Privacy Policy

Sky Lane Network LLC ("Sky Lane Network," "we," "us," or "our") operates the website located at skylanenetwork.com and the associated lead exchange platform and API (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with the Platform, including information submitted by Buyers, Sellers, consumers whose information is transmitted as part of a Lead, and visitors to our website.

This Policy should be read together with our Terms & Conditions. Capitalized terms not defined here have the meaning given to them in the Terms & Conditions.

1. Information We Collect

1.1 Information from Website Visitors

When you visit our website, we may automatically collect device and usage information, including IP address, browser type, referring pages, and pages viewed, using cookies and similar technologies described in Section 5.

1.2 Information from Partner Accounts

When a Buyer or Seller registers for an account or submits an inquiry, we collect business and contact information such as company name, contact name, email address, phone number, billing information, tax identification information, and details about the applicant's traffic sources or buying criteria.

1.3 Lead Data

As part of operating the Platform, we process personal information about consumers that Sellers submit as Leads, and that Buyers subsequently receive. Depending on the vertical, this may include a consumer's name, contact information, address, date of birth, and category-specific qualifying information (for example, income range, credit band, insurance coverage type, or loan amount requested). Sellers are solely responsible for obtaining the consumer consent described in our Terms & Conditions before submitting any Lead.

2. How We Use Information

• To operate, maintain, and improve the Platform, including ping-post routing, campaign matching, and fraud/duplicate detection;
• To facilitate delivery of Leads from Sellers to Buyers and to process related payments;
• To communicate with Buyers and Sellers about their accounts, campaigns, and support requests;
• To investigate and resolve lead quality disputes and compliance inquiries;
• To comply with legal obligations, enforce our Terms & Conditions, and protect the rights, property, and safety of Sky Lane Network, our partners, and consumers; and
• To detect, prevent, and respond to fraud, abuse, or security incidents.

3. How We Share Information

We disclose information in the following circumstances:

• With Buyers. Lead Data is transmitted to the Buyer(s) who accept a ping or receive a post, in accordance with the applicable campaign configuration.
• With service providers. We share information with vendors who support hosting, payment processing, identity/fraud verification, analytics, and customer communications, under confidentiality and data-protection obligations.
• For legal reasons. We may disclose information to comply with applicable law, regulation, legal process, or governmental request, including requests from state attorneys general or the FTC relating to telemarketing or lending compliance.
• Business transfers. Information may be disclosed in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

We do not sell Lead Data to parties outside the intended Buyer for that Lead's campaign, and we do not permit Buyers to resell or re-distribute Lead Data except as permitted under our Terms & Conditions.

4. Financial Services & GLBA-Adjacent Data

Leads submitted in financial services verticals (for example, personal loans, mortgage, or debt relief) may include nonpublic personal information as contemplated by the Gramm-Leach-Bliley Act. Buyers operating as financial institutions are responsible for maintaining their own GLBA-compliant privacy and safeguarding programs with respect to Lead Data they receive. We maintain administrative, technical, and physical safeguards designed to protect such information while it is within our systems, as described in Section 6.

5. Cookies & Tracking Technologies

We use cookies, pixels, and similar technologies to operate the website, remember preferences, and understand aggregate usage patterns. You can control cookies through your browser settings; disabling cookies may affect site functionality. We do not currently respond to browser "Do Not Track" signals.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls, and logging of Lead delivery events. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain account information for as long as an account is active and as needed to comply with legal, tax, and accounting obligations. We retain Lead Data and associated consent records for the period necessary to support dispute resolution, compliance audits, and applicable statutes of limitation, after which it is deleted or de-identified.

8. Your Privacy Rights

Depending on your state of residence, you may have rights to know what personal information is collected about you, request deletion or correction of that information, opt out of certain sharing, and not be discriminated against for exercising these rights, under laws such as the California Consumer Privacy Act (as amended by the CPRA), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, and similar state laws.

To submit a privacy rights request, email compliance@skylanenetwork.com with your request and sufficient information for us to verify your identity. If you are a consumer whose information was submitted as a Lead by a Seller, we will direct verifiable deletion or opt-out requests to the applicable Seller and/or Buyer where required, and will honor requests directed to us regarding data still in our possession.

9. Children's Privacy

The Platform is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. Leads relating to consumers under 18 are not permitted on the Platform except where a vertical's field set explicitly calls for household or dependent information.

10. U.S.-Focused Service

The Platform is intended for use by businesses operating in, and consumers located in, the United States. If you access the Platform from outside the United States, you do so on your own initiative and are responsible for compliance with local law.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date above, and, where required by law, we will provide additional notice.

12. Contact Us

Sky Lane Network LLC
8 The Green, Suite A
Dover, DE 19901
compliance@skylanenetwork.com