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PRIVACY POLICY

Effective Date: August 5, 2026
Last Updated: September 2, 2026

PowderDay LLC ("PowderDay," "we," "us," or "our") is an online advertising and customer acquisition company located at:

PowderDay LLC
6834 South University Boulevard, #102
Centennial, Colorado 80122

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit a website operated by PowderDay, submit an online form, respond to an advertisement, communicate with us, or otherwise use a website, landing page, application, campaign, or service that links to this Privacy Policy (collectively, the "Services").

It also describes the privacy choices and rights that may be available to you.

1. Scope

This Privacy Policy applies to personal information that PowderDay collects through the Services and through related communications, advertising campaigns, customer acquisition activities, and business operations.

This Privacy Policy does not apply to:

  • Information collected by a third party on a website, application, or service that it independently controls;
  • Information processed solely in an employment or independent-contractor context;
  • Information about representatives of businesses when the information is processed solely in a commercial or business-to-business context, to the extent exempted by applicable law; or
  • Information that is exempt from applicable privacy laws.

When we provide a separate or supplemental privacy notice for a particular service, campaign, or category of information, that notice will govern to the extent it conflicts with this Privacy Policy.

2. Our Role in Advertising and Customer Acquisition

PowderDay designs and operates online advertising campaigns on behalf of businesses that offer products and services to consumers. Depending on the campaign, we collect information from individuals who request information about an advertised product or service and connect those individuals with the business identified in the campaign.

These businesses may include advertisers, service providers, lenders, insurance providers, real estate professionals, professional-service providers, or other companies identified on the applicable form or disclosure.

When you submit a request, ask for a quote, or otherwise express interest in an advertised product or service:

  1. PowderDay may use your information to process, verify, qualify, route, and respond to your request;
  2. PowderDay may disclose your information to the business or businesses identified on or near the form you completed;
  3. Those businesses may independently use your information under their own privacy policies, for the purpose of responding to your request; and
  4. You may be contacted about the product or service in which you expressed interest, subject to your consent and applicable law.

We do not operate a marketplace, exchange, or resale channel for consumer contact information. Information you submit is routed only to the business identified in the disclosure presented to you at the time of submission.

Submitting a request does not guarantee that you will qualify for, receive, or purchase any product or service.

3. Personal Information We Collect

The information we collect depends on how you interact with the Services and the information requested in a particular campaign.

A. Information You Provide Directly

We may collect:

  • First and last name;
  • Mailing address, city, state, and ZIP code;
  • Email address;
  • Telephone number;
  • Preferred method or time of contact;
  • Information entered into online forms, questionnaires, surveys, or applications;
  • Product or service interests;
  • Information used to evaluate or qualify a request;
  • Communications, requests, feedback, and customer-support information;
  • Records of consent, including the wording presented when consent was obtained;
  • Information you provide when exercising a privacy right; and
  • Any other information you voluntarily provide.

B. Qualification Information

Depending on the campaign, we may collect information relevant to the requested product or service, such as:

  • Property, homeownership, or housing information;
  • Business ownership or employment information;
  • Estimated budget, purchasing timeframe, or service needs;
  • Project type and location;
  • Insurance, financing, or service preferences;
  • Information about an existing product, account, contract, or service; and
  • Other eligibility or qualification information disclosed on the relevant form.

We do not intend to collect highly sensitive information unless it is necessary for a clearly disclosed service and permitted by law. Do not submit Social Security numbers, complete financial-account credentials, medical records, government identification numbers, or similarly sensitive information unless a PowderDay form specifically requests the information and explains why it is required.

C. Information Collected Automatically

When you use the Services, we and our vendors may automatically collect:

  • Internet Protocol address;
  • Browser type and version;
  • Device type, operating system, and device identifiers;
  • General geographic location derived from an IP address;
  • Referral source;
  • Pages, advertisements, and links viewed;
  • Dates, times, and duration of visits;
  • Form interactions and conversion events;
  • Clickstream and navigation information;
  • Cookie identifiers and advertising identifiers;
  • Network and diagnostic information; and
  • Information about interactions with emails, advertisements, and marketing campaigns.

D. Information from Third Parties

We may obtain information from:

  • Advertising platforms and social-media platforms;
  • Data analytics and attribution providers;
  • Advertisers and clients, regarding the status of a request you submitted;
  • Service providers acting on our behalf;
  • Publicly available records and sources; and
  • Other persons or entities acting with your authorization.

When required by law, we take reasonable steps to confirm that third parties are authorized to provide the information to us.

We do not purchase, rent, or license consumer telephone numbers from data brokers, list vendors, publishers, or contact marketplaces, and we do not append or infer telephone numbers that a consumer did not provide directly.

4. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, tags, scripts, software-development kits, local storage, session-replay technologies, and similar tools to:

  • Operate and secure the Services;
  • Remember preferences;
  • Measure website traffic and campaign performance;
  • Diagnose technical issues;
  • Prevent fraud and abuse;
  • Attribute requests or conversions to particular advertisements;
  • Conduct analytics;
  • Personalize content;
  • Deliver or measure targeted advertising; and
  • Improve our Services and marketing campaigns.

Some technologies are necessary for the Services to function. Others may be used for analytics, advertising, or personalization.

You may be able to control cookies through our cookie-preference tool, where offered, or through your browser settings. Blocking cookies may affect the operation of certain features.

PowderDay also processes qualifying browser-based universal opt-out signals as described in Section 13.

5. How We Use Personal Information

We may use personal information to:

  • Provide, operate, maintain, and improve the Services;
  • Process and respond to requests;
  • Match or connect individuals with relevant businesses;
  • Verify, qualify, and route consumer requests to the appropriate business;
  • Communicate about requested products or services;
  • Provide customer service;
  • Administer advertising and marketing campaigns;
  • Measure campaign performance, attribution, and conversions;
  • Personalize content and advertisements;
  • Analyze website use and consumer interests;
  • Develop and improve our technology, products, and services;
  • Maintain accurate suppression, consent, and opt-out records;
  • Detect, investigate, and prevent fraud, misuse, security incidents, and unlawful activity;
  • Protect the rights, property, and safety of PowderDay, our clients, consumers, and others;
  • Comply with laws, regulations, legal processes, and enforceable governmental requests;
  • Establish, exercise, or defend legal claims;
  • Enforce our agreements and policies;
  • Complete a merger, acquisition, financing, sale, restructuring, or similar corporate transaction; and
  • Carry out other purposes disclosed at the time information is collected or with your consent.

We will not process personal information for a purpose that is not reasonably necessary or compatible with the purpose disclosed at collection unless we provide additional notice and obtain consent when required.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

A. Advertisers and Participating Businesses

When you request information about an advertised product or service, we may disclose your information to the business identified on or near the form you completed.

These businesses may independently determine how to use your information and may be separate "controllers" or "businesses" under applicable privacy laws. Their use of your information is governed by their own privacy policies.

B. Service Providers and Processors

We may disclose information to companies that perform services on our behalf, including:

  • Website hosting and cloud-storage providers;
  • Form, call-tracking, and communications platforms;
  • Customer-relationship-management providers;
  • Email and text-message providers;
  • Data analytics and attribution providers;
  • Advertising technology providers;
  • Fraud-prevention and cybersecurity providers;
  • Consent-recording and compliance vendors;
  • Professional advisers, accountants, insurers, and attorneys; and
  • Other operational vendors.

We contractually require service providers to process personal information only for authorized purposes and to provide protections appropriate to the nature of the information.

C. Advertising and Analytics Partners

We may disclose online identifiers, device information, browsing activity, campaign interactions, and related information to advertising and analytics partners. Depending on the circumstances, this activity may constitute targeted advertising, sharing, or a "sale" of personal data under certain state privacy laws, even when no money is exchanged.

This subsection does not apply to telephone numbers or text-message consent records, which are handled as described in Section 9.D.

You may opt out as described in Sections 11 and 12.

D. Legal, Safety, and Compliance Recipients

We may disclose information when reasonably necessary to:

  • Comply with applicable law, legal process, or governmental requests;
  • Investigate suspected fraud, misuse, or unlawful activity;
  • Enforce agreements or policies;
  • Protect legal rights, safety, or property; or
  • Respond to an emergency.

E. Corporate Transactions

We may disclose or transfer information in connection with an actual or proposed merger, acquisition, financing, asset sale, bankruptcy, restructuring, or similar transaction. A recipient of personal information in such a transaction may continue to use it subject to this Privacy Policy unless it provides legally required notice of a change.

F. At Your Direction

We may disclose information to another person or entity at your direction or with your consent.

