Privacy Policy.

Last updated: November 11, 2026

1. Who This Policy Covers

This Privacy Policy applies to Xy7Elite.com, Elite-Calls.com, and any website that links to it (collectively, the "Sites"). It covers two groups of people:

• Consumers who submit information through a form or place a call through one of our tracking numbers or campaigns
• Business users, publishers, advertisers, and partners who apply for or maintain accounts on our pay-per-call network platform

Elite-Calls.com is operated by Rapid Response Marketing, LLC ("RRM," "we," "us," or "our"), a U.S.-based company.

2. Summary

We are a marketing company. Our business is connecting consumers who are actively seeking products or services, such as insurance quotes, home services, or benefits information, with the companies that provide them. That means: if you submit a form or place a call through one of our campaigns, we share your information with the companies you asked to hear from, and with a limited number of service providers who help us deliver and verify that connection.

You can opt out of non-essential cookies, request access to your data, ask us to delete it, or opt out of the sale or sharing of your personal information at any time (see Do Not Sell My Info).

3. Personal Information We Collect

Identifiers and contact information:

• Name, email address, phone number, mailing address
• Account registration details and company name

Business account information (publishers/advertisers):

• Publisher/advertiser application information: traffic sources, business details, tax information
• Payment information: bank account or payment details for commission payouts (processed by our payment processor; we do not store full financial account numbers)

Commercial and transactional information:

• Transaction records, campaign performance data
• Communications: emails, support tickets, offer requests submitted through our website

Internet and network activity:

• Device and browser information: browser type, operating system, screen resolution
• Usage data: pages visited, time spent, referring URLs, click patterns
• IP address and approximate geographic location
• Cookies and similar tracking technologies (see our Cookie Policy)

Audio information:

• Call recordings, where disclosed at the start of the call (see Section 6 below)

Consent and compliance records:

• Records of consent provided (e.g., TCPA consent, opt-in timestamps, consent language presented)

Sensitive personal information:

• For campaigns related to Medicare, ACA health insurance, or disability benefits, consumers may provide health-insurance or benefits-related details. We use this information solely to connect consumers with the services they requested and do not use it for any unrelated purpose.

We do not collect government-issued identification numbers, financial account numbers, or precise geolocation data from consumers.

4. Where We Get It

• Directly from you: When you submit a form, place a call, register an account, or contact us
• From publishers and traffic partners: Who are contractually required to obtain proper consent before transmitting consumer information to us
• Automatically: Through cookies, pixels, server logs, and call-tracking technology when you interact with our Sites
• From verification and compliance vendors: Identity verification, phone validation, and fraud detection services

5. How We Use Personal Information

• To connect consumers with the products or services they requested
• To verify the legitimacy and quality of each consumer inquiry
• To monitor call quality and compliance
• To operate, maintain, and improve our Sites and network platform
• To process publisher and advertiser applications
• To calculate and pay commissions accurately
• To respond to your questions, requests, and support tickets
• To detect and prevent fraud, invalid traffic, and policy violations
• To comply with legal obligations, including telemarketing recordkeeping requirements

We do not engage in automated decision-making that produces legal or similarly significant effects, and we do not use consumer data to train artificial intelligence or machine learning models.

6. Call Recording and Monitoring

Calls placed through our tracking numbers may be recorded and monitored for quality assurance, compliance verification, and dispute resolution. You will be notified at the beginning of a recorded call, and you may decline to be recorded by ending the call.

Call recordings are treated as confidential and are accessible only to personnel with a legitimate business need. Call recordings are not sold. They may be shared with the advertiser who received the call and with service providers who assist with call routing, quality monitoring, and compliance, subject to contractual restrictions.

7. How We Share Personal Information

When a consumer submits a form or places a call through one of our campaigns, we transmit that consumer's information to the company (buyer/advertiser) the consumer asked to hear from. Under certain state privacy laws, including the California Consumer Privacy Act, this transmission constitutes a "sale" or "sharing" of personal information. You may opt out, see How To Exercise Your Rights.

We may also disclose personal information in the following circumstances:

• With service providers: Companies that help us operate our platform under contractual restrictions, including hosting providers, call routing and recording platforms (e.g., TrackDrive), affiliate tracking and attribution platforms (e.g., Everflow), phone validation and DNC scrubbing services, lead verification vendors, payment processors, and analytics services. These providers may only use personal information to perform services on our behalf.
• With publishers (limited): We share limited reconciliation data with publishers for commission calculation purposes. We do not share call recordings or transcripts with publishers.
• For legal reasons: When required by law, court order, subpoena, or government request, or to protect our rights, safety, or property
• In corporate transactions: In connection with a merger, acquisition, sale of assets, or bankruptcy proceeding

We do not disclose personal information to third parties for their own independent marketing purposes except as described above (transmitting consumer leads to the companies consumers asked to hear from).

7.1 Categories, Sources and Recipients

In the last 12 months we have collected the categories of personal information below. For each one, the table shows where it comes from and to whom we may sell, share or disclose it. We collect, use, sell and share them for the purposes in sections 5 and 7.

8. Cookies and Tracking

We use cookies, pixels, and web beacons for site operation, performance measurement, and marketing attribution. For detailed information about the types of cookies we use and how to manage them, see our Cookie Policy. We honor Global Privacy Control (GPC) browser signals as a valid opt-out of non-essential tracking.

