PROCURE MEDIA, LLC
PRIVACY POLICY
Effective Date: July 7, 2026 • Version 1.0
1.1 Scope. This Privacy Policy explains how Procure Media, LLC (“Procure,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with walterspeaking.com, signup.walterspeaking.com, and the related services (collectively, the “Services”). It applies to our business customers, website visitors, prospective customers, and the consumers who submit information through our advertising and landing pages.
1.2 Business Context. Procure provides a business-to-business platform and lead-generation and lead-distribution services. This policy describes our own information practices. Information practices for specific consumer-facing lead-generation websites we operate may be described in separate notices posted on those websites.
1.3 United States Only. The Services are intended only for businesses and users in the United States. We do not target or direct the Services to users outside the United States, and information is processed in the United States.
2.1 Categories of Information. Depending on how you interact with the Services, we may collect the following categories of information:
Identifiers — such as name, username, and account identifiers.
Contact information — such as email address, telephone number, and business mailing address.
Commercial information — such as products or services purchased, Leads purchased, and transaction history.
Internet or network activity — such as pages viewed, referring pages, and interactions with our sites and emails.
Device information — such as IP address, browser type, operating system, and device identifiers.
Geolocation — coarse location derived from IP address.
Communications — the content and metadata of calls, texts, emails, and support requests.
Payment information — billing details processed by our payment processors (we do not store full card numbers).
Professional or business information — such as company name, role, and industry.
2.2 Information You Provide. We collect information you provide when you sign up, place an order, contact us, or otherwise use the Services.
2.3 Information Collected Automatically. When you visit our sites, we automatically collect device and usage information using cookies and similar technologies, as described in Section 4.
2.4 How We Generate and Obtain Leads. We generate prospective-customer (“Lead”) information primarily through our own advertising and landing pages: we acquire advertising traffic from advertising platforms (for example, Google and Meta) and direct it to our landing pages, where consumers voluntarily submit information such as their name and contact details. We do not resell Leads to third parties, and we may also obtain Lead information from business partners, affiliates, publishers, or other lawful sources consistent with applicable law.
2.5 Communications. If you call, text, or email us, we may record and retain those communications as permitted by law, including through third-party telephony and email providers.
2.6 Please Do Not Send Sensitive Information. Please do not submit sensitive personal information (such as Social Security numbers, financial account numbers, or health information) through the Services unless we specifically request it.
We use information to: provide, operate, and improve the Services; create and manage accounts; process payments and billing; generate and deliver Leads and related services; communicate with you (including service, transactional, billing, and — where permitted — marketing messages); provide support; measure and improve marketing and site performance; ensure security and prevent fraud and abuse; and comply with legal obligations and enforce our agreements.
We and our providers use cookies, pixels, tags, and similar technologies, including:
Strictly necessary / security cookies — to operate the sites, enable sign-in, and protect against fraud.
Preference cookies — to remember your settings.
Analytics cookies — to understand site usage and performance (for example, Google Analytics).
Advertising cookies — to measure and deliver advertising and remarketing (for example, Google Ads and the Meta pixel).
Session and persistent cookies — session cookies expire when you close your browser; persistent cookies remain until they expire or are deleted.
4.1 Analytics. We use analytics services such as Google Analytics, which use cookies and collect IP address and usage information to help us understand how our sites are used. You can learn about Google’s practices and opt-out options at Google’s policies pages.
4.2 Your Cookie Choices. You can control cookies through your browser settings and opt out of certain advertising cookies through industry tools such as the Digital Advertising Alliance or Network Advertising Initiative opt-out pages. See Section 6 for California “sale/share” choices, including Global Privacy Control.
5.1 Service Providers. We share information with vendors that perform services for us, who are permitted to use it only to provide those services. These include providers of cloud hosting and infrastructure (Cloudflare); analytics and advertising (Google and Meta); payment processing (Stripe and NMI); telephony and messaging (Twilio); email delivery (Zoho / ZeptoMail); voice and automated-assistant technologies (Amazon Web Services and ElevenLabs); and scheduling (Cal.com).
