Last revised: June 1, 2026

This Privacy Policy (“Policy”) explains how No Good Marketing LLC, a South Dakota limited liability company (“NGM,” “we,” “us” or “our”), handles personal information. Contact [email protected] with privacy questions.

Overview (read first)

NGM platform and separate services. NGM primarily provides SaaS subscriptions to its CRM and business-automation platform, using third-party software, hosting, communications, payments, security, and related technology (“Third-Party Providers,” including underlying platform providers and relevant subprocessors).

NGM processes information to provide platform subscriptions and any separately purchased professional services. Integration, configuration, automation, migration and other implementation work requires a separately accepted scope and fee and is never included in a platform subscription.

NGM may engage, replace, or add Third-Party Providers. NGM presents the Services under its own brand. Specific providers may be identified in applicable service terms, privacy or data-processing disclosures, and security information. Detailed non-public technical or security materials may be subject to reasonable confidentiality terms. This naming convention does not limit disclosures required by applicable law or contract.

We do not sell personal information for money or use entrusted Customer Data for our independent advertising. See Section 6 for the broader legal meanings of “sale” and “sharing” and the controls required before optional tracking.

1. Who We Are; Scope of This Policy

1.1 Who we are. No Good Marketing LLC is a South Dakota limited liability company. This Policy describes how NGM handles personal information in connection with:

• NGM’s public websites, landing pages, and marketing materials;
• Client portals, account-administration tools, billing, and checkout;
• CRM / marketing-automation platform access, sub-accounts, wallets, and related online tooling offered by NGM; and
• Managed marketing, automation, communications, and related professional services NGM provides under its Terms and Conditions (“TOS”), Master Services Agreement (“MSA”) and applicable accepted Project Record. A standalone statement of work (“SOW”) is optional.

Together, these are the “Services.”

1.2 What this Policy covers. This Policy covers personal information (information that identifies, relates to, or could reasonably be linked to an individual or household) that NGM processes in connection with the Services.

1.3 What this Policy does not do. This Policy does not:

• Replace your own privacy notices to your end customers or contacts;
• Make NGM the controller of Client Customer Data merely because that data sits in a sub-account NGM administers (see Section 2);
• Replace the actual supplier disclosures in service terms or an accepted DPA; specific provider identities are disclosed where applicable or required; or
• Create warranties beyond those in the TOS, MSA, or SOW.

1.4 Related agreements. Use of the Services is also governed by the TOS, MSA and accepted Project Records that apply to you. If there is a conflict on commercial or liability terms, those agreements control; this Policy describes privacy practices.

2. Roles: Controller vs Service Provider / Processor

Understanding who decides how personal information is used is essential.

2.1 NGM as controller

NGM is the controller (the business that determines the purposes and means of processing) for personal information collected for NGM’s own operations, including:

• Website visitors and prospects who interact with NGM’s marketing sites and forms;
• Sales, demos, proposals, and relationship management for NGM’s own pipeline;
• Account registration, authentication, and account-admin contacts for customers buying from NGM;
• Billing, invoicing, payments, tax records, and collections related to fees owed to NGM;
• Security, fraud prevention, abuse detection, and legal compliance for NGM’s environment; and
• NGM’s own service improvement and (where permitted) marketing of NGM’s services.

2.2 NGM as service provider / processor

When a customer (“Client,” “Customer,” or “you”) uploads, imports, generates, or instructs NGM to process contacts, leads, messages, jobs, files, or other business records in a CRM/platform sub-account or related system administered under the Services (“Customer Data” or “Client Customer Data”), that data is the Client’s.

• NGM acts as a service provider / processor / custodian for Customer Data.
• NGM processes Customer Data to provide the Services, prevent abuse, and comply with law — not for NGM’s independent commercial purposes unrelated to the Services.
• NGM does not sell Customer Data.
• The Client is responsible for providing required notices and obtaining required consents from end customers, subscribers, and other individuals whose information the Client places in the Services (including TCPA, CAN-SPAM, consent, opt-out, call-recording, privacy, and advertising rules that apply to the Client’s outreach).
• End users who want to exercise privacy rights regarding data a Client holds about them should generally contact that Client. NGM will assist Clients as reasonably required by contract and law when a Client instructs NGM to help fulfill a verified request.

2.3 Third-Party Providers

Third-Party Providers may process personal information as independent controllers or as processors/subprocessors, depending on the product and the context. Their privacy terms apply to their platforms. NGM does not restate Third-Party Provider security attestations as NGM warranties (consistent with the TOS/MSA).

3. Information We Collect

The categories below depend on how you interact with NGM (website only, customer account, or managed services). We do not necessarily collect every category from every person.

