Is LeadsPlease Intent Data a consumer report under FCRA?

No. LeadsPlease Intent Data is licensed for marketing use — finding people — not for eligibility decisioning. This is the FCRA bright line. The EULA enforces it on every order: no underwriting, no credit decisioning, no insurance pricing, no employment screening, no tenant or housing decisions, no claims handling. If you need data for an eligibility decision, you need a consumer report under FCRA from a CRA — not a marketing data provider.

Can I use LeadsPlease Intent Data for insurance underwriting?

No — marketing only. Insurance pricing, underwriting, and claims handling all require data licensed under FCRA from a consumer reporting agency. LeadsPlease Intent Data may be used to find households likely to need insurance products and to prioritize marketing outreach — not to decide who is insurable, at what price, or whether a claim should be paid. State insurance departments in NY, CA, CO, WA further restrict use of external consumer data in insurance pricing, reinforcing the marketing-only posture.

Can I use this to decide whether to offer credit?

No — marketing only. Credit decisioning is governed by FCRA and ECOA, including adverse-action notice rights. LeadsPlease Intent Data may be used to identify households for marketing campaigns about credit products, not to decide who gets credit, at what rate, or whether to deny a credit application.

Can I use this for employment, hiring, or tenant screening?

No. FCRA requires a consumer report from a CRA for employment, hiring, and housing decisions. LeadsPlease Intent Data is marketing data and may not be used for those purposes.

Can I market to people who have opted out of data sales?

No — opt-outs are suppressed pre-delivery. CCPA/CPRA, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana opt-outs are honored across all U.S. state-level privacy laws. The federal DNC registry, prison addresses, deceased records, and your own client-supplied suppression files are also applied pre-delivery.

Do I need TCPA consent to call numbers in the file?

For automated/recorded calls and SMS — yes, express written consent is required under TCPA, with stricter state-level rules in FL, OK, WA, MD on top. The federal DNC registry is suppressed pre-delivery; client-level consent for automated outreach is your responsibility. Manual dialing of mobile or landline numbers and direct mail have different rules — consult your TCPA counsel.

What happens if a state passes a new privacy law?

LeadsPlease honors state privacy rights at delivery; the EULA flows the obligation through to clients. We track state-level privacy legislation continuously and update suppression rules pre-delivery as new laws go into effect.

Can I combine this data with credit data to make decisions?

No. The EULA contains an anti-circumvention clause: combining LeadsPlease data with other sources to derive eligibility-grade information is explicitly prohibited. The marketing-use restriction cannot be bypassed by re-scoring against credit data, employment data, or any other eligibility-grade source.

Can I resell the data?

Resale of raw signals is prohibited under the EULA. Authorized resale of scored, enriched output requires a separate reseller agreement with LeadsPlease. The Sales.Garden reseller program is the structured path for white-label resellers; contact tech@leadsplease.com for terms.

Intent Data › Permitted Use

⚖️ Compliance Reference · v1.0 · Updated 2026-05-03

Permitted use — the full reference for LeadsPlease® Intent Data.

This page is the single source of truth for what you can and can't do with LeadsPlease® Intent Data. The same canonical rules flow into the EULA, every order, every delivery surface, every vertical, and every page on this site. Plain English. Reference-grade. Marketing use only. Not a consumer report under FCRA.

The short statement

Marketing use only. Not for eligibility decisions, underwriting, pricing, or claims.
Licensed for finding people — for direct mail, email, phone, SMS, digital ad targeting, lookalike modeling, CRM enrichment, and marketing-prioritization scoring.
Not a consumer report under FCRA. Eligibility decisioning requires a CRA-issued report.
EULA-enforced on every order. Anti-circumvention applies: no combining with other sources to derive eligibility-grade information.

Allowed uses

Allowed use	Notes
Direct mail, email, phone, SMS, digital ad targeting	Subject to channel-specific consent and compliance rules (TCPA for phone/SMS, CAN-SPAM for email, state-level privacy rights).
Lookalike modeling for marketing audiences	Use the Intent Propensity Score and demographic enrichment to model audiences resembling your converted customers.
CRM enrichment for marketing segmentation	Append the score and intent_category to existing CRM records via SHA256 hashed-email match — for segmentation and outreach prioritization, not for eligibility scoring.
Suppression matching against your existing customer base	Upload your customer file as a suppression key file so existing customers are excluded from prospecting drops.
Marketing prioritization (not eligibility scoring)	Decide which households to mail, call, email, or target with digital ads first. The Intent Propensity Score is a marketing prioritization tool, not an eligibility score.

