Legal

Privacy Policy — Loyalty LTD

Effective Date: August 30, 2026
Last Updated: August 30, 2026

Loyalty LTD ("Loyalty," "AlwaysHereOS," "we," "us," or "our"), a Nevada domestic limited liability company, respects your privacy and is committed to protecting the personal information we collect, receive, use, store, share, transfer, and process.

This Privacy Policy explains how we collect and use information when you visit www.alwayshereos.com, use our services, submit information through our forms, communicate with us, or otherwise engage with Loyalty.

By accessing or using our websites, platforms, or services, you agree to this Privacy Policy. If you do not agree, please do not use our websites or services.

1. Scope of This Privacy Policy

This Privacy Policy applies to Loyalty websites, landing pages, forms, portals, applications, communications, and related services that link to or reference this Privacy Policy.

Loyalty provides managed operations and related support services to performance marketing companies, including affiliate networks, lead generation companies, and call marketing businesses. Loyalty does not operate its Clients' campaigns in its own name, does not buy or sell leads or calls for its own account, and does not act as an advertising network or lead aggregator.

This Privacy Policy is incorporated into and made part of our Terms and Conditions of Use.

Two different roles. This Privacy Policy distinguishes between two categories of information:

Website and business contact information — information about company owners, managers, employees, job applicants, vendors, and other website visitors who interact with us directly. Loyalty is the business responsible for this information and decides how it is used.
Client consumer information — personal information about consumers, leads, callers, and partners that we access or receive from a Client, or through a Client's platforms and systems, in order to perform managed operations services for that Client. Loyalty handles this information only as a service provider to the Client, under the Client's instructions and under a written agreement. Section 5 explains this in detail.

2. Notice at Collection

We may collect or process the following categories of personal information: identifiers, customer records information, commercial information, internet or electronic network activity, professional or employment-related information, approximate geolocation, audio information from recorded calls where permitted, consumer information contained in Client platforms and records, and inferences.

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and meet applicable recordkeeping requirements.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising. We have not done so in the preceding twelve (12) months.

To exercise privacy rights or submit a privacy request, contact us at privacy@alwayshereos.com or use our Legal Request Form.

3. Personal Information We Collect

For purposes of this Privacy Policy, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household.

3.1 Information You Provide

We may collect personal information you voluntarily provide, including through website forms, service inquiries, engagement discussions, document submissions, employment applications, and other communications.

This information may include:

Name
Business email address
Telephone number
Company name
Company website
Job title or role
The platforms and systems your company uses
Monthly volume, verticals handled, and other business qualification information
Billing and payment information for Clients
Content of messages, files, or documents you send us
Any other information you choose to provide

Your decision to provide personal information is voluntary. If you do not provide certain information, we may be unable to respond to inquiries, evaluate a potential engagement, provide services, or make certain website features available.

3.2 Information Collected Automatically

We may automatically collect information when you visit or interact with our websites, emails, or digital properties. This may include:

IP address
Browser type
Device type
Operating system
Pages viewed
Referring and exit pages
Date and time of visits
Clickstream data
Cookie identifiers
Approximate location derived from IP address
Interaction with emails, forms, or website features

We may use cookies, pixels, tags, log files, and similar technologies to collect this information. See Section 7.

3.3 Information From Clients and Third Parties

We may receive information from:

Client companies, including consumer, lead, caller, and partner information contained in their platforms and records
Call tracking, affiliate tracking, and lead distribution platforms we are given access to
A Client's partners, vendors, and buyers, in connection with the services we perform for that Client
Service providers and technology vendors
Analytics providers
Background screening and identity verification providers, for hiring and vendor onboarding
Publicly available sources

3.4 Call Recordings

Calls to or from Loyalty may be recorded or monitored for quality assurance, training, compliance, and dispute resolution purposes where permitted by law. Where required, we provide notice at the start of the call.