3.1 When NGM is controller (NGM’s own business)

3.2 When NGM is service provider / processor (Customer Data)

Depending on what the Client configures and imports, Customer Data may include identifiers and contact information of the Client’s customers or leads; commercial or job records; message content (email, SMS, voice metadata/recordings where enabled); files and attachments; marketing engagement events; and similar CRM fields. NGM does not prescribe what Clients must store; Clients control the content of their sub-accounts subject to acceptable-use and law.

3.3 Sensitive personal information

NGM does not seek sensitive personal information (as defined under California and similar laws) for NGM’s own marketing. Clients should not place unnecessary sensitive data in the Services. If a Client instructs NGM to process such data, the Client remains responsible for lawful basis, notices, and consents.

Protected health information is excluded until a separately accepted health-data scope, applicable signed BAAs, required safeguards and verification of the relevant environment are complete. A paid feature or platform attestation alone does not authorize PHI processing. Applicable charges are separately agreed.

4. Sources of Information

We obtain personal information from:

1. You — forms, account registration, checkout, email, calls, meetings, and support.
2. Automatic collection — cookies, pixels, SDKs, logs, and similar technologies on NGM sites and portals (see Section 7).
3. Clients — Customer Data Clients upload or generate in sub-accounts and systems NGM administers.
4. Third-Party Providers — platform events, deliverability/status signals, billing rails, hosting/security logs, and similar operational data needed to run the Services.
5. Public and business sources — public websites, business directories, and referrals, used primarily for B2B prospecting and relationship context.
6. Affiliates and service providers — where needed to deliver or support the Services (see Section 6).
7. Referral partners — minimal business-contact information from an authorized introduction, referral code or permitted attribution event. Referral partners do not receive access to a Client's CRM, messages or end-customer lists.

5. How We Use Personal Information

5.1 Controller purposes (NGM’s own data)

We use personal information to:

• Provide and operate the Services, accounts, portals, and support;
• Bill and collect fees, manage wallets/usage where applicable, and keep financial records;
• Secure systems, prevent fraud, spam, and abuse, and investigate incidents;
• Improve websites, products, templates, and operations (including analytics and quality monitoring);
• Market NGM’s own services to business contacts (email or similar), with a clear opt-out in each marketing message and via the contact methods in Section 13; Offers may include separately accepted consulting, implementation or partner-delivered services to the direct client. Entrusted end-customer records are not used to develop those offers.
• Administer an accepted referral program — verify permitted attribution, calculate commissions, prevent referral fraud and keep necessary payout/tax records; provide partners only the minimal referral identifier, qualification status and commission information needed for that purpose, not Customer Data;
• Communicate about the Services, policy updates, and transactional notices; and
• Comply with law, enforce agreements, and defend legal claims.

5.2 Processor purposes (Customer Data)

We process Customer Data only as needed to:

• Provide, maintain, and support the Client’s configured Services and sub-accounts;
• Carry out Client instructions under the TOS/MSA/SOW;
• Prevent abuse that threatens NGM’s agency environment or other customers;
• Comply with law and Third-Party Provider / carrier requirements; and
• Create de-identified or aggregated operational metrics solely to operate, secure or report on the Client's agreed Services where permitted by contract and law; this does not authorize independent product development, AI training, advertising or reuse of entrusted data for other clients.

We do not use Customer Data to market NGM’s services to the Client’s end customers for NGM’s own benefit.

6. How We Share Information

We share personal information only as described below.

6.1 Third-Party Providers

We share information with Third-Party Providers so they can host, transmit, store, message, bill, authenticate, analyze (where enabled), or otherwise enable the Services. Providers may be identified in applicable service terms, privacy or data-processing disclosures, and security information. Detailed non-public security materials may be subject to reasonable confidentiality terms; legally or contractually required disclosures are not restricted by this naming convention.

6.2 Affiliates

Where needed for business administration, delivery or support, NGM may share the minimum necessary business-contact or account information with affiliated entities, including Capital Horizons Group LLC and Infinite 8 Enterprises LLC, under appropriate written confidentiality and purpose restrictions. When Infinite 8 acts as NGM's technology delivery subcontractor, its authorized personnel may also access Customer Data only to perform the agreed Services under NGM's instructions and the applicable confidentiality, security and data-processing terms. Affiliation alone grants no access or independent use rights. Affiliates are not authorized to sell that information. Subcontractor access or delivery does not make the client the subcontractor's direct customer. A separately accepted introduction or professional engagement identifies the actual provider and any minimal contact sharing; this paragraph is not blanket permission for affiliate or partner marketing. The restriction on independent use of Customer Data and mobile opt-in records remains.

