Advisor Atlas Leads — Terms of Service

These Terms of Service (“Terms”) govern your access to and use of Advisor Atlas Leads, the website at advisoratlasleads.com, the marketplace, and any related services (collectively, “AAL”). The Privacy Policy is incorporated by reference.

You accept these Terms by checking the consent box on the signup form, by accessing the marketplace as a returning advisor, or by purchasing a lead. The consent box reads:

By checking this box and clicking [Sign up], I represent that I am an investment adviser, investment adviser representative, broker-dealer registered representative, or state-licensed insurance producer, that I am authorized to act on behalf of the firm I am signing up, and that I agree to AAL’s Terms of Service and Privacy Policy. I understand that lead purchases are non-refundable except under the limited circumstances described in Section 8, that I must independently comply with TCPA, GLBA, SEC Rule 206(4)-1, NAIC suitability and best-interest rules, and every other law applicable to my outreach, and that AAL does not supervise, control, or vouch for me to the consumers introduced through the marketplace.

If you do not agree, do not check the box and do not use the marketplace.

Advisor Atlas Leads is a per-lead marketplace operator. Nothing more. AAL operates the marketplace that lists anonymized consumer leads forwarded from Retirement Atlas (“RTP”), accepts purchases from qualifying advisors, releases the consumer’s contact information to the one advisor that purchases a given lead, and bills the advisor for that purchase.

AAL is not:

• a registered investment adviser, investment adviser representative, or solicitor;
• a broker-dealer or registered representative;
• an insurance producer or insurance agency;
• a Certified Financial Planner, financial planner, accountant, attorney, bank, trust company, or other financial institution;
• a co-fiduciary, co-adviser, joint venture partner, agent, or representative of yours or of any advisor on the marketplace;
• a supervisor of, or party responsible for, any communication, recommendation, advice, sale, transaction, fee, product, or other conduct that takes place between you and a consumer whose lead you purchased through the marketplace.

The marketplace surfaces, including the matching score, the briefing narrative, the planning trail, and the price list, are tools for you to evaluate inventory. They are not investment advice, suitability determinations, or compliance review of any kind.

Every lead on AAL originates with a consumer who has used the Retirement Atlas planning journey, opted in to be matched with a partner firm, and given RTP the consent described in RTP’s Terms of Use. RTP forwards an anonymized payload to AAL over an HMAC-signed bridge. The anonymized listing you see on the marketplace contains things like asset bands, state, age, journey stage, score signals, and a headline. It does not contain the consumer’s name, email, phone number, or any other direct identifier.

When you purchase a lead, AAL releases the consumer’s contact information and the contents of the consumer’s plan to you. The release happens by HMAC-signed unlock callback to RTP at the moment of purchase. From that point forward, your relationship with the consumer is between you and the consumer.

AAL does not generate leads, does not pre-screen consumers for suitability or fit, does not vouch for the accuracy of any consumer-provided input, and does not warrant that any particular lead will convert, close, or produce any particular outcome.

To open an account on AAL you must represent and warrant that:

• You are at least 18 years of age, a resident of the United States, and authorized to bind the firm on whose behalf you are signing up;
• You (or the firm) are currently registered or licensed in every state in which you intend to receive leads under at least one of the following capacities: state-licensed insurance producer, SEC-registered investment adviser or investment adviser representative, state-registered investment adviser or investment adviser representative, FINRA-registered broker-dealer or registered representative, or other capacity AAL agrees to in writing;
• You and the firm are in good standing with every regulator whose authority you fall under, and you are not currently subject to any unresolved disciplinary action, suspension, statutory bar, or supervisory order that would affect your ability to serve consumers through the marketplace;
• You will only mark a state in your “licensed states” profile if you are actually licensed or registered to serve consumers in that state for the products and services you intend to discuss with leads from that state;
• Your authorization to act on behalf of the firm covers checkout, billing, and the wallet-debit authorizations in Section 6.

AAL may verify any of the above through public registries (FINRA BrokerCheck, SEC IAPD, state Department of Insurance lookups), through third-party background-check providers, or directly with you. AAL may decline or revoke account access at any time, with or without cause.