4. How We Use Information

We may use personal information for business purposes, including to:

Provide, operate, maintain, and improve our websites and services
Process and respond to inquiries, intake forms, and service requests
Evaluate, establish, and manage Client engagements
Perform managed operations services on behalf of Clients
Communicate with you about your inquiry, engagement, campaigns, or account
Provide customer and technical support
Invoice, bill, and collect for services
Analyze website performance and improve content
Verify identity, authority, and eligibility
Detect, prevent, and investigate fraud, security incidents, misuse, or unauthorized activity
Enforce agreements, policies, and terms
Maintain internal records, accounting, quality control, audit, and business operations
Comply with legal, regulatory, and recordkeeping obligations
Protect the rights, safety, property, and interests of Loyalty, our Clients, consumers, and others
Evaluate or complete a merger, acquisition, sale, financing, reorganization, or other corporate transaction

We do not use Client consumer information for our own marketing purposes.

5. Client Consumer Information

When Loyalty accesses or receives personal information about a Client's consumers, leads, callers, or partners in connection with a Client engagement, Loyalty acts as a service provider to that Client. The Client is the business with the direct relationship with those individuals, and the Client's own privacy notice governs that relationship.

5.1 What we access or receive

Client consumer information may include name, address, telephone number, email address, call recordings and transcripts, lead form submissions, campaign and source data, transaction and payout records, and other information contained in the Client's platforms and systems that we manage or support.

5.2 How we use it

We use Client consumer information only to perform the services requested by the Client, under the Client's instructions, our written agreement with the Client, and applicable law.

We do not use Client consumer information for our own purposes, do not sell it, do not share it for advertising, do not add those individuals to marketing lists, and do not disclose it except as directed by the Client or as required by law.

5.3 Who we disclose it to

At the Client's direction and as necessary to perform the services, Client consumer information may be provided to the Client's platforms of record, the Client's partners, buyers, and vendors engaged on a campaign, and our own vetted subcontractors and technology service providers bound by written confidentiality and security obligations.

5.4 How we protect it

We maintain administrative, technical, and physical safeguards designed to protect Client consumer information, including:

Encryption of data in transit
Role-based access controls limiting access to personnel assigned to the engagement
Access logging and periodic access reviews
Prompt revocation of access on personnel offboarding
Confidentiality obligations for all personnel and subcontractors
Secure transfer channels rather than unsecured email for sensitive records
Retention and deletion practices aligned with Client agreements

5.5 Retention and deletion

We retain Client consumer information for the period specified in the applicable Client agreement, or as required by law or audit requirements. After that period, records in our possession are deleted or destroyed using methods designed to prevent reconstruction. Records held in a Client's own platforms remain under the Client's control.

5.6 Consumer requests

If you are a consumer, lead, or caller and wish to make a privacy request regarding information held in a Client's systems, please contact the company you interacted with, since they control the data and their privacy notice governs. If you contact us directly at privacy@alwayshereos.com, we will forward your request to the applicable Client and assist as their service provider.

6. Disclosure of Personal Information

We may disclose personal information to third parties for the purposes described in this Privacy Policy.

6.1 Service Providers

We may disclose information to vendors and service providers who perform services on our behalf, including website hosting, cloud storage, secure document transfer, data processing, email and communications, customer support, payment processing, analytics, call recording, CRM and workflow systems, data security, background screening, and professional services.

Service providers are contractually restricted from using personal information for any purpose other than performing services for us.

6.2 Clients and Campaign Participants

As described in Section 5, we disclose Client consumer information to the applicable Client and, at the Client's direction, to the Client's platforms, partners, buyers, and vendors as necessary to perform the services.

6.3 Legal, Compliance, and Safety Purposes

We may disclose information when we believe it is reasonably necessary to:

Comply with applicable law or legal process
Respond to subpoenas, court orders, regulatory inquiries, or government requests
Enforce our agreements, policies, or rights
Protect against fraud, misuse, or unauthorized activity
Protect the rights, property, safety, or security of Loyalty, our Clients, consumers, or others

6.4 Corporate Transactions

We may disclose or transfer information in connection with an actual or proposed merger, acquisition, investment, financing, restructuring, bankruptcy, sale of assets, or other corporate transaction, subject to the confidentiality obligations that apply to that information.