7. Categories of Personal Data and Processing Purposes

For purposes of the Colorado Privacy Act, PowderDay may process the following categories of personal data:

Category Examples Principal Purposes
Identifiers Name, email address, telephone number, postal address, IP address, cookie ID Request processing, communications, security, advertising, analytics
Customer and request information Product interests, service needs, project details, qualification responses Matching, qualification, routing, customer service
Internet or electronic activity Browsing activity, advertisement interactions, referral source, conversion data Analytics, attribution, security, targeted advertising
Commercial information Products or services considered, requested, or purchased Request processing, campaign measurement, personalization
Geolocation information General location derived from IP address or information you provide Routing requests, localization, fraud prevention
Professional information Employer, business, occupation, or professional needs Business-service requests and qualification
Inferences Probable interests, preferences, or likelihood of purchasing Campaign optimization, matching, targeted advertising
Communications Emails, calls, messages, and support requests Responding to requests, compliance, dispute resolution
Sensitive data, when specifically disclosed and lawfully collected Information defined as sensitive under applicable law Only for the disclosed purpose and with consent when required

We may disclose these categories to the recipients described in Section 6.

8. Sensitive Data

PowderDay does not knowingly collect or process sensitive data unless:

  • The collection is reasonably necessary for a specific and disclosed service;
  • Appropriate notice is provided;
  • Any consent required by law is obtained; and
  • The information is subject to safeguards appropriate to its sensitivity.

Sensitive data may include information revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or immigration status, genetic or biometric information used for identification, precise geolocation, or personal data concerning a known child.

We do not sell sensitive data without consent where prohibited by law.

You may withdraw consent to the processing of sensitive data by contacting us as described in Section 23. Withdrawal will not affect processing that occurred before the withdrawal became effective.

9. Communications, Email, Telephone Calls, and Text Messages

A. Email

We may send emails relating to a request, requested service, transaction, or business relationship. Where permitted by law, we may also send commercial or promotional emails.

You may unsubscribe from promotional emails by using the unsubscribe link contained in the email. We may still send non-promotional communications concerning an existing request, transaction, legal notice, privacy request, or security matter.

B. Calls and Text Messages

When you provide a telephone number and affirmatively agree to be contacted, PowderDay and the specifically identified businesses may contact you as described in the consent disclosure presented with the form.

Consent may include calls or text messages made using an automatic telephone dialing system, artificial or prerecorded voice, or other automated technology, but only when the applicable disclosure expressly states this and legally sufficient consent has been obtained.

Consent to receive marketing calls or texts is not a condition of purchasing any property, goods, or services.

Message and data rates may apply. Message frequency may vary.

You may withdraw consent to text messages by replying STOP. You may also request that calls stop by telling the caller, using another opt-out method provided in the communication, or contacting PowderDay.

Opt-out requests may take a reasonable period to process as permitted by law. A one-time confirmation message may be sent in response to a text-message opt-out.

C. Separate Consent Records

PowderDay may retain records showing:

  • The date and time consent was provided;
  • The applicable web page, form, or campaign;
  • The language displayed to the consumer;
  • The telephone number or email address submitted;
  • Associated technical information; and
  • Any subsequent withdrawal or revocation of consent.

These records may be created, transmitted, and independently maintained by a third-party consent-certification provider engaged by PowderDay for the purpose of documenting consent. Where such a provider is used, the provider may capture and store a record of the web page and consent language presented at the time of submission, together with associated technical information, and may retain that record independently of PowderDay's own systems.

D. Telephone Numbers and SMS Consent

Telephone numbers and text-message consent records are handled separately from other categories of information described in this Privacy Policy.

Source. Every telephone number PowderDay holds was entered directly by the individual on a PowderDay form or a form operated by PowderDay on behalf of a client. We do not purchase, rent, license, import, append, or infer telephone numbers.

Consent. Text messages are sent only to individuals who affirmatively opted in through an unchecked consent checkbox presented with the disclosure identifying every party authorized to make contact. Consent to receive marketing calls or texts is never a condition of purchase.

Disclosure limits. Telephone numbers and associated consent records are not sold, rented, licensed, or transferred to any party other than the business identified in the consent disclosure presented at the time of submission. They are not made available to contact marketplaces, data aggregators, list vendors, or unaffiliated marketers, and no third party is authorized to use them for its own marketing purposes.

Revocation. A revocation received on any channel suppresses telephone, text, and email contact for the associated record. Revocations are logged with timestamp and channel and retained as described in Section 15.

Additional detail is available in our SMS Terms & Messaging Policy.

10. Sale of Personal Data, Targeted Advertising, and Profiling

PowderDay may engage in the following processing activities, depending on the campaign and technology used:

A. Sale of Personal Data Under the Colorado Privacy Act

Under the Colorado Privacy Act, a "sale" generally includes exchanging personal data for monetary or other valuable consideration.

PowderDay may receive compensation for generating, qualifying, or transferring a consumer request to an advertiser or service provider. Depending on the structure of the campaign and applicable legal definitions, this disclosure may constitute a sale of personal data.