You can purchase a single non-exclusive (in the sense of: not a long-term retainer) but one-buyer-per-lead right to receive a consumer’s contact information and retirement map contents. Each lead is sold to exactly one advisor.

• One buyer per lead. Once a lead is purchased by an advisor, the marketplace marks it “purchased” and no other advisor can buy it.
• No exclusivity beyond the lead. The consumer is free to use other planning tools, talk to other advisors, and engage anyone they choose. The one-buyer rule does not extend to any future conduct by the consumer.
• No subscription. You pay per lead. There is no monthly minimum, no recurring license fee, and no guaranteed lead volume.
• No contract term. You may close your account at any time under Section 22. We may close it for cause under the same section.

Per-lead pricing. Each lead is priced according to the matrix published on /browse at the time of purchase: a 5-tier (by estimated liquid assets) by 2-intent (planning vs. hot) base price, with automatic aging discounts after 3 days (-15%) and 7 days (-35%), and removal at 90 days. The price displayed on the lead row at the time you click “Buy” is the price you pay.

Wallet model. AAL operates a pre-paid wallet. You top up by credit or debit card or other payment method we accept; lead purchases (manual and auto-buy) debit your available balance. Bulk top-ups earn bonus credit per the ladder published on /billing.

Auto top-up authorization (optional). If you enable auto top-up, you authorize AAL to charge the payment method you have on file, on a recurring basis, to bring your wallet balance back to the target you set whenever it drops below the floor you set. You can disable auto top-up at any time from /billing.

Auto-buy authorization (optional). If you enable any auto-buy rule, you authorize AAL to purchase matching leads on your behalf and to debit your wallet at the published price for each purchase, up to the monthly cap you set. Auto-buy purchases are final at the moment they occur and are subject to the same refund window in Section 8 as manual purchases. You can pause or delete any rule at any time from /autobuy.

Taxes. Prices are exclusive of any sales, use, value-added, or similar tax. You are responsible for any such tax. We may add tax to your charges where we are required to collect it.

Payment processor. Card payments are processed by Stripe, Inc. Your card information is collected and stored by Stripe under its own terms and privacy policy; AAL does not receive or store full card numbers.

When you purchase a lead, the consumer is marked as held to you and to you alone. While the hold is in effect, no other advisor on AAL will receive that consumer’s contact information from this purchase. The hold is released, and the consumer becomes available to be re-matched, when:

• you mark an outcome of “not a fit,” “unresponsive,” or “closed” on the lead under Section 9, OR
• 30 days pass after the purchase without your having logged any outreach or outcome, OR
• the consumer asks RTP to release the hold from inside the RTP product, OR
• AAL terminates your account under Section 22.

The hold is enforced on the RTP side via the bridge. AAL does not represent that any consumer will remain available for you beyond your good-faith use of the hold window.

Lead purchases are generally non-refundable. We will, however, credit your wallet for any purchase that meets all of the following criteria, provided you submit a written dispute to disputes@advisoratlasleads.com within fourteen (14) days of the purchase:

• The email address provided by the consumer hard-bounces on a test send, OR
• The phone number provided by the consumer (where contact by phone is permitted) is disconnected, reassigned, or otherwise fails to reach the consumer named in the lead, OR
• The consumer informs you, in writing or by phone (with a contemporaneous note), that the lead is fraudulent, that the consumer never opted in, or that the consumer’s identity was used without their authorization, OR
• The lead is a duplicate of a lead you have already purchased in the prior 90 days, where the duplicate is the result of a AAL or RTP error rather than the consumer re-engaging, OR
• The lead is suppressed (consumer opt-out, CCPA/CPRA deletion, GDPR erasure, court order, RTP-side compliance action) within 72 hours of the purchase, before you have had a reasonable opportunity to engage.

We decide refund requests within ten (10) business days, based on our review of the facts. Our decision is final. We do not refund based on lack of conversion, lack of fit determined after a reasonable attempt to engage, or the consumer’s decision not to retain you.

You agree to record an outcome on each lead you purchase within thirty (30) days of the purchase. Outcomes are one of: “engaged,” “closed,” “not a fit,” or “unresponsive.” For “closed” outcomes, you agree to report a good-faith estimate of the net worth or AUM being managed under the engagement, for the purpose of the marketplace’s aggregate ROI dashboard and any feedback signal to RTP.