Prohibited uses

Prohibited use	Reason
Underwriting, credit decisioning, insurance pricing, or claims handling	FCRA — eligibility decisioning requires a consumer report from a CRA with adverse-action notice rights, dispute procedures, and accuracy standards. LeadsPlease® Intent Data is not a consumer report.
Employment, hiring, tenant screening, or housing decisions	FCRA — same boundary. Decisions about a person's eligibility for employment or housing require a CRA-issued consumer report.
Direct marketing to children under 13	COPPA — the Babies & Children signal category targets the parent or caregiver, never the child. No outreach may be directed to minors under 13.
Reselling raw signal data	EULA — the scored, demographically-enriched output is licensable. Raw upstream behavioral signals are not. Resale of the scored output requires a separate reseller agreement.
Reverse-engineering or replicating the Intent Propensity Score	EULA — the scoring model is proprietary. Attempting to derive or replicate the model from delivered output is prohibited.
Combining the data with other sources to derive eligibility-grade information	EULA anti-circumvention clause — the marketing-use restriction cannot be bypassed by re-scoring against credit, employment, or any other eligibility-grade source.

Channel rules

Phone

The federal Do Not Call (DNC) registry is suppressed pre-delivery on every order. Client-level consent for outbound calls — especially automated/recorded calls — is the client's responsibility under TCPA. State-level rules in FL, OK, WA, MD apply on top.

SMS

Express written consent is required for SMS marketing under TCPA. Stricter state-level rules apply in FL, OK, WA, MD. The federal DNC registry suppression applies to mobile numbers as well.

Email

CAN-SPAM compliance is the client's responsibility on send: clear sender identity, honest subject line, valid postal address, and a working unsubscribe mechanism in every commercial email.

Mail

No federal consent requirement for direct mail. LeadsPlease® applies DNC, prison, deceased, and client-supplied suppression files pre-delivery. State-level solicitation rules in CA, NY, TX may apply for specific verticals.

Industry-specific rules

Insurance

Marketing use only. LeadsPlease® Intent Data identifies households likely to need insurance products — for outreach and targeting. It is not used for underwriting, pricing, or claims handling. Several state insurance departments (NY, CA, CO, WA) restrict use of external consumer data in insurance pricing, which reinforces the marketing-only posture. Eligibility decisions remain with your underwriting team and require a consumer report from a CRA.

Mortgage

Marketing use only. May be used to identify households for marketing campaigns about credit products — not to decide who gets credit, at what rate, or whether to deny a credit application. ECOA prohibits use of protected-class proxies (age, gender, ethnicity) in credit decisioning. Mortgage trigger-lead rules (24-hour post-credit-pull restrictions) are the client's responsibility.

Medicare

Marketing use only. LeadsPlease® identifies Medicare-eligible households with relevant interest signals for outreach. CMS Medicare Marketing Guidelines — licensed agents, scope-of-appointment forms, unsolicited-contact limits, prohibited language and disclaimers — govern your outreach and remain your responsibility.

Health & Wellness

Marketing use only. Health & Wellness signals describe consumer interest, not medical conditions or diagnoses. LeadsPlease® is not a HIPAA-covered entity, but several state privacy laws require opt-in consent for sensitive categories — that obligation is flowed through to clients via the EULA.

Privacy rights & suppression

Consumer privacy rights are honored across all U.S. states with applicable laws. Opt-outs are suppressed pre-delivery. Coverage includes California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, plus 12+ other states with comprehensive privacy statutes. New state laws are tracked continuously and suppression rules update pre-delivery as they take effect.

Pre-delivery suppression includes:

Federal DNC registry — on every order
Prison addresses — correctional-facility records suppressed
Deceased records — death-record-flagged households suppressed
Client-supplied suppression — existing customers, prior responders, churned accounts — uploaded as a CSV match-key file
State opt-out registries — CA/CPRA, VA, CO, CT, UT, TX, OR, MT, plus emerging-law states

Matching & privacy

SHA256 lowercase hashed email (HEM) is the primary join key between LeadsPlease® and upstream signal providers. PII never moves between systems in the clear. Plaintext PII is reconstituted only at the LeadsPlease® delivery boundary, where it's joined to the household graph for the final enriched output.

Three additional match keys are supported as fallback: name + postal address, phone number, email address. Most CRM appends use SHA256 HEM as the join because it works without exchanging plaintext PII between systems.

EULA attestation

Every order requires acceptance of the LeadsPlease® End-User License Agreement, which contractually restates the permitted-use boundaries above. The EULA is the mechanism that makes the marketing-only restriction enforceable; combined with hashed-email privacy and pre-delivery suppression, it forms the LeadsPlease® compliance posture end-to-end.

⚖️ Bottom line

Marketing use only. Not for eligibility decisions, underwriting, pricing, or claims. If you need data for any decision about a person (credit, insurance, employment, housing), you need a consumer report under FCRA from a CRA — not a marketing data provider. Every LeadsPlease® Intent Data delivery, on every channel, flows under this same restriction.