Data Handling Statement

LeadLocker is a business name of Red Capital Group Pty Ltd (ABN 41 696 755 530).

Last updated: 6 July 2026

Overview

This Data Handling Statement describes how LeadLocker processes personal information, which third-party services receive data and for what purpose, and where data is stored. It is intended to provide transparency for account holders, their customers (leads), and third parties such as Meta who review our data practices.

This statement should be read alongside our Privacy Policy and Terms of Service.

Data flows

Inbound lead sources

LeadLocker receives lead data from the following sources, depending on which integrations you have configured:

SourceData received
Meta Facebook/Instagram Lead AdsLead name, email, phone, custom question responses, Page ID, Page access token
Inbound email (via Mailgun)Full email: From, To, Subject, message body (text and HTML), headers
Inbound SMS (via Telnyx)Sender phone number, SMS message body
Inbound voice calls (via Telnyx)Caller phone number, call duration, call recording, call transcript
Google Ads lead form webhookLead name, phone, comments
Public lead formLead name, email, phone, description
Custom webhookName, email, phone, description (as submitted by the integrating system)

All inbound lead data is stored in Firebase Firestore, located in australia-southeast1 (Sydney, Australia).

Third-party subprocessors

LeadLocker engages the following third-party service providers to deliver the service. Each provider acts as a data processor under our instructions, except where noted. Operational logs are currently handled by Vercel only; we do not use Better Stack or Upstash in production today.

Google Firebase (Google LLC)

  • Purpose: Primary data store for all account data, lead data, conversations, call transcripts, attachments, and authentication
  • Data processed: Account details (email, name, hashed password), lead data (names, emails, phones, message content, call transcripts, attachments, quote data), organisation metadata, push notification tokens, Facebook Page tokens
  • Storage location: australia-southeast1 (Sydney, Australia) — Firestore and Firebase Storage
  • Authentication location: Google Identity Platform (global Google infrastructure)
  • Own use: Google processes data as cloud infrastructure under Google Cloud's data processing terms. Google does not use Firestore content to train public AI models.
  • Privacy policy: policies.google.com/privacy
  • Data processing terms: firebase.google.com/terms/data-processing-terms

Vercel Inc.

  • Purpose: Application hosting and serverless API processing
  • Data processed: All data passes through Vercel's servers in transit during API request processing (lead data, webhook payloads, account data). Vercel retains structured operational logs per their log retention policy.
  • Storage location: Washington DC, USA (iad1) — data is processed transiently; not stored long-term on Vercel
  • Own use: Vercel uses data only to host and operate the application per their DPA
  • Privacy policy: vercel.com/legal/privacy-policy

OpenAI (OpenAI, LLC)

  • Purpose: AI-powered lead classification, lead scoring, and call transcript analysis
  • Data processed:
    • Lead classification: lead subject, sender, and up to 600 characters of message body
    • Lead scoring: lead subject, sender, and up to 1,500 characters of message body
    • Transcript analysis: full call transcript text
  • Triggered by: Inbound email leads, Facebook/Instagram Lead Ads leads, and completed voice calls
  • Storage location: United States
  • Own use: Under OpenAI's API data usage policy, data submitted via the API is not used to train OpenAI's models by default. LeadLocker stores only the parsed output (classification result, score, suggestions) — not raw OpenAI responses.
  • API data policy: openai.com/policies/api-data-usage-policies

Telnyx LLC

  • Purpose: Inbound and outbound SMS, inbound voice calls, call transcription
  • Data processed: Phone numbers (E.164 format), SMS message content (including lead name snippets and job details), call metadata (from/to numbers, duration, call outcome), call transcripts delivered via webhook
  • Storage location: United States — Telnyx retains call and message records per carrier regulatory requirements and their data retention policy
  • Own use: Carrier/CPaaS processing for routing, billing, fraud prevention, and regulatory compliance
  • Privacy policy: telnyx.com/privacy-policy

Mailgun (Sinch)

  • Purpose: Inbound email processing — forwarding emails sent to your LeadLocker inbox to the LeadLocker API
  • Data processed: Full inbound email content (From, To, Subject, body text and HTML, headers)
  • Storage location: United States
  • Own use: Email delivery and processing per Mailgun's terms. LeadLocker does not retain raw Mailgun payloads beyond what is extracted into Firestore.
  • Privacy policy: mailgun.com/privacy-policy

Resend (Resend Inc.)

  • Purpose: Transactional email delivery (account onboarding, setup links, quote delivery)
  • Data processed: Recipient email address, recipient name, email content (onboarding links, quote details including lead name and quote total)
  • Storage location: United States
  • Own use: Transactional email delivery only per Resend's terms
  • Privacy policy: resend.com/legal/privacy-policy

Meta Platforms Inc. (Facebook/Instagram)

  • Purpose: OAuth authentication for Page connections, Lead Ads webhook delivery, Graph API for lead retrieval and page subscription
  • Data processed: Page access tokens, Lead Ads form submissions (name, email, phone, custom question responses), Page and Instagram business account metadata
  • Storage location: Global (Meta infrastructure, primarily United States)
  • Own use: Meta processes data per Meta's Platform Terms and data policies. LeadLocker uses Page tokens only to receive leads and maintain the connection — not for advertising.
  • Platform terms: developers.facebook.com/terms
  • Privacy policy: facebook.com/privacy/policy

Stripe (Stripe Payments Australia Pty Ltd)

  • Purpose: Payment processing and subscription management
  • Data processed: Customer email address, subscription plan and status, Stripe customer ID, Stripe subscription ID. LeadLocker does not store or access card numbers — payment details are handled entirely by Stripe's hosted checkout.
  • Storage location: Australia/Global (Stripe Australia entity)
  • Own use: Payment processing, fraud prevention, and financial compliance per Stripe's terms
  • Privacy policy: stripe.com/privacy

Data LeadLocker does not use

Facebook Lead Ads data handling

LeadLocker receives lead data from Meta Lead Ads via the Facebook Graph API and webhook subscriptions. This data is:

End consumer deletion requests: if an individual whose information was collected via a Facebook Lead Ad wishes to have their information deleted from LeadLocker's systems, they may contact us at support@leadlocker.app. We will process deletion requests within 30 days.

Account holder deletion: when you disconnect your Facebook Page or delete your LeadLocker account, your Page access tokens are permanently deleted from our systems. Lead data associated with your account is deleted in accordance with our account deletion process.

Data security

We implement the following technical measures to protect data:

Data retention and deletion

Data typeRetentionDeletion
Account dataDuration of accountDeleted on account deletion
Lead dataDuration of account, or until manually deletedDeleted on lead deletion or account deletion
Call transcriptsDuration of accountDeleted on account deletion
AttachmentsDuration of accountDeleted on account deletion
Facebook Page tokensUntil Page disconnected or account deletedPermanently deleted on disconnection or account deletion
BackupsUp to 30 days after account deletionPurged within 30 days of account deletion
Stripe billing recordsPer Stripe's retention requirementsManaged by Stripe

International data transfers

Your primary data is stored in Australia (Firebase, Sydney — australia-southeast1). Some service providers process data in the United States (Vercel, OpenAI, Telnyx, Mailgun, Resend, Meta). When data is transferred outside Australia, we engage only providers with appropriate data protection practices and contractual terms. For more information, see the subprocessor list above.

Contact

For data handling enquiries or to submit a deletion request:

Email: support@leadlocker.app

Business: LeadLocker, operated by Red Capital Group Pty Ltd (ABN 41 696 755 530)

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