Outcome data is forwarded to RTP over the bridge so RTP can measure how well its planning journey converts. Outcome data is not used to identify the consumer to any other advisor and is not published in any advisor-identifying form.

Failure to report outcomes does not, by itself, breach these Terms. Persistent non-reporting may result in lower ranking in auto-match queues and may, in AAL’s discretion, trigger account review.

The information you receive at purchase — the consumer’s name, email, phone number (if permitted), state, retirement map contents, and discovery answers — is nonpublic personal information within the meaning of the Gramm-Leach-Bliley Act (“GLBA”) and applicable state financial privacy laws. You agree, with respect to that information:

• to handle it under your firm’s written information security program, in compliance with the GLBA Safeguards Rule (16 C.F.R. Part 314), state insurance privacy regulations modeled on the NAIC Insurance Information and Privacy Protection Model Act, and any other privacy law applicable to your firm and to the consumer’s state;
• not to share it with any third party other than your firm, your firm’s service providers under appropriate contracts, the consumer themselves, or as required by law;
• not to use it for any purpose other than evaluating, pursuing, or maintaining a professional engagement with the consumer introduced through the marketplace;
• to honor any opt-out, deletion, correction, or access request the consumer makes, in the time required by the applicable privacy law (CCPA/CPRA, Virginia CDPA, Colorado CPA, etc.);
• to notify AAL within 72 hours of any actual or reasonably suspected unauthorized disclosure of the consumer’s information that you receive from AAL, at security@advisoratlasleads.com.

The above survives termination of these Terms.

Each lead on the marketplace carries an explicit “allowed contact methods” flag forwarded from RTP. The consumer’s TCPA consent has been captured by RTP only where the flag includes “phone.” Where the flag is “email only,” the consumer has not consented to phone or text outreach.

You agree:

• to honor the consumer’s contact-permissions flag exactly: no phone calls or text messages to any consumer whose flag is “email only,” regardless of how that consumer’s number was obtained;
• to comply with the Telephone Consumer Protection Act (“TCPA”), including its rules on autodialed and prerecorded calls and texts, AI-generated calls, STOP and HELP keyword handling, calling-time restrictions, and the National Do Not Call Registry;
• to comply with state telemarketing laws applicable to each consumer’s state, including without limitation the Florida Telephone Solicitation Act (FTSA), the Washington Mass Telephone Practices Act (WMTPA), the Oklahoma Telephone Solicitation Act of 2022, and any equivalent law;
• to comply with the CAN-SPAM Act for any commercial email you send the consumer;
• to maintain your own internal Do Not Call list and add any consumer who asks to be removed.

AAL is not the calling party for TCPA purposes, does not dispatch calls or texts on your behalf, and does not vouch for the accuracy of any phone number a consumer enters into RTP. Compliance is yours.

AAL pays no fee to you, but you pay a fee to AAL for each consumer introduction. If you (or your firm) are a registered investment adviser, the SEC’s Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) treats that fee, and the marketplace listing of the consumer’s plan, as an endorsement or testimonial advertisement that you are disseminating. You are responsible for the rule’s promoter and endorser conditions, including, where applicable:

• clear and prominent disclosure to the consumer, at or before the time of advice, that AAL was paid for the introduction and the cash nature and amount of the compensation;
• disclosure of the material conflicts of interest resulting from your payment relationship with AAL;
• a written agreement covering the promoter relationship to the extent required;
• oversight by your firm of the marketing the consumer received before the introduction.

AAL provides a downloadable summary of the matching mechanic and the fee paid for your records but does not opine on whether your specific marketing program complies with the Marketing Rule. Your compliance, including any required Form ADV disclosure, is yours.

If you intend to discuss or sell insurance products to any consumer introduced through the marketplace, you agree to comply with the NAIC Suitability in Annuity Transactions Model Regulation, with the state best-interest standard adopted by the consumer’s state (where adopted), and with all other product-side suitability, best-interest, and disclosure rules applicable to your firm and the consumer’s state.

If you are also a broker-dealer or registered representative, you agree to comply with Regulation Best Interest (Reg BI), the FINRA rules applicable to your conduct, and any associated disclosure obligations (including Form CRS delivery).

