Referral Direct Privacy Policy

Effective Date: August 17, 2026

Referral Direct is a referral-program software service operated by Loyalty LI LLC (“Referral Direct,” “we,” “us,” or “our”).

We respect your privacy and are committed to handling personal information responsibly.

This Privacy Policy explains how we collect, use, process, store, and disclose information through the Referral Direct website, business dashboards, referral-program pages, communications, and related software and services (collectively, the “Service”).

This Privacy Policy applies to:

  • Businesses that use Referral Direct (“Business Customers”);

  • Authorized users of Business Customer accounts;

  • Individuals who join referral programs (“Referrers”);

  • Individuals submitted as referrals (“Referred Persons”);

  • Website visitors; and

  • Other individuals who interact with the Service.

1. How Referral Direct Works

Referral Direct provides software that enables businesses to create, operate, share, track, and manage referral programs.

A Business Customer determines the details of its own referral program, including eligibility requirements, qualifying referrals, reward types, reward amounts or benefits, and whether a referral has satisfied the Business Customer's requirements.

Referral Direct provides the technology used to record and manage this information.

When Referral Direct processes personal information on behalf of a Business Customer for purposes of operating that Business Customer's referral program, the Business Customer generally determines the purposes for which that information is used and Referral Direct acts as a service provider or processor.

Referral Direct may separately process information for its own legitimate business purposes, including administering accounts, subscriptions, billing, security, fraud prevention, support, legal compliance, and operation of the Service.

2. Information We Collect

A. Business Account Information

When a business creates, purchases, configures, or uses a Referral Direct account, we may collect:

  • Business name;

  • Contact person's name;

  • Email address;

  • Telephone number;

  • Business website;

  • Account credentials;

  • Referral-program settings;

  • Program name;

  • Reward information;

  • Subscription and billing status;

  • Customer or subscription identifiers;

  • Communications with Referral Direct; and

  • Other information reasonably necessary to provide the Service.

B. Referrer Information

When an individual joins or participates in a referral program, we may collect:

  • First and last name;

  • Email address;

  • Telephone number;

  • Program participation information;

  • Referrals submitted;

  • Referral statuses;

  • Reward information;

  • Reward fulfillment status;

  • Dates associated with program activity; and

  • Communications relating to the referral program.

C. Referred Person Information

A Referrer may submit information regarding another individual to a participating business.

This information may include:

  • First and last name;

  • Telephone number;

  • Email address, if provided;

  • Date of referral;

  • Identity of the Referrer;

  • Referral status; and

  • Information voluntarily submitted by the Referrer that may help the participating business understand or follow up on the referral.

A Referred Person may therefore have personal information processed through Referral Direct even if that person did not initially provide the information directly to us.

D. Referral and Reward Information

We may process information concerning:

  • The participating business;

  • The Referrer;

  • The Referred Person;

  • Date of referral;

  • Current referral stage;

  • Business follow-up;

  • Whether the referral became a customer;

  • Reward type;

  • Reward amount or benefit;

  • Reward fulfillment status; and

  • Related program activity.

Referral Direct may record rewards such as cash rewards, discounts, store credit, free products or services, or other rewards created by a Business Customer.

Referral Direct generally records and tracks reward obligations and fulfillment. Unless expressly stated otherwise, Referral Direct does not itself provide or fund those rewards.

E. Subscription and Payment Information

Business subscriptions may be processed through third-party payment processors.

Referral Direct may receive information such as:

  • Payment status;

  • Subscription status;

  • Billing dates;

  • Transaction identifiers;

  • Payment processor customer identifiers;

  • Subscription identifiers; and

  • Limited billing information.

Complete payment-card numbers are generally processed directly by the applicable payment processor rather than stored by Referral Direct.

F. Technical and Usage Information

When the Service is used, we may automatically collect technical or usage information such as:

  • IP address;

  • Browser type;

  • Device information;

  • Operating system;

  • Login activity;

  • Timestamps;

  • Pages or features accessed;

  • Error information;

  • Security events; and

  • Other information reasonably necessary to operate, secure, troubleshoot, maintain, or improve the Service.

We may use cookies, local storage, session information, and similar technologies for authentication, security, functionality, preferences, and operation of the Service.

3. Information About Other People

Referral Direct allows Referrers to provide information about people they wish to refer to participating businesses.

