some cases, support advertising measurement. These technologies may be set by us or by third-party analytics and attribution providers we work with.
You can control cookies through your browser settings, including blocking or deleting cookies. Doing so may affect the functionality of our site and our ability to attribute your inquiry to the correct source. Where required by law, we present a cookie notice or preference tool allowing you to manage non-essential cookies, and residents of applicable states may also exercise the opt-out rights described in the section below.
08Your Privacy Rights
Depending on where you live, you may have rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) and comparable laws in other states, including the right to:
- Know and access the categories and specific pieces of personal information we have collected about you and the sources, purposes, and third parties involved.
- Delete personal information we have collected from or about you, subject to certain legal exceptions.
- Correct inaccurate personal information we maintain about you.
- Opt out of the sale or sharing of your personal information. Because we route and resell calls and leads to buyers, this activity may constitute a "sale" or "sharing" of personal information under some state laws.
- Limit the use of sensitive personal information, where applicable.
- Non-discrimination for exercising any of these rights.
To exercise your access, deletion, or correction rights, contact us using the information in the Contact Us section. We will verify your identity before fulfilling a request, using information reasonably necessary to confirm you are the person about whom we hold data, and we will respond within the time period required by applicable law. You may designate an authorized agent to submit a request on your behalf, subject to verification.
09Data Retention
We retain personal information, call recordings, and consent records for as long as reasonably necessary to fulfill the purposes described in this Policy, including satisfying buyer dispute windows, resolving billing and compliance disputes with publishers, defending against legal claims, and meeting record-keeping obligations under TCPA and state telemarketing laws, after which the information is deleted or de-identified in accordance with our internal retention schedule.
10Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, including access controls limiting who within our organization and our service providers can view call recordings and lead data, and encryption of data in transit where technically supported. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you become aware of a security concern involving our systems, please contact us immediately using the details below.
11Children's Privacy
Our services are directed to businesses and adult consumers and are not directed to, marketed to, or intended for individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe a minor has provided us with personal information, please contact us using the details below.
12Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or applicable law. When we make changes, we will revise the "Last updated" date at the top of this page. Material changes will be posted on this page, and where required by law we will provide additional notice. Your continued use of our services after a revised Policy is posted constitutes your acknowledgment of the updated terms.
13Contact Us
If you have questions about this Privacy Policy, want to exercise your privacy rights, or want to opt out of future calls, texts, or the sale or sharing of your information, contact us at:
Caliber Capital Advisors
c/o Caliber Wealth Group, LLC
16192 Coastal Hwy, Lewes, DE 19958
Email: hello@calibercapitaladvisors.com