Consent and compliance
Consent is captured at acquisition, because it cannot be reconstructed afterward. We generate the demand ourselves, so the disclosure language, the timestamp, the IP, and the page are ours to store and ours to produce.
Consent is captured at the form
Five things are stored with every lead, at the moment the prospect submits it.
- The exact disclosure language. The words on the screen when the prospect submitted the form, stored with the record. Campaign copy changes over time, so the version that was live at that moment is what we keep.
- The timestamp. When the submission happened, recorded at the point of capture rather than reconstructed from a delivery log later.
- The IP address. Captured at submission and stored with the lead.
- The page. Which landing page and which campaign produced the record, because we own both and can say so without asking anyone.
- Retrievable on request. Ask for a specific lead and we produce its record. Nothing in that chain requires a third party to cooperate.
This page is not legal advice
It describes how our acquisition process works so you can evaluate it. It is not a legal opinion, it is not a compliance review of your operation, and it does not create any safe harbor for either of us. We hold no compliance certification and claim none. Ask your own counsel what your dialing program requires before you rely on anything written here.
Why consent cannot be reconstructed later
The record either exists from the moment of capture, or it does not exist.
Consent is a snapshot of one moment: a specific person, on a specific page, reading specific words, and choosing to submit. Everything that makes it meaningful is tied to that moment, which is why it has to be captured there.
When a lead has changed hands twice before it reaches you, that snapshot usually has not traveled with it. What arrives instead is an assurance. The current seller believes the previous seller collected consent, the previous seller believes the original publisher did, and the original publisher may be a network that has since changed its landing pages. None of that is retrievable when a specific record is questioned, because there is no longer one party who was present when the form was submitted.
Under the TCPA, the practical question when a complaint arrives is what a particular consumer was actually shown and actually agreed to, on a particular day. That is a question about evidence. A chain of vendor assurances is not evidence, and contractual language does not convert it into evidence. This is the concrete reason we generate demand in house instead of buying it: not because owned campaigns are cheaper, but because the seller and the collector being the same company is the only arrangement where the record can be produced.
None of this removes your own obligations, and none of it is a legal conclusion about your program. It removes one specific gap: the one where nobody can say what the prospect saw.
Suppression, opt-outs, and do-not-call
Applied before delivery, and honored afterward.
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1
Before a lead is generated
Our campaigns carry the disclosure the prospect reads before they submit. We write that copy ourselves, so there is no upstream partner who decided what the offer said and no ambiguity about what was disclosed.
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2
Before a lead is delivered
Internal suppression, prior opt-out state, and do-not-call handling run in the same pre-delivery pass as phone validation and duplicate suppression. A suppressed record does not get sent, which is a materially different thing from sending it and asking you not to call.
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3
After delivery
Opt-outs that arrive later are honored going forward, across programs rather than in the one campaign they came from. If a prospect asks you to stop contacting them, send it to us and we apply it on our side as well so the same person does not reappear through another program.
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4
When a question arrives
We produce the record for the lead in question: the disclosure text, the timestamp, the IP, the page, and the suppression state at the time of delivery. What you do with it, and how you respond, is a conversation with your own counsel.
What we produce if a complaint arrives
Ask by lead, and this is what comes back.
| The lead record | The submitted fields as they were captured, with the program and vertical the record belonged to. |
|---|---|
| The consent snapshot | The disclosure language displayed at submission, held as it appeared rather than as a reference to a current template. |
| Submission metadata | Timestamp and IP address recorded at capture, plus the page and campaign that produced the form fill. |
| Delivery detail | When the record was delivered to you, by which path, and whether your endpoint accepted it. |
| Suppression state | The suppression and opt-out checks applied before delivery, and any opt-out recorded afterward. |
Retention
Consent and delivery records are retained on a defined schedule set to outlive the window in which a complaint would realistically arrive, and the specific period is stated in your program terms rather than improvised when you ask for it. Records are produced for the buyer the lead was sold to. We do not publish another buyer's records to you, and we do not publish yours to anyone else.
What stays yours
We handle acquisition. The phone call is your operation, and so is the responsibility for how it runs.
- Your dialing practices, including calling hours, frequency, and abandonment behavior on any dialer you run.
- Your scripts and what your agents say once a call connects, including disclosures your carriers or CMS require of you.
- Your state registrations, licensing, and any filings your operation is required to maintain.
- Your own internal do-not-call list and the process that keeps it current.
- Your relationship with your own counsel, who should read your program terms before you sign them.
Where to go next
The mechanics of how records reach you, including retries and delivery confirmation, are on the delivery page. What exclusivity means and why it is possible at all is on the exclusivity page. How data is handled on our side is covered under security.
Once more, plainly
Nothing on this page is legal advice, and nothing on it claims a certification, an audit, or a safe harbor. It is a description of a process, written so you can ask hard questions about it. Bring those questions and we will answer them specifically, including the ones where the honest answer is that the obligation is yours.
FAQs
Consent questions
What exactly is stored with each lead?
The disclosure language the prospect actually saw, the timestamp of the submission, the IP address it came from, and the page it was submitted on, stored alongside the lead record itself. Not a description of the consent language, and not a template we keep on file somewhere. The words on the screen at that moment.
Can I get the consent record for a specific lead?
Yes. Ask for the record by lead and we produce what we captured. That is the practical reason to buy from the company that ran the campaign: the evidence exists because we were the ones who collected it, not because we asked an upstream vendor to vouch for it.
Does buying these leads make my dialing TCPA compliant?
No, and anyone who tells you otherwise is selling something. We handle the acquisition side: the disclosure, the consent capture, the record, and the suppression we apply before delivery. Your dialing practices, your calling hours, your scripts, your state registrations, and your own internal do-not-call process remain yours. This page is not legal advice.
How do you handle do-not-call and opt-outs?
Federal and state do-not-call handling and our internal suppression list are applied before a lead is delivered, so a suppressed record does not reach you in the first place. When someone opts out after the fact, the suppression is applied going forward across programs. If a prospect you bought asks you to stop calling, tell us and it is suppressed on our side too.
How long are records kept?
Consent records are retained on a defined schedule that is stated in your program terms and set to outlive the window in which a complaint would realistically arrive. Retention is a policy we can show you rather than a number we improvise when you ask.
Do you hold any compliance certification?
We do not claim one, and we will not imply one. There is no audit certificate, no safe harbor, and no seal behind anything on this page. What we have is a described process, records we can produce, and the ability to tell you exactly where a lead came from because we generated it.
Something else? Contact us
Ask us for a consent record before you buy.
It is a fair test of any lead seller, and it is the one question an aggregated record usually cannot survive.