By submitting another person's personal information through Referral Direct, the submitting individual represents that they have a lawful basis and appropriate permission to provide that information for purposes of making the referral.

Users must not submit information about another person through automated scraping, purchased contact lists, deceptive means, harassment, spam, or other unlawful methods.

Users must not submit highly sensitive information through Referral Direct referral forms or free-text fields, including:

  • Social Security numbers;

  • Complete payment-card information;

  • Bank-account credentials;

  • Passwords;

  • Government identification numbers;

  • Medical records;

  • Protected health information;

  • Biometric information; or

  • Other highly sensitive personal information.

4. How We Use Information

We may use information to:

  • Provide and operate Referral Direct;

  • Create and maintain accounts;

  • Authenticate users;

  • Operate referral programs;

  • Connect referrals with the appropriate participating business;

  • Display referral information;

  • Track referral progress;

  • Track rewards and reward fulfillment;

  • Process and administer subscriptions;

  • Send account and service communications;

  • Send referral-program communications;

  • Provide customer support;

  • Maintain records;

  • Detect and prevent fraud, abuse, spam, and security threats;

  • Investigate suspected violations of our Terms;

  • Protect users, participating businesses, Referral Direct, and others;

  • Comply with legal obligations;

  • Establish, exercise, or defend legal claims;

  • Troubleshoot and improve the Service; and

  • Conduct internal analytics.

We may use aggregated or de-identified information for analytics, product development, operational planning, and improvement of the Service when the information does not reasonably identify an individual or Business Customer.

5. How We Disclose Information

Referral Direct does not sell personal information.

We may disclose information in the following circumstances.

A. Participating Businesses

Information associated with a particular referral program may be made available to the Business Customer operating that program.

This may allow the Business Customer to:

  • Identify a Referrer;

  • Contact a Referred Person;

  • Follow up on a referral;

  • Determine whether the referral became a customer;

  • Administer the referral program;

  • Fulfill rewards;

  • Maintain referral records; and

  • Resolve program-related issues.

Information associated with one Business Customer's referral program is not made available to unrelated Business Customers merely because they also use Referral Direct.

B. Service Providers

Referral Direct uses third-party providers to help operate the Service.

These providers may provide services involving:

  • Website hosting;

  • Cloud infrastructure;

  • Database hosting;

  • Authentication;

  • Email delivery;

  • Payment processing;

  • Security;

  • Error monitoring;

  • Technical infrastructure; and

  • Customer support.

These providers may process information as reasonably necessary to perform services for Referral Direct.

C. Legal, Security, and Safety Reasons

We may preserve, access, or disclose information when we reasonably believe doing so is necessary to:

  • Comply with applicable law;

  • Respond to lawful subpoenas, court orders, warrants, or governmental requests;

  • Investigate fraud or suspected illegal activity;

  • Protect the security or integrity of the Service;

  • Enforce our agreements;

  • Protect the rights, property, or safety of Referral Direct or others; or

  • Establish, exercise, or defend legal claims.

D. Business Transactions

If Loyalty LI LLC or Referral Direct is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar business transaction, information may be transferred or disclosed as part of that transaction, subject to applicable law.

6. We Do Not Sell Personal Information

Referral Direct does not sell personal information.

We do not rent referral-program personal information to unrelated third parties.

We do not disclose Customer Data, Referrer Data, or Referred Person Data to unrelated third parties for their independent direct-marketing purposes.

We do not use referral-program personal information for unrelated third-party targeted advertising or cross-context behavioral advertising.

7. Business Customer Data

As between Referral Direct and a Business Customer, the Business Customer retains all rights it has in customer, referrer, referral, program, and other information submitted to or processed through its account (“Customer Data”).

The Business Customer grants Referral Direct a limited right to host, process, transmit, display, secure, back up, and otherwise use Customer Data as reasonably necessary to:

  • Provide the Service;

  • Operate the Business Customer's referral program;

  • Protect the Service;

  • Prevent fraud and abuse;

  • Provide support;

  • Comply with law; and

  • Fulfill our contractual obligations.

Referral Direct does not acquire ownership of Customer Data merely because the information is processed through the Service.

Loyalty LI LLC retains ownership of Referral Direct's software, platform, systems, designs, branding, technology, documentation, and other intellectual property.

8. Business Customers' Responsibilities

Business Customers are responsible for their own collection, use, storage, and handling of personal information obtained through their referral programs.