6.5 Professional Advisors

We may disclose information to legal, accounting, financial, insurance, compliance, audit, and other professional advisors.

6.6 With Your Consent or Direction

We may disclose personal information when you consent to or direct the disclosure.

6.7 Aggregated, De-Identified, or Anonymized Information

We may use and disclose aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify de-identified information except as permitted by law.

6.8 What We Do Not Do

We do not sell personal information. We do not share personal information for cross-context behavioral advertising or targeted advertising. We do not disclose personal information to lead buyers, lead aggregators, data brokers, or list vendors for their own purposes. We do not rent or trade contact lists.

7. Cookies and Tracking Technologies

We and our service providers may use cookies, pixels, tags, scripts, log files, and similar technologies to collect information about your interactions with our websites and emails.

These technologies are used to:

Operate the website and remember preferences
Analyze traffic and usage
Measure the performance of our own content and pages
Detect fraud, spam submissions, or security issues
Understand how visitors find and use the site

You may be able to adjust your browser settings to refuse or remove cookies. Disabling cookies may affect the availability or functionality of certain website features.

We do not use cookies or pixels to build advertising profiles about you across unaffiliated websites, and we do not disclose website analytics data to advertising networks for their own purposes.

8. Do Not Track and Global Privacy Control

Some browsers offer "Do Not Track" signals. Because there is no uniform standard for recognizing or responding to such signals, we do not currently respond to all Do Not Track signals.

Because we do not sell or share personal information for targeted advertising, opt-out preference signals such as Global Privacy Control have no data for us to act upon. We nonetheless honor requests submitted through the mechanisms in Section 9.

9. Your Privacy Rights and Choices

Depending on where you live, you may have certain rights regarding your personal information. These rights may include the right to:

Know or access the personal information we collect about you
Request deletion of personal information
Request correction of inaccurate personal information
Opt out of the sale or sharing of personal information (we do not sell or share)
Opt out of targeted advertising (we do not engage in targeted advertising)
Limit certain uses of sensitive personal information, where applicable
Receive a copy of certain personal information in a portable format
Opt out of marketing communications
Appeal a decision regarding a privacy request, where applicable
Not be discriminated against for exercising privacy rights

To submit a privacy request, email privacy@alwayshereos.com or use our Legal Request Form. To opt out of communications, email optout@alwayshereos.com or see our Opt Out Request page.

We will respond within the timeframes required by applicable law, generally within forty-five (45) days, with an extension where permitted.

We may need to verify your identity before fulfilling your request. Verification may require information such as your name, email address, phone number, company, state of residence, or other information reasonably necessary to confirm your identity and locate your records.

If we deny a request in whole or in part, you may appeal by replying to our response with the subject line "Privacy Appeal" or by emailing privacy@alwayshereos.com. We will respond to appeals within the period required by applicable law.

10. Authorized Agents

Where permitted by law, you may designate an authorized agent to submit a privacy request on your behalf. We may require written proof of authorization and may also require you to verify your identity directly with us.

11. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, provide services, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, and support legitimate business operations.

Retention periods vary depending on the type of information, the purpose of collection, legal and regulatory requirements, contractual obligations, and operational needs. Client consumer information is retained under Section 5.5.

12. Security

We use reasonable technical, physical, and administrative safeguards designed to protect personal information from unauthorized access, disclosure, loss, misuse, alteration, or destruction, as described in Section 5.4.

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of any information transmitted to or stored by us.

If we become aware of a security incident affecting personal information, we will notify affected individuals, Clients, and regulators as required by applicable law.

13. Children

Our websites and services are directed to businesses and are not intended for children under 16. We do not knowingly collect, use, sell, or share personal information from children under 16.