AAL does not pre-qualify any consumer for any product. The fact that an annuity, insurance, or other product slug appears in the consumer’s planning trail is not a recommendation by AAL that the product is suitable, appropriate, or in the consumer’s best interest.

You agree not to:

• resell, re-share, sublicense, broker, syndicate, or otherwise transfer any consumer information you receive through the marketplace to any third party other than as expressly permitted in Section 10;
• use any consumer information for a purpose unrelated to evaluating, pursuing, or maintaining a professional engagement with the consumer introduced through the marketplace, including but not limited to bulk marketing of unrelated products or services;
• scrape, mirror, harvest, automatically extract, reverse engineer, or otherwise programmatically extract listings, pricing, scores, or any other marketplace data outside the purchase flow;
• attempt to access another advisor’s account, wallet, rules, or purchases;
• use the marketplace to defraud, mislead, threaten, harass, or unlawfully discriminate against any consumer;
• use AAL to identify a consumer for any purpose other than the introduction that the consumer agreed to in RTP’s consent language, including ad targeting, data enrichment for third parties, or training of any third-party model;
• misrepresent to any consumer that you have been vetted, approved, endorsed, supervised, or otherwise certified by AAL beyond the contractual eligibility representations in Section 4.

You are responsible for keeping your account credentials confidential and for all activity that occurs under your account, including auto-buy purchases. Notify us promptly at security@advisoratlasleads.com if you suspect any unauthorized access. If we reasonably suspect compromise, we may suspend the account, reverse any auto-buy purchases that occurred after the compromise, and require re-authentication before the account resumes.

AAL retains the anonymized lead inventory, the price and score history, your purchase history, your auto-buy rules, your outcome reports, and all bridge audit logs for as long as we need them to operate the marketplace and to defend any dispute. We do not retain consumer PII after delivery to the purchasing advisor beyond what is necessary for billing, fraud detection, and audit. RTP, not AAL, is the system of record for consumer PII.

On a consumer’s deletion request to RTP, RTP marks the lead suppressed on the bridge; AAL hides the listing from the marketplace, redacts any anonymized references where required, and retains the audit trail of the request and the action taken.

The marketplace mechanics, the pricing formula, the scoring composition, the auto-buy queue logic, and any non-public information about other advisors’ activity are AAL’s confidential information. You agree not to disclose it to any third party other than your firm’s legal, accounting, or compliance advisors under appropriate confidentiality, except as required by law.

To the maximum extent permitted by law, AAL is provided on an “AS IS” and “AS AVAILABLE” basis without warranties of any kind, express, implied, or statutory, including warranties of merchantability, fitness for a particular purpose, accuracy, non-infringement, or quiet enjoyment. AAL does not warrant that the marketplace will be uninterrupted, timely, error-free, or free of viruses or other harmful components.

AAL does not warrant the quality, accuracy, completeness, suitability, conversion rate, AUM-closed rate, or any other attribute of any lead. The match score, the pricing matrix, and the briefing narrative are informational only.

To the maximum extent permitted by law:

(a) AAL and its affiliates, officers, employees, agents, suppliers, and licensors will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenues, data, business, goodwill, or other intangible losses, arising out of or related to your use of AAL, even if AAL has been advised of the possibility of such damages.

(b) AAL’s aggregate liability arising out of or related to these Terms or your use of AAL will not exceed the greater of one thousand U.S. dollars ($1,000) or the total amount of fees you actually paid to AAL in the twelve (12) months preceding the event giving rise to the liability.

(c) AAL is not liable for any act, omission, advice, recommendation, communication, sale, product, breach, or violation of law by you, the consumer, RTP, or any third party. Any claim arising from your conduct toward a consumer introduced through the marketplace must be brought against you, not against AAL.

(d) Some jurisdictions do not allow the exclusion or limitation of certain damages. In those jurisdictions, the exclusions above apply only to the maximum extent permitted by law.

You agree to defend, indemnify, and hold harmless AAL, its affiliates, officers, employees, agents, suppliers, and licensors from any claim, damage, loss, liability, cost, or expense (including reasonable attorneys’ fees) arising out of or related to (a) your breach of these Terms, (b) your breach of any law or regulation applicable to your handling of consumer information or your outreach to a consumer, (c) any dispute between you and a consumer introduced through the marketplace, including TCPA, GLBA, state telemarketing, state privacy, suitability, best-interest, or Marketing-Rule claims, and (d) your misrepresentation of your eligibility, licensing, or good standing under Section 4.

