Privacy policy
This policy explains what data Lee Flannery Consulting LLC ("we") collects, how we use it, and the choices you have. It covers this website and the measurement services we provide to our clients.
This website
This site does not use cookies, analytics, or tracking pixels. If you email us, we keep your message and address to reply and to keep a record of our correspondence.
Services we provide to clients
We help businesses that run paid advertising measure which of their advertising produces real customers. To do that, a client may share records from its own systems with us, such as lead forms, order records, or customer relationship data. In that work:
- We act on the client's instructions. The client is the controller of its customers' data. We process it only to provide the service described in our agreement with that client.
- Only consented or transacted people are included. We send information to advertising platforms only about people who opted in to the client's marketing or completed a transaction with the client, according to a rule the client sets.
- Identifiers are hashed before they leave our systems. Names, email addresses, phone numbers, and postal addresses are normalized and hashed with SHA-256 before being sent to any advertising platform (Google, Meta, or Reddit). We do not send unhashed personal data to those platforms.
- What we send. Hashed identifiers, the type and time of a conversion event, its value and currency, and advertising click identifiers when the client captured them, so the platform can attribute the conversion to an ad.
- What we do not do. We do not sell personal data. We do not build profiles of people who never gave the client their contact information. We do not use client data to train machine learning models. We do not share one client's data with another.
- Access to advertising accounts is granted by the client through the platform's own partner or manager features. We never hold the client's passwords, and the client can revoke access at any time.
Where data lives and how long
Client data is stored in access-controlled systems in the United States, separated per client. We keep it for the duration of the engagement and for up to 90 days afterward unless the client asks for earlier deletion or the agreement says otherwise. Records of what was sent to advertising platforms are kept as hashed identifiers only.
Your rights
If you are a customer of one of our clients and want to access, correct, or delete information about you, contact that business; we will carry out its instructions. If you believe we hold information about you directly, or you have a question about this policy, email hello@leeflanneryconsulting.com. California residents may exercise their rights under the California Consumer Privacy Act by the same address. We do not discriminate against anyone for exercising their rights.
Advertising platforms
Data sent to Google, Meta, or Reddit on a client's behalf is then governed by those platforms' terms and privacy policies as well as the client's own policy. We use the platforms' official conversion and audience interfaces and comply with their customer data terms.
Changes
If this policy changes, the new version will be posted here with a new effective date.