If you believe a child has provided personal information to us, contact us at privacy@alwayshereos.com and we will take reasonable steps to delete the information as required by law.

14. Third-Party Websites

Our websites may contain links to third-party websites, platforms, or services that we do not own or control, including the platforms we manage for Clients. We are not responsible for the privacy practices, content, or policies of third parties.

Review the privacy policies of any third-party websites or services before providing personal information.

15. Notice to California Residents

If you are a California resident, this section supplements the rest of this Privacy Policy and applies to personal information subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act. Additional detail is on our California Privacy / CPRA page.

15.1 Categories of Personal Information Collected

In the preceding 12 months, we may have collected:

Identifiers, such as name, business email address, phone number, IP address, or online identifier
Personal information categories listed in California Civil Code Section 1798.80, such as contact information and, within Client platforms and records, consumer contact and transaction information
Commercial information, such as services requested, considered, or purchased
Internet or electronic network activity information, such as pages viewed, referring URLs, and form interactions
Geolocation data, limited to approximate location derived from IP address or a state or ZIP code you provide
Audio information, from recorded calls where permitted
Professional or employment-related information, such as job title, company, and business volume
Inferences, such as the likely fit of a company for our services
Sensitive personal information, only where contained in Client platforms or records we are given access to in order to perform the services, and used solely to perform the services

15.2 Sources of Personal Information

You directly; your device or browser; Client companies; a Client's platforms, partners, buyers, and vendors; service providers and technology vendors; and publicly available sources.

15.3 Purposes

We collect, use, and disclose personal information for the purposes described in Section 4 and, for Client consumer information, Section 5.

15.4 Categories of Third Parties

Service providers and contractors; Client companies; a Client's platforms, partners, buyers, and vendors; professional advisors; and government or legal authorities where required.

15.5 Sale or Sharing of Personal Information

We do not sell personal information and we do not share personal information for cross-context behavioral advertising. In the preceding 12 months, we have not sold or shared personal information, including personal information of consumers under 16 years of age.

Because we do not sell or share, there is no sale or sharing to opt out of. You may still submit a request at optout@alwayshereos.com and we will confirm our practices in writing.

15.6 Use of Sensitive Personal Information

We use sensitive personal information only for purposes permitted under California Civil Code Section 1798.121(a) — to perform the services requested and for permitted business purposes such as security and legal compliance. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about a consumer.

15.7 California Privacy Rights

California residents may have the right to know, access, delete, correct, opt out of sale or sharing, limit use of sensitive personal information, and not receive discriminatory treatment for exercising privacy rights.

To exercise these rights, email privacy@alwayshereos.com or use our Legal Request Form.

16. California "Shine the Light"

California Civil Code Section 1798.83 permits California residents with an established business relationship with us to request information regarding our disclosure of personal information to third parties for those third parties' direct marketing purposes.

We do not disclose personal information to third parties for their direct marketing purposes. To submit a request, email privacy@alwayshereos.com with the subject line "California Shine the Light Request."

17. Notice to Residents of Other States

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws may have rights to access, correct, delete, obtain a portable copy of personal information, opt out of targeted advertising, opt out of sale of personal information, opt out of certain profiling, and appeal a denial.

We do not sell personal information, do not process personal information for targeted advertising, and do not engage in profiling that produces legal or similarly significant effects.

To submit a request, email privacy@alwayshereos.com or use our Legal Request Form.

Where we hold information only as a Client's service provider, we will tell you so in our response and direct you to the Client that controls the data.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective when posted unless otherwise stated.

The "Last Updated" date above indicates when this Privacy Policy was last revised. Your continued use of our websites or services after changes are posted means you acknowledge the updated Privacy Policy.

19. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, contact us at:

Loyalty LTD
2206 Heavenly View Drive
Henderson, NV 89014

Phone: (505) 477-3990
Privacy requests: privacy@alwayshereos.com
Opt-out requests: optout@alwayshereos.com
General support: support@alwayshereos.com