PowderDay does not sell personal data in exchange for money unless the practice is disclosed at or before the time the information is collected and the consumer is provided any legally required opt-out right.

Exclusion for telephone numbers and consent records. This Section 10.A does not apply to telephone numbers or to records of consent to telephone or text-message contact. PowderDay does not sell, rent, license, or otherwise transfer telephone numbers or SMS consent records to any party other than the business identified in the consent disclosure presented to the consumer at the time of submission, and does not receive compensation for making telephone numbers available to any other party. See Section 9.D.

B. Targeted Advertising

PowderDay and its partners may use information about activity across nonaffiliated websites, applications, or services to select advertisements based on predicted interests. This may constitute targeted advertising under Colorado law.

C. Profiling

We may use automated tools to evaluate the likely relevance, quality, source, or routing of a consumer request. We do not knowingly use automated profiling to make decisions that produce legal or similarly significant effects concerning a consumer unless we provide the notices and rights required by law.

You may opt out of sale, targeted advertising, and qualifying profiling as described below.

11. Colorado Privacy Rights

Subject to applicable exceptions, Colorado residents may have the right to:

  • Confirm processing: Confirm whether PowderDay processes their personal data;
  • Access: Obtain access to personal data PowderDay processes about them;
  • Correction: Correct inaccuracies in their personal data;
  • Deletion: Request deletion of personal data they provided or that PowderDay obtained about them;
  • Data portability: Obtain a portable copy of certain personal data;
  • Opt out of sale: Opt out of the sale of personal data;
  • Opt out of targeted advertising: Opt out of processing for targeted advertising;
  • Opt out of profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects;
  • Withdraw consent: Withdraw consent for processing when processing is based on consent; and
  • Appeal: Appeal PowderDay's refusal to act on a privacy request.

PowderDay will not unlawfully discriminate against a consumer for exercising a privacy right.

Residents of other states. Depending on where you reside, you may have additional or different privacy rights under applicable state law, including the New Jersey Data Privacy Act and the Connecticut Data Privacy Act. Where those laws apply, we honor the rights described in this section and any additional rights those laws provide. Requests are handled under the process in Section 12 regardless of state.

12. How to Exercise Privacy Rights

You may submit a privacy request through either of the following methods:

  • Email: support@powderday.net, with "Privacy Request" in the subject line
  • Mail: PowderDay LLC, Attn: Privacy Request, 6834 South University Boulevard, #102, Centennial, Colorado 80122

Your request should identify:

  • Your full name;
  • The email address, telephone number, or other identifier associated with your interaction;
  • The state in which you reside;
  • The right you wish to exercise; and
  • Sufficient information to help us locate the relevant records.

A. Verification

We may take reasonable steps to verify your identity and authority before completing a request. Verification measures will be proportionate to the nature of the request and sensitivity of the information.

We will not require you to create an account solely to exercise a privacy right. We will use information submitted for verification only to verify and process the request, prevent fraud, maintain required records, and comply with law.

If we cannot reasonably verify your identity, we may deny or limit the request and explain the reason.

B. Authorized Agents

You may authorize another person to submit an opt-out request or another legally permitted privacy request on your behalf. We may require evidence of the agent's authority and may ask you to verify your identity directly.

C. Response Timing

We will respond within the period required by applicable law. Under the Colorado Privacy Act, this is ordinarily 45 days after receipt of a verifiable request. We may extend the response period once when reasonably necessary, in which case we will provide notice and explain the reason for the extension.

D. Appeals

If we decline to act on your request, you may appeal by emailing support@powderday.net with "Privacy Request Appeal" in the subject line, or by mailing an appeal to the address above and marking it "Privacy Request Appeal."

Please identify the original request and explain why you believe the decision should be reconsidered.

We will respond to an appeal within the period required by applicable law. If an appeal is denied, we will provide information about how to contact the Colorado Attorney General.

13. Universal Opt-Out Mechanisms

Where required by Colorado law, PowderDay recognizes qualifying universal opt-out mechanisms, such as browser or device signals that communicate a consumer's choice to opt out of the sale of personal data or targeted advertising.

When we detect a legally recognized signal, we will process it as required for the browser or device from which the signal is received and, when we can reasonably associate the signal with a known consumer profile, for the associated profile.

Because these signals operate through a particular browser or device, you may need to enable the signal separately on each browser or device you use.

PowderDay does not respond to browser "Do Not Track" signals that are not recognized as legally binding universal opt-out mechanisms.

14. Children and Minors

The Services are intended for adults and are not directed to children under 13. PowderDay does not knowingly collect personal information from a child under 13 without verifiable parental consent.