Please read this section carefully. It affects your legal rights.

Informal resolution first. Before filing any claim, you agree to first contact us at legal@advisoratlasleads.com with a written description of the dispute and the relief you seek. We will try in good faith to resolve the dispute within sixty (60) days.

Binding arbitration. If informal resolution fails, you and AAL agree that any claim arising out of or relating to these Terms, your use of AAL, the marketplace, or any lead purchase will be resolved by binding individual arbitration administered by JAMS under its Streamlined Arbitration Rules (for claims under $250,000) or its Comprehensive Arbitration Rules (for larger claims). The arbitration will be conducted before one commercial arbitrator, will be governed by the Federal Arbitration Act and not by any state arbitration law, and will take place in [city, state] or, at AAL’s election, by videoconference.

Class-action waiver. You and AAL each agree to bring claims against the other only in your or its individual capacity and not as a plaintiff or class member in any purported class, collective, consolidated, or representative action.

30-day opt-out. You may opt out of this arbitration agreement by sending written notice to legal@advisoratlasleads.com within thirty (30) days of first agreeing to these Terms. The notice must include your name, the email used with AAL, and a clear statement that you wish to opt out of arbitration.

Exceptions. Either party may bring an individual action in small-claims court. Either party may seek injunctive relief in court to protect intellectual property rights or to enforce Section 14 (acceptable use). Nothing in this section limits a party’s right to report conduct to a government agency.

You may close your account at any time from /profile or by writing to support. We may suspend or terminate your account, refuse any purchase, reverse any auto-buy purchase, or hold any unspent wallet balance for review:

• immediately, if we have a reasonable belief that you have breached Section 4 (eligibility), Section 10 (PII handling), Section 11 (TCPA), or Section 14 (acceptable use);
• immediately, if a regulator, law enforcement agency, or court instructs us to;
• immediately, on receipt of a credible complaint from a consumer about your conduct that we cannot resolve informally;
• with reasonable notice, for non-payment, fraud risk, or continued failure to report outcomes;
• without cause, on thirty (30) days’ notice.

On termination, any wallet balance that is not subject to chargeback or dispute will be refunded to your original payment method within thirty (30) days. The sections that by their nature should survive termination — including 2, 3, 10, 11, 12, 13, 16, 17, 18, 19, 20, 21, 23, and the Privacy Policy — survive.

These Terms are governed by the laws of the State of Wyoming, excluding its conflict-of-laws rules and excluding any matter governed by the Federal Arbitration Act. Subject to Section 21, the state and federal courts located in [county, Wyoming] have exclusive jurisdiction over any matter not subject to arbitration.

We may update these Terms. If a change is material, we will give you at least thirty (30) days’ notice by email or by an in-product notice before the change takes effect, and we will update the “Effective date” line at the top of this document. Your continued use of AAL after the effective date of the change means you accept the updated Terms. If you do not accept them, you can stop using AAL.

Entire agreement. These Terms and the Privacy Policy are the entire agreement between you and AAL regarding AAL and supersede any prior agreements.

Third-party beneficiaries. RTP is an intended third-party beneficiary of Sections 2, 3, 10, 16, and 20.

Severability. If any provision is held unenforceable, the rest stays in effect.

No waiver. Our failure to enforce a provision is not a waiver of our right to enforce it later.

Assignment. You may not assign these Terms without our prior written consent. We may assign them in connection with a merger, acquisition, reorganization, or sale of substantially all of our assets.

Independent contractors. You and AAL are independent contractors. Nothing in these Terms creates an agency, partnership, joint venture, or employment relationship.

Notices. We send notices to the email address associated with your account. You can send notices to legal@advisoratlasleads.com.

Questions about these Terms: legal@advisoratlasleads.com
Billing questions and refund requests: disputes@advisoratlasleads.com
Privacy questions and consumer requests: privacy@advisoratlasleads.com
Security incidents: security@advisoratlasleads.com
Mail: [LEGAL ENTITY NAME], [registered address]