6.3 Other service providers

We use professional advisors and vendors (e.g., accounting, legal, contractors under confidentiality) who process information on NGM’s instructions.

6.4 Legal and safety

We may disclose information if we believe in good faith that disclosure is required by law, regulation, legal process, or governmental request, or is necessary to protect rights, safety, or security of NGM, customers, or the public.

6.5 Business transfers

If NGM is involved in a sale of assets, change of control, or reorganization (including financing or acquisition), personal information may be transferred as part of that transaction, subject to appropriate confidentiality and this Policy’s principles (or a successor policy that is at least as protective for ongoing processing).

6.6 Sale, sharing and advertising choices

NGM does not sell personal information for money.

Under California and similar U.S. state laws, “sale” and “share” can include disclosures without a monetary payment. If optional analytics or advertising on NGM's own sites would constitute sale or sharing under applicable law, NGM must disclose the actual practice and provide required controls before enabling it:

• We will treat that activity as described in Section 7;
• You may opt out through the site's applicable privacy controls or by contacting [email protected] with “Do Not Sell or Share.” Browser and industry tools are supplementary to required NGM controls; and
• We honor Global Privacy Control (GPC) and similar browser opt-out signals for NGM sites where legally required.

Customer Data is never sold by NGM or shared for NGM's independent advertising. Clients remain responsible for their own advertising instructions and notices; NGM retains its own duties for technology it configures or operates.

6.7 No mobile information sale / SMS consent sharing

NGM does not sell, rent or share mobile information, text-message opt-in data or SMS consent with third parties or affiliates for their own marketing or promotional use. SMS consent is specific to the sender and purposes you authorized and is not transferable. This restriction controls the other sharing descriptions in this Policy.

Messaging and support providers may process the minimum information needed to deliver and support NGM's messages, maintain security or meet legal obligations, subject to applicable restrictions. They receive no permission to market independently using that information or consent.

NGM records the message categories you choose and your consent or withdrawal so it can apply your preferences, document authorization and prevent unwanted messages. Service-text and marketing-text choices are separate. A form submission, purchase, general policy acceptance or later policy update does not by itself create SMS marketing consent. See Terms and Conditions Section 4.5–4.10.

Reply STOP to an NGM text or send a clear request to [email protected] to withdraw consent. Reply HELP or use that email address for messaging assistance. NGM may retain necessary consent and suppression records to respect your choices and meet legal obligations; retaining a record does not permit further marketing.

Messages sent for a Client through its own account remain subject to that Client's notices, instructions and valid permissions. Consent to that Client's messages does not authorize NGM, its affiliates or another business to market independently to the Client's customers.

7. Cookies and Similar Technologies

The Cookie Policy describes cookies, local storage, pixels and similar technologies on NGM-controlled sites and portals, including nogoodmarketing.com and its subdomains. Potential categories are essential, optional preferences, analytics, and marketing/referral attribution; their actual deployment and duration must match the notice for the affected property.

NGM obtains consent before optional tracking where required and honors legally required opt-out preference signals, including Global Privacy Control. A referral commission does not make an attribution cookie essential. Site use, acceptance of service terms, or publication of a revised policy is not itself consent to optional tracking.

Use the cookie choices provided on the affected site, browser controls, or [email protected] for assistance and applicable opt-out requests. Browser or industry controls are supplementary and do not replace controls NGM must provide. Withdrawal must be as easy as giving consent where that standard applies. Third-party technology loaded by NGM remains subject to NGM's applicable notice, choice and data-processing duties.

On client-controlled properties, NGM follows the client's lawful instructions and applicable agreement. NGM does not place tracking on a client's property to prospect from that client's end customers or use entrusted Customer Data for its own advertising.

8. Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including:

• Account and billing records — for the life of the customer relationship and a commercially reasonable period afterward for tax, audit, and dispute purposes (often several years);
• Marketing contacts — until you opt out or the relationship is no longer relevant, subject to suppression-list retention so we can honor opt-outs;
• Security and logs — for periods appropriate to detect and investigate incidents; and
• Customer Data — according to the accepted MSA, Project Records and DPA, including the export window, deletion instructions, actual backup cycle and lawful retention exceptions. NGM does not substitute de-identification for a required deletion. Restricted backups and legally retained copies remain protected, unavailable for ordinary use and deleted when the applicable period ends.

Exact periods vary by record type; contact us if you need specifics for a verified request.

9. Security

NGM uses commercially reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, or alteration. No method of transmission or storage is perfectly secure.