On this website: the pages of www.elite-calls.com do not load analytics or advertising tags. The fonts, images and video are served from this website, except the BBB Accredited Business seal, which is loaded from bbb.org (seal-southernnevada.bbb.org); when your browser loads it, BBB receives the usual technical details of the request, such as your IP address and browser type, under BBB's own privacy policy. If you opt out on this website, or your browser sends a Global Privacy Control signal, we set a small cookie that records that choice, so that any advertising or analytics tags we add later are not loaded for you. Messages sent from the contact, question and privacy request forms are delivered to us through Formspree. Publisher applications from the qualification questionnaire, including any stats screenshots you upload, are stored on our server for review by our team. To recognize repeat applications we keep hashed values of the contact details, the IP address and a random identifier that the questionnaire stores in your browser. If an applicant lists you as a reference, we receive your company, name, email and phone from the applicant and email you a short reference check; your answers are stored with the application. The compliance intake keeps your answers in your browser as you type, so a closed tab does not lose them; the finished intake is stored on our server and emailed to our team. Opt-out requests sent from our Do Not Sell or Share My Personal Information page are stored on our server and emailed to our team.

9. Your Privacy Rights

Depending on where you live, you may have the right to:

• Know and access the personal information we have collected about you
• Delete your personal information
• Correct inaccurate personal information
• Opt out of the sale or sharing of your personal information
• Limit the use of sensitive personal information to purposes necessary to provide the service you requested
• Data portability, receive a copy of your data in a portable format
• Appeal a decision we make about your privacy request
• Non-discrimination, we will not discriminate against you for exercising your privacy rights

We may decline a request where a legal exemption applies, for example, where we are required to retain records for telemarketing compliance or to establish or defend legal claims. If we decline, we will explain why.

For a detailed breakdown of rights by state, see Your Rights.

10. How To Exercise Your Rights

You may submit a privacy request by any of the following methods:

• Email: privacy@xy7elite.com
• Company email: kevin@xy7elite.com
• Mail: Rapid Response Marketing, LLC, Attn: Privacy, 7500 W Lake Mead Blvd #9-463, Las Vegas, NV 89128
• Phone and text: 702-848-3954
• Opt out online: our Do Not Sell or Share My Personal Information page, no account or login needed
• Other requests online: the form on our Do Not Sell My Info section

To opt out of sale/sharing: Email privacy@xy7elite.com with the subject line "Do Not Sell or Share My Personal Information" and include the phone number and email address you used. You may also use our Do Not Sell or Share My Personal Information page, or enable Global Privacy Control (GPC) in your browser, which we treat as an opt out of sale and sharing for that browser. We act on opt-out requests as soon as we can and no later than 15 business days after we receive them.

To limit use of sensitive personal information: Email privacy@xy7elite.com with the subject line "Limit the Use of My Sensitive Personal Information."

Identity verification: We verify your identity by matching the phone number and email address you provide against our records. We will not ask for government identification.

Authorized agents: You may designate an authorized agent to submit requests on your behalf. The agent must provide written authorization signed by you. We may contact you directly to confirm the request.

Timing: We will acknowledge your request within 10 business days and provide a substantive response within 45 calendar days. If we need additional time, we will notify you and may extend by up to 45 additional days.

11. Telephone Contact, Consent, and Do Not Call

We and our partners may contact consumers by telephone or text message only where prior express written consent has been obtained, as required by the Telephone Consumer Protection Act (TCPA) and applicable state laws. We require our publishers to obtain this consent before transmitting any consumer inquiry to us.

How to revoke consent:

• Tell the person calling you that you wish to revoke your consent
• Reply STOP to any text message
• Email privacy@xy7elite.com with the subject line "Revoke Consent"

Do Not Call: We maintain an internal Do Not Call list and honor the National Do Not Call Registry. To add your number to our internal Do Not Call list, email privacy@xy7elite.com with the subject line "Do Not Call" and include the phone number(s) you want added.

12. Retention

We retain your personal information for as long as your account is active or as needed to provide services. After account closure or the end of a business relationship, we retain records for up to 7 years as required for tax, legal, and fraud prevention purposes. Consent and compliance records (such as TCPA consent records and call recordings) are retained as required by telemarketing recordkeeping laws. You may request deletion at any time (see Your Rights), subject to our legal retention obligations.

Server logs are kept for a short operational period. Opt-out and other privacy requests are kept for at least 24 months, as the law requires.

13. Security

We implement security measures including SSL/TLS encrypted transmission, multi-factor authentication, role-based access controls, company-managed devices for personnel who handle personal information, and an incident response plan. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

14. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected data from a person under 16, we will delete it promptly. We do not sell or share the personal information of consumers we know to be under 16 years of age.

15. Other Websites

Our Sites may contain links to websites operated by companies we do not control. This Privacy Policy does not apply to those websites, and we encourage you to review their privacy policies before providing any personal information.

16. Data Location

We are based in the United States and process personal information within the U.S. Some of our service providers and call center partners may be located outside the United States. Where this is the case, they are bound by contractual obligations to protect personal information in a manner consistent with this policy.

16.1 California Notices

California residents may ask, once a year and free of charge, for a list of the third parties to whom we disclosed personal information for their own direct marketing purposes in the past year, by emailing privacy@xy7elite.com.

Under California Civil Code Section 1789.3, California residents are entitled to the following consumer rights notice: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

17. Changes To This Policy

We may update this Privacy Policy periodically. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will provide notice on our Sites. We encourage you to review this policy regularly.

18. Contact Us

For privacy-related questions, requests, or complaints:

• Email: privacy@xy7elite.com
• Mail: RRM LLC, Attn: Privacy, 7500 W. Lake Mead Blvd. #9-463, Las Vegas, NV 89128
• Phone: (702) 848-3954