5.2 Lead Distribution. As part of the lead-generation and distribution Services, Lead information a consumer submits on our landing pages is shared only with the business(es) designated to receive that Lead pursuant to the applicable campaign. Once a Lead is delivered to a business customer, that customer independently determines how it uses the information and is independently responsible for its own privacy practices and legal compliance.
5.3 Advertising Partners. We share limited information with advertising and analytics partners to measure and deliver advertising, as described in Section 4 and subject to the choices in Section 6.
5.4 Legal and Safety. We may disclose information to comply with law, respond to lawful requests and legal process, enforce our agreements, or protect the rights, property, or safety of Procure, our customers, or others.
5.5 Business Transfers. We may disclose or transfer information in connection with a merger, acquisition, financing, or sale of assets.
6.1 California and Similar Laws. We do not sell your personal information in exchange for money. However, under the California Consumer Privacy Act / California Privacy Rights Act and similar state laws, our use of advertising and analytics technologies (such as Google Ads and the Meta pixel) may be considered a “sale” or a “sharing” of personal information for cross-context behavioral advertising.
6.2 Your Opt-Out. To opt out of any such “sale” or “sharing,” you may: (a) use an opt-out preference signal such as Global Privacy Control (GPC), which we honor as required by law; (b) adjust your cookie choices in your browser; or (c) email us at dan@procuremedia.com with the subject “Do Not Sell or Share My Personal Information.”
Certain support, routing, analytics, lead-handling, or communications functions may be assisted by automated technologies or artificial intelligence. We remain responsible for the Services provided, and human review is applied where appropriate.
8.1 Consent and Opt-Out. If you opt in to text messages, message and data rates may apply and message frequency varies. You can reply STOP to opt out or HELP for help at any time.
8.2 Mobile Data Not Sold or Shared for Marketing. No mobile information (including text-messaging opt-in and consent) will be sold or shared with third parties or affiliates for their marketing or promotional purposes. Mobile information may be shared with subcontractors in support services (such as customer service) solely to provide the messaging service. All other categories of information sharing exclude text-messaging originator opt-in data and consent.
We retain information for as long as needed to provide the Services and for legitimate business and legal purposes, including: maintaining accounts; billing and financial records; support history; legal, tax, and regulatory compliance; fraud prevention and security; and disaster-recovery backups. Retention periods vary by record type and legal requirement; we delete or de-identify information when it is no longer needed.
10.1 Security. We use reasonable administrative, technical, and physical safeguards designed to protect information, which may include encryption where appropriate, access controls, authentication, and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10.2 Breach Notification. In the event of a security incident involving personal information, Procure will provide notifications required by applicable law.
11.1 Rights. Depending on your state of residence (for example, under the laws of California, Colorado, Virginia, and other states), you may have rights to access, correct, delete, or receive a portable copy of your personal information, and to opt out of the “sale” or “sharing” of personal information and of certain profiling.
11.2 How to Exercise. To exercise a right, contact us at dan@procuremedia.com. We will respond within the timeframe required by applicable law (generally within 45 days, with an extension where permitted). We will not discriminate against you for exercising your rights.
11.3 Verification. We may need to verify your identity before fulfilling a request, and, where an authorized agent submits a request on your behalf, we may require proof of authorization and verification of your identity.
11.4 Appeals. Where required by law, if we decline your request you may appeal by contacting us at dan@procuremedia.com.
11.5 No Financial Incentive. Procure does not offer financial incentives in exchange for the collection, sale, or sharing of personal information.
12.1 Children. The Services are for businesses and are not directed to children. We do not knowingly collect personal information from children under 13, and we do not knowingly sell or share the personal information of consumers under 16.
12.2 Third-Party Links. Our sites may link to third-party sites we do not control; their privacy practices are their own.
12.3 Changes. We may update this Privacy Policy from time to time and will revise the “Last Updated” date. Material changes will be indicated as required by law.
Procure Media, LLC
9169 W State St #1371, Garden City, ID 83714
dan@procuremedia.com