Privacy Policy

Updated October 9, 2025

1. Overview

The Drake Agency, LLC (“The Drake Agency,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.TheDrakeAgency.ai, you communicate with us, or we otherwise process your Personal Information (collectively, the “Platform”), except as specified below with respect to our role as a processor.

This Privacy Policy does not apply to data subjects of our customers whose Personal Information we may receive pursuant to The Drake Agency services we provide to our customers. Our customers use our platform to store and process their own customers’ Personal Information, such as to: (i) create their own websites and applications; (ii) offer or provide their own products and services; (iii) send electronic communications; and (iv) otherwise collect, use, share or process Personal Information. In these cases, we act as a processor and service provider when providing these services to our customers (the “Processor Services”). When you give your data to one of our customers or when we collect your Personal Information on their behalf in connection with our Processor Services, our customer’s privacy notice, rather than this Privacy Policy, will apply to our processing of your Personal Information.

Please read this Privacy Policy to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree and consent to this Privacy Policy.

2. Information That The Drake Agency Collects About You

We collect information about you (“Personal Information”):

Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase or request information from The Drake Agency, we will ask for things like your name, contact (including email address and phone number), billing, shipping and communication information, and account ID or credentials in order to fulfill your request. If you set up an appointment with us through the Platform, attend a trade show or event, or otherwise contact us, you may also provide similar information. If you submit any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by you obtaining their consent).

From third parties. We obtain information through marketing partners (such as advertising and marketing companies, marketing affiliates, and social media platforms), vendors (such as data set and information vendors), and suppliers and other third parties (such as hosts or vendors at events or trade shows, public database providers, or research partners). This information can include, for example, your name, contact information, professional information, and content that is publicly available. We might also obtain information through a partner, or co-create datasets with a partner, as part of our business operations.

3. How The Drake Agency Uses Information It Collects About You

We use Personal Information that we collect about you or that you provide to us for the following purposes:

For Functionality and Development of the Platform. We use information to provide, offer, personalize, and improve the Platform. Other business purposes that depend on use of your information include data analysis related to testing, modifying, improving or developing new products, services and technologies, and to identify trends. We also use information from the Platform to generate updates and reports, and to check that the Platform is working properly. Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernized, in order to provide you with the up-to-date security, versions, features, options and controls associated with your systems or devices.

To Provide AI Features: Some Platform features may leverage artificial intelligence (“AI”) tools to enhance performance capabilities. Our use of AI is designed to provide direct services to you. We do not use your Personal Information to train generalized, public AI models. We work with specialized AI subprocessors and our instructions limit their use of your data to the provision of the specific service you are using.

For Customer Support. We use your Personal Information to provide you with customer support for the Platform.

For Business Operations. We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities, or comply with contractual obligations. 

To Communicate. We use contact information to send messages; to communicate with you about the Platform and your account; to provide the Platform; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences.  We occasionally conduct surveys or do focused research or studies through which you may choose to share information.  

To Protect and Secure the Platform: We may use information to keep our Platform safe, such as crime or fraud monitoring and prevention or cybersecurity efforts.

For Advertising and Marketing. We may use Personal Information about you, including what advertisements you viewed and other information we collect, to enable us to provide personalized content, verify eligibility for and extend promotional offers, engage in targeted advertising, and study the effectiveness of advertising and marketing campaigns. This includes using data we collect from marketing partners through our affiliate referral program to support our targeted advertising.  

For Statistical Purposes to Improve the Platform. We may compile Platform statistics into traffic reports, which help The Drake Agency understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Platform, we are likely to highlight that information. This Information helps us create a better overall experience for Platform users.

For Legal, Regulatory, and Compliance Purposes. We may use Personal Information to comply with legal, regulatory, or related obligations, including to protect our legal rights.

LEGAL BASIS FOR OUR USE: Certain data protection laws (such as those for example, in the European Economic Area (EEA), the United Kingdom (UK), and Brazil) require us to identify a valid legal reason (called a “legal basis”) before we collect, use, share or otherwise process your Personal Information. Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.

Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.

Go High Level, Inc. is the Data Controller of all Personal Information collected through the Platform in the EEA and the United Kingdom, except with respect to the Processor Services (where The Drake Agency is the Data Processor) or where a supplemental Privacy Policy says otherwise. The contact details for The Drake Agency are set out in the "HOW TO CONTACT US” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “HOW TO CONTACT US” Section below.

4. How The Drake Agency Protects Your Information

Go High Level, Inc has designed the Platform to provide reasonable and appropriate administrative, technical and organizational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. They require their suppliers and vendors, such as The Drake Agency, to apply similar protections when they access or use Personal Information that is shared with them. Users of the Platform must also do their part in protecting the data, systems, networks, and service they are utilizing. No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any The Drake Agency account has been compromised), please immediately notify us by contacting us using the instructions in the “HOW TO CONTACT US” section below.

5. When The Drake Agency Shares Your Information

We may disclose Personal Information with the following categories of third parties:

With Affiliates and Subsidiaries. We may share information with our corporate affiliates and subsidiaries for purposes limited to and consistent with this Privacy Policy.

With Service Providers. We may share information with our authorized vendors and suppliers to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at The Drake Agency, and we process Personal Information using these tools as a regular course of business. We also share anonymized or aggregated information with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new The Drake Agency services. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.

With Partners. We work with third parties for purposes such as marketing and similar promotions, to enable joint products or identify opportunities for product integration, or to facilitate services on the Platform. For example, we use an affiliate referral system in which third parties promote The Drake Agency services; if you visit or use our Platform through an affiliate referral link, we will share information about you back to the referral partner, including your name, email address, and account plan.

For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns.

In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform. Content may be based on information obtained, for example, through prior purchases or transactions, through your device’s physical location, through information about what advertisements and content you have viewed. For information about how to manage our advertising and marketing, please see the section entitled "Your Choices & Rights" below. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable Platform Services and content.

For Connections to Social Networks and Third-Party Services. If you connect third-party services to the Platform (including installing an app through our marketplace) you are agreeing to provide information about you to the third-party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the The Drake Agency Services, this connection uses YouTube’s API services, and the Google Privacy Policy (located here) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located here.

Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

For Legal, Regulatory, or Related Purposes. We may disclose your information to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders.

At Your Direction or With Your Consent. The Drake Agency may disclose your Personal Information to any other person or entity where you consent to the disclosure or otherwise direct us to disclose the information.

We do NOT share your phone number or opt-in consent with third parties unless we’ve received your express written consent to do so.

6. Data Retention

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further information. And in some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Information From Children

We do not knowingly collect, use, disclose, sell, or share Personal Information from children under 16. If we learn that we have collected the Personal Information of a child under 16 we will take steps to delete the information as soon as possible. If you are under 16, do not provide any information about yourself to The Drake Agency, including your name, address, telephone number or email address. If you become aware that Personal Information of a child under 16 years of age has been provided, please let us know using one of the methods provided under the “HOW TO CONTACT US” section below.

8. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on The Drake Agency’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to other organizations through or in connection with the Platform or other The Drake Agency Services.

9. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

10. YOUR LEGAL RIGHTS

The Drake Agency respects your rights related to your Personal Information. Depending on where you live, you may have rights to request access to, corrections of, or deletion of your personal data, and to make additional choices such as the kinds of marketing materials you receive (or choose not to receive marketing from The Drake Agency at all). See below for more information, depending on your location. If your jurisdiction does not appear on the list below, you may still have privacy rights like those that appear below; you can contact us using the “HOW TO CONTACT US” section below to learn more

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11. U.S. Privacy Rights

Residents of certain US states, such as California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and other states to the extent they enact similar privacy laws, may have additional rights under your corresponding state laws (“collectively, US State Privacy Laws”). This section provides further information pursuant to the US State Privacy Laws.