Security and compliance materials published by Third-Party Providers describe their controls and are provided or referenced for informational purposes. Consistent with NGM’s TOS/MSA, NGM does not restate third-party attestations as NGM warranties.

Clients are responsible for safeguarding their credentials, enabling available security features (such as multi-factor authentication), and configuring access within their sub-accounts appropriately.

10. Children’s Privacy

The Services are directed to businesses and adults. They are not directed to children under 13, and NGM does not knowingly collect personal information from children under 13. Where U.S. state law sets a higher age for certain online services (e.g., under 16 for some sale/share rules), NGM does not knowingly sell or share personal information of consumers under that age. If you believe a child provided personal information to NGM, contact [email protected] and we will take appropriate steps to delete it.

11. International and U.S.-Centric Processing

NGM is organized in the United States (South Dakota) and primarily processes personal information in the United States. Third-Party Providers may process and store data in the U.S. and other countries where they operate. If you access the Services from outside the U.S., you understand that your information may be transferred to the United States and other jurisdictions that may have different data-protection rules than your home country.

EEA/UK (if applicable). If NGM knowingly offers Services to individuals in the EEA or UK in a way that triggers GDPR/UK GDPR, NGM will rely on appropriate transfer mechanisms (such as standard contractual clauses with Third-Party Providers where required) and process personal information under a lawful basis (typically contract performance, legitimate interests for B2B communications and security, or consent where required). Contact [email protected] for transfer or lawful-basis questions.

12. Your Privacy Rights (U.S. Multi-State)

Depending on where you live, applicable law (including California and other comprehensive state privacy laws) may give you rights such as:

• Know / access — categories and specific pieces of personal information we hold about you (as controller);
• Correct — inaccurate personal information;
• Delete — personal information, subject to legal exceptions (e.g., billing, security, freestanding legal claims);
• Portability — a portable copy of certain information;
• Opt out of sale / share — as described in Section 6.6 (including the broader non-monetary disclosures described in Section 6.6);
• Limit use of sensitive personal information — where that right applies and NGM processes such data as a controller;
• Opt out of marketing — NGM promotional emails and similar (transactional/service messages may continue); and
• Non-discrimination — we will not discriminate against you for exercising privacy rights.

Customer Data note. If your request concerns data a Client holds about you in a sub-account, we may redirect you to that Client or require the Client’s authorization, because NGM is the service provider for that data.

Nevada / other states. Residents of states with privacy laws may have similar opt-out and access rights; we will process requests consistent with applicable law.

13. How to Exercise Rights; Appeals

13.1 Submit a request

Email [email protected] (preferred) or write to:

No Good Marketing LLC
Attn: Privacy
514 America’s Way STE #21163
Box Elder, SD 57719

You may also use general contact methods on NGM’s website. Please describe your request and the email/account associated with it. We may need to verify your identity (and authority, if you are an agent) before fulfilling a request.

13.2 Authorized agents

Where law permits authorized agents, we may require proof of authorization and direct verification from the consumer.

13.3 Timing and appeals

We aim to respond within the period required by applicable law (often 45 days, extendable as permitted). If we deny your request, you may appeal by replying to our decision email with “Privacy Appeal” in the subject line. If an appeal is denied, we will explain available complaint options (including any applicable state attorney general process).

13.4 Marketing opt-out

Use the unsubscribe link in NGM marketing emails or email [email protected] with “Unsubscribe.”

14. Changes to This Policy

NGM reserves the right to revise or replace this Policy at any time. Each version identifies its revision date and applicable effective date. Updates describe practices prospectively; publication is not consent and does not silently change the commitments governing information already collected.

NGM posts the revised notice and identifies material changes. Affected account holders receive at least thirty (30) days' advance email or in-product notice of materially adverse changes, subject to the narrow law/security exceptions and other protections in Terms of Service Section 13. Visitors can review the dated notice on the affected site.

NGM obtains affirmative consent before a new use or disclosure whenever required by law or the applicable prior commitment, and before optional tracking when required. A notice update cannot override an accepted MSA, DPA or BAA, expand a client's processing instructions, permit prospecting from client end-customer records or authorize AI training on entrusted data. Existing opt-outs and withdrawals remain effective unless the person validly changes them.

15. Contact

16. Relationship to Terms of Service and MSA

This Privacy Policy is incorporated by reference into NGM’s Terms of Service (see TOS § Privacy) and describes personal-information practices for website, portal, CRM/platform/sub-account, and related Services. The accepted MSA and Project Records govern the Client's Services; a standalone SOW is optional. An accepted DPA or BAA controls its data-processing subject matter. Customer ownership of Customer Data and the restrictions on its use continue to apply; this Policy explains practices and rights and does not grant broader processing rights.