A Business Customer may independently contact, collect information from, contract with, or conduct business with Referrers and Referred Persons.

Referral Direct does not control those independent activities.

Each Business Customer is responsible for complying with laws applicable to its:

  • Privacy practices;

  • Referral program;

  • Marketing;

  • Email communications;

  • Telephone calls;

  • Text messages;

  • Advertising;

  • Consumer disclosures;

  • Rewards;

  • Industry; and

  • Professional or licensing obligations.

If a privacy request concerns information controlled by a particular Business Customer, Referral Direct may direct the requesting person to that Business Customer and may reasonably assist the Business Customer as required by applicable law.

9. Communications

Referral Direct may send transactional, security, administrative, and service-related communications necessary to operate the Service.

These may include:

  • Account-access emails;

  • Password or security communications;

  • Referral confirmations;

  • Program information;

  • Subscription information;

  • Billing information;

  • Service notices; and

  • Customer-support communications.

Referral Direct or a participating Business Customer may also send marketing or promotional communications when permitted by applicable law.

Marketing emails sent by or through Referral Direct will include applicable unsubscribe mechanisms where required.

Business Customers are responsible for ensuring that communications they initiate through Referral Direct comply with applicable marketing and communications laws.

10. Data Retention

Referral Direct retains information for as long as reasonably necessary for the purposes for which it was collected, including to:

  • Provide the Service;

  • Maintain accounts;

  • Operate referral programs;

  • Maintain legitimate business records;

  • Comply with legal obligations;

  • Prevent fraud and abuse;

  • Resolve disputes;

  • Enforce agreements; and

  • Protect the security of the Service.

When a Business Customer terminates its account, it may request deletion or return of eligible Customer Data, subject to:

  • Reasonable technical limitations;

  • Backup retention;

  • Fraud-prevention requirements;

  • Legal obligations;

  • Security records;

  • Financial records; and

  • Information we are otherwise permitted or required to retain.

Information contained in backups may remain until those backups are overwritten or deleted through normal retention processes.

11. Data Security

Referral Direct maintains administrative, technical, and organizational measures designed to protect personal information from unauthorized access, loss, misuse, disclosure, alteration, or destruction.

However, no internet transmission, computer system, cloud service, or security program can guarantee absolute security.

Users are responsible for safeguarding their login credentials and for promptly notifying Referral Direct if they suspect unauthorized account access.

Where required by applicable law, Referral Direct will provide legally required notification following qualifying security incidents involving personal information.

12. Privacy Rights

Depending on where you reside and which laws apply, you may have legal rights concerning your personal information.

Those rights may include the ability to request:

  • Access to certain personal information;

  • Correction of inaccurate information;

  • Deletion of certain information; or

  • A copy of certain information.

Some rights are subject to legal exceptions.

We may take reasonable steps to verify a requesting person's identity before fulfilling a request.

If Referral Direct processes information solely on behalf of a Business Customer, we may direct the request to the appropriate Business Customer.

Referral Direct will not unlawfully discriminate against an individual for exercising a privacy right provided by applicable law.

Privacy requests may be sent to nick@loyaltyli.com.

13. Children

Referral Direct is intended for adults and is not designed for children under 18.

Users may not knowingly submit information concerning a minor through the Service for purposes of participating in a referral program unless the activity is lawful and Referral Direct has expressly permitted that use.

If we learn that personal information was improperly submitted concerning a child, we may delete or restrict that information.

14. United States Service

Referral Direct is currently intended primarily for businesses and referral programs operating in the United States unless Referral Direct expressly agrees otherwise.

Information may be processed in the United States or other locations in which authorized service providers operate.

15. Third-Party Websites and Services

Referral Direct may contain links to participating businesses or other websites and services that Referral Direct does not control.

Referral Direct is not responsible for the privacy, security, content, products, services, or practices of those third parties.

Information provided directly to another company is governed by that company's policies.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the Service, our practices, technology, service providers, or applicable laws.

When required, we will provide appropriate notice of material changes.

The Effective Date at the beginning of this Privacy Policy indicates when the current version became effective.

17. Contact Us

For questions, privacy requests, or concerns regarding this Privacy Policy, contact:

Loyalty LI LLC
Operator of Referral Direct
42 Jetmore Place
Massapequa, New York 11758
nick@loyaltyli.com