Right to Opt Out of Sale/Share/Targeted Advertising. The Drake Agency does not sell your Personal Information for money. However, certain US State Privacy Laws may consider the disclosure of information for advertising purposes to be a “sale,” “share,” or “targeted advertising.” If you wish to exercise your right to opt out of The Drake Agency using your Personal Information for these purposes, you may do so by using the “Do Not Sell or Share My Information” on the Platform website or via the details in the “HOW TO CONTACT US.”

Rights to Access, Correction, and Deletion. You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request deletion of your Personal Information, please note that The Drake Agency may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by law. Depending on the nature of your request, we may require additional information to verify your identity before processing your request.

Right to Non-Discrimination. We will not discriminate against you for exercising any of your US State Privacy Law rights.

Right to Appeal. If we have not responded to your request or you are unsatisfied with our response, you have the right to appeal. To appeal please, contact us using the details in the “HOW TO CONTACT US” section.

Authorized Agent. You can designate an authorized agent to make a privacy request on your behalf in certain circumstances. If you use an authorized agent for this purpose, The Drake Agency may ask the agent and you for additional information to verify their authorization.

Sensitive Data. To the extent The Drake Agency collects any Personal Information considered to be sensitive under US State Privacy Laws, we limit our processing of that information to uses: (1) you have authorized, or (2) that are otherwise allowed or required by law.

Automated Profiling. We do not profile in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you.

Further Information about Data Collection, Uses, and Disclosures. We collect Personal Information from and about you for a variety of purposes, as described in the Information that The Drake Agency Collects and How The Drake Agency Uses Information sections above.

In the past 12 months, we have collected the following categories of Personal Information:

Identifiers (such name, address, IP address, email, etc.)

Personal information listed in the California Consumer Records Statute (Civil Code Section 1798.80(e)), such as name and phone number

Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)

Internet or other similar network activity (such as information on a consumer’s interaction with a website, application, or advertisement, etc.)

Inferences (such as analytics and preferences)

We share Personal Information with third parties for business purposes. These business purposes include:

Site Functionality

Customer Support

Business Operations

Communication

Advertising and Marketing

Analytics

The categories of third parties to whom we disclose your Personal Information for a business purpose include: (i) subsidiaries and affiliates; (ii) service providers; (iii) partners; and (iv) advertising and marketing partners.

We may “sell” or “share” your Personal Information (as those terms are defined by U.S State Privacy Laws) to third parties, subject to your right to opt out of those sales or sharing. In the last 12 months, we have sold or shared the following categories of personal information for the purposes described in this Privacy Policy, subject to your settings and preferences and your Right to Opt-Out:

Identifiers (such name, address, IP address, email, etc.)

Personal information listed in the California Consumer Records Statute (Civil Code Section 1798.80(e)), such as name and phone number

Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)

Internet or other similar network activity (such as information on a consumer’s interaction with a website, application, or advertisement, etc.)

Inferences (such as analytics and preferences)

The categories of third parties to whom we may sell or share the personal information include:

Marketing and advertising partners

Affiliate partners 

12. International Data Transfers

The Drake Agency is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our affiliates or third-party service providers, who may be located in a different country to you (including India).

The Drake Agency transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

Whenever The Drake Agency transfers Personal Information beyond the country of origin, we will do so in accordance with applicable laws. The Federal Trade Commission has jurisdiction over The Drake Agency’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF). The Drake Agency may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Drake Agency is liable in cases of onward transfers to third parties.

13. Data Privacy Framework

The Drake Agency, LLC and LeadConnector LLC comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. The Drake Agency further agrees to notify you without undue delay, if its self-certification under any of the Data Privacy Framework is withdrawn, terminated, revoked or otherwise invalidated and take appropriate steps to stop and remediate and unauthorized processing of such personal data.

14. Privacy Policy Updates

The Drake Agency may change this Privacy Policy at any time, at its discretion. We will notify you of changes if required by law. Your continued use of the Platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

15. How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy practices, contact us at [email protected] or by mail at:

The Drake Agency, LLC

7013 Bolzano Way, Elk Grove CA 95757