PowderDay also does not knowingly use or willfully disregard information indicating that a consumer is a minor when providing an online service, product, or feature that creates a heightened risk of harm to minors.

We do not knowingly:

  • Sell the personal data of a child or minor in violation of applicable law;
  • Use a minor's personal data for targeted advertising without legally required consent;
  • Use manipulative design features to encourage minors to provide unnecessary personal information; or
  • Retain a minor's personal information longer than reasonably necessary for the disclosed purpose.

If you believe a child or minor has submitted personal information in violation of this section, contact us immediately using the information in Section 23.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

  • Process and document requests;
  • Route and verify consumer requests;
  • Provide requested services;
  • Maintain consent and suppression records;
  • Measure campaign performance;
  • Meet contractual obligations;
  • Detect fraud and secure the Services;
  • Resolve disputes;
  • Enforce agreements; and
  • Satisfy legal, tax, accounting, regulatory, and reporting requirements.

Retention periods vary depending on the nature of the information, the campaign, legal obligations, contractual requirements, the sensitivity of the information, and the risks associated with continued retention.

When personal information is no longer reasonably necessary, we will delete it, deidentify it, aggregate it, or otherwise dispose of it in accordance with applicable law and our retention procedures.

We may retain records of privacy choices, consent, revocation, and suppression requests for as long as reasonably necessary to demonstrate compliance and ensure that a consumer's preferences continue to be honored.

Notwithstanding the general retention approach described above, PowderDay retains records of consent to telephone and text-message contact, including the consent language displayed, for a minimum of five years from the date consent was obtained.

16. Data Security

PowderDay uses reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, acquisition, destruction, use, modification, or disclosure.

These safeguards may include:

  • Access restrictions;
  • Authentication controls;
  • Encryption where appropriate;
  • Vendor-management procedures;
  • Security monitoring;
  • Incident-response procedures;
  • Employee and contractor confidentiality requirements; and
  • Periodic review of security practices.

No website, system, network, transmission method, or storage system is completely secure. We therefore cannot guarantee the absolute security of personal information.

You are responsible for using reasonable precautions when communicating with us and for protecting passwords, devices, and accounts under your control.

17. Data Breach Notification

If we discover a security breach involving personal information, we will investigate and provide notices to affected individuals, regulators, consumer-reporting agencies, or other parties when required by applicable law.

18. Deidentified and Aggregated Information

We may create or use information that has been aggregated or deidentified so that it cannot reasonably be linked to an identified or identifiable individual.

When we maintain information as deidentified data, we will take reasonable measures to ensure that it cannot be associated with an individual, publicly commit to maintaining and using it in deidentified form, and not attempt to reidentify it except as permitted by law.

We may use and disclose aggregated or deidentified information for lawful purposes.

19. Third-Party Websites and Services

The Services may link to websites, applications, advertisements, or services controlled by third parties.

PowderDay does not control and is not responsible for the privacy, security, content, or business practices of third parties. A link or referral does not constitute an endorsement of the third party's privacy practices.

You should review the privacy policy and terms of each third-party service before providing personal information.

20. Business Clients and Advertisers

PowderDay may process personal information on behalf of a business client under the client's instructions. In those circumstances, the client may be the party responsible for responding to a privacy request.

PowderDay's agreements with clients and participating businesses may require them to:

  • Use consumer information only for disclosed and authorized purposes;
  • Comply with applicable privacy, advertising, telemarketing, and consumer-protection laws;
  • Maintain reasonable security safeguards;
  • Honor applicable consumer opt-outs and revocations;
  • Refrain from making unauthorized onward disclosures; and
  • Delete or return information when contractually or legally required.

Consumers should also review the privacy notices of the businesses to which they submit a request or are connected.

21. International Users

PowderDay is based in the United States, and the Services are directed principally to users located in the United States.

If you access the Services from another country, your information may be transferred to, stored in, and processed in the United States, where privacy laws may differ from those in your jurisdiction.

22. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, Services, legal requirements, or business operations.

When we make changes, we will post the revised Privacy Policy and update the "Last Updated" date. If required by law, we will provide additional notice or obtain consent before materially different processing begins.

Your continued use of the Services after an updated Privacy Policy becomes effective signifies acknowledgment of the revised policy, but does not constitute consent where affirmative consent is legally required.

23. Contact Us

Questions, concerns, complaints, and privacy requests may be directed to:

PowderDay LLC
Attn: Privacy
6834 South University Boulevard, #102
Centennial, Colorado 80122

Email: support@powderday.net
Phone: 866-284-3532

For telephone-call or text-message opt-outs, you may also use the opt-out instructions contained in the applicable communication.