Recovery Joint Controller Arrangement

The parties are the customer business that purchases a recovery and Jordan Boyce, sole trader, trading as Lead Reclaimer.

For the defined historical-lead recovery campaign only, the customer and Lead Reclaimer are joint controllers. The shared purpose is to re-contact the customer's own historical membership leads with one reviewed three-message email sequence during the agreed recovery, stop further contact on reply, bounce or opt-out, maintain suppression, and pass interested replies to the customer's team.

For purchases on or after October 15, 2026, the recovery lasts 30 calendar days, including weekends. Earlier purchases retain their agreed length, including 14 days where applicable. The October 15 update applies to service duration for new purchases. The responsibility allocation under this arrangement remains unchanged, and earlier purchases retain their agreed terms.

This arrangement does not make the parties general partners or agents of each other, and it does not make them joint controllers for any unrelated activity. The customer remains the sole controller of its source CRM or list before transfer to Lead Reclaimer and of its post-reply sales records. Lead Reclaimer remains the controller of its own account, billing, security, audit and service administration data.

Each party will comply with the data-protection, privacy and commercial email laws that apply to its responsibilities above, and will not ask the other to act unlawfully. Each party will provide the information within its responsibilities that people need to understand the recovery processing, and the essence of this arrangement is available to individuals on request and through the Privacy Notice.

Lead Reclaimer uses service providers to run the recovery. Smartlead is Lead Reclaimer's email-delivery processor for the existing app-password route. Customers do not buy or administer Smartlead and do not receive campaign, lead or billing access to it. The generally available connection supports eligible Google Workspace and Gmail mailboxes only, using a Google app password entered in Lead Reclaimer after onboarding verification, not a normal Google password. Each customer's isolated Smartlead workspace remains controlled by Lead Reclaimer and is never reused across customers.

The generally available connection still uses a Google app password with SMTP and IMAP through Smartlead. Google OAuth is limited to accounts where it is enabled; it is not generally available and is not represented as Google verified. Existing purchase compatibility checks and app-password requirements remain unchanged.

Where Google OAuth is enabled for your account, Google's permission flow connects the intended Google Workspace or Gmail mailbox. You must own or be authorized to connect and operate that mailbox. Lead Reclaimer does not request your normal Google password or a Google app password for this OAuth connection.

Gmail Direct OAuth tokens are not sent to Smartlead. Google-data use for enabled accounts is described in the Privacy Notice. This connection clarification does not change the responsibility allocation, retention periods, version or effective date of this arrangement.

Bouncer is the selected email-address verification provider. Lead Reclaimer submits email addresses only, not CSV filenames, local lead IDs, names, reply bodies or credentials, and receives address deliverability and safety results. Only addresses explicitly returned as safe and valid are eligible for scheduling; other eligibility and mailbox safety controls still apply. Provider agreements and transfer safeguards remain under verification; this arrangement does not assert that account-specific terms are signed.

Current providers and purposes are listed on the Subprocessors page.

Individuals can exercise their rights against either party. Lead Reclaimer is the practical contact for recovery records at hello@leadreclaimer.com. The sending business also remains reachable through its sending address.

If a party receives a request that concerns the other party's responsibilities, it will pass it on promptly and the parties will cooperate in good faith to respond within the time the law requires. This arrangement does not restrict a person's statutory rights against either controller.

Each party will maintain appropriate security for the systems and data within its responsibilities. The customer protects its mailbox, devices and account access. Lead Reclaimer protects its platform and provider configuration.

A party that becomes aware of a personal data breach affecting recovery data will tell the other without undue delay, share the information reasonably available, and cooperate on investigation, mitigation and any required notice to regulators or individuals.

• Lead Reclaimer requests deletion of Bouncer's submitted addresses and verification results after checks. Failed cleanup is retried, and unresolved submissions or cleanup block account erasure. This does not promise immediate deletion of provider logs, backups or metadata.
• Raw completed-import files are deleted after 30 days, or earlier after a verified deletion request when safety gates permit.
• Recovery message, reply and normalized lead content is reviewed 90 days after the campaign ends and deleted or minimized when there is no active follow-up, dispute, security or legal need.
• Smartlead workspaces are stopped at campaign end and deleted after final events, suppressions and open rights requests are reconciled. They are never reused.
• Minimum per-customer suppression data may be retained to prevent future contact. Payment, tax, security, audit and acceptance evidence may remain for applicable legal or dispute periods.
• Deleted application data can remain recoverable within a provider's limited backup and restore window. After any restore, verified deletion and suppression must be reapplied before service use resumes.

Lead Reclaimer does not promise physical deletion of copies outside its control, including immediate deletion from provider backups.

Lead Reclaimer may update this arrangement for legal, security or service changes. The current version and effective date will be posted here.

Future model, not currently in effect: a model in which the customer is the sole controller and Lead Reclaimer acts as its processor may be adopted in future. It would apply only under a new data processing addendum, documented customer instructions, notice and new acceptance. It does not apply to recoveries today.

The customer accepts this arrangement when it accepts the Terms of Service and starts a recovery. Questions may be sent to hello@leadreclaimer.com.