Lead Desk Privacy Policy

Lead Desk (also shown as IBI CRM)

Operated by immigration by investment (DBA) - Immigration Diligence LLC

Effective date: October 9, 2026

Last updated: October 9, 2026

This Privacy Policy explains how personal data is collected, used, shared, kept and deleted in Lead Desk, a tool for managing inquiries, at https://ibicrm.com. In the Zoom App Marketplace and other services we connect to, Lead Desk appears as IBI CRM.

Lead Desk is used by:

• IBI staff ("Admins"); and
• Advisors: independent advisory firms, and the people who sign in for them, who work with the inquiries IBI introduces to them. Each Advisor has its own separate workspace and sees only the inquiries that belong to it.

This Policy also covers the people whose data Lead Desk holds: people who send an inquiry about residence or citizenship by investment ("Leads"), and anyone else who takes part in a consultation meeting.

Questions: contact@immigrationbyinvestment.com (section 16).

1. Who we are and who is responsible

1.1 Who runs Lead Desk

Lead Desk is run by immigration by investment (DBA) - Immigration Diligence LLC. This means Immigration Diligence LLC, doing business as "immigration by investment" ("IBI", "we", "us"). IBI is an independent advisory firm. It helps families get residence permits and second citizenship through investment programs.

• Website: https://www.immigrationbyinvestment.com
• Email: contact@immigrationbyinvestment.com

1.2 Who is responsible for your data

In plain terms:

• Inquiries belong to Advisors. When IBI assigns your inquiry to an Advisor, it belongs to that Advisor. From then on, the Advisor decides how to work with you, and is responsible for your data in Lead Desk; the legal terms for this are "controller" or "business".
• Each Advisor is responsible for its own meetings. This includes deciding whether a consultation is recorded, telling the people taking part, and getting their agreement where the law requires it (section 6).
• IBI runs Lead Desk for the Advisor. IBI hosts the Advisor's inquiries in Lead Desk and handles them on the Advisor's behalf, to provide, support and secure Lead Desk.
• IBI's own uses. IBI is also responsible for its own uses of your data, before and after your inquiry is assigned. For these uses, IBI is a controller too:
  • its own record of the inquiry it collected. IBI keeps it even if the Advisor asks for the Advisor's data to be deleted (section 10);
  • choosing the Advisor, and moving an inquiry to a different Advisor;
  • following up on the inquiries it introduces, and checking the quality of the service. For this, IBI staff can see calls, messages, consultations, transcripts and AI reviews, including the AI feedback on how a call or consultation was conducted;
  • calls and messages that IBI staff themselves have with you;
  • alerts to IBI's own team (section 4.8);
  • accounts, security and logs, and what the law requires.
• If IBI moves your inquiry to a different Advisor, the new Advisor is responsible for it from then on. The previous Advisor stays responsible for the records it created (its calls, messages, bookings and consultations). It loses access to them, and only IBI staff can still see their content.
• Payment. Advisors do not pay for Lead Desk. They pay IBI only for the inquiries IBI introduces to them, under separate agreements with IBI.
• Your requests. Send every request about your data in Lead Desk to us, whoever is responsible for it. If you write to the Advisor instead, the Advisor forwards it to us. Section 12 explains how we handle it.

2. Summary

• What Lead Desk holds:
  • the inquiry you sent IBI;
  • records made when IBI or an Advisor communicates with you, such as calls, text messages, emails and meetings;
  • data from tools an Advisor chooses to connect, such as Calendly or Zoom.
• What it is used for:
  • responding to your inquiry and choosing the Advisor best suited to help you;
  • scheduling and holding consultations;
  • AI-assisted summaries and feedback on calls and consultations, for the Advisor and IBI staff.
• Who can see it: IBI staff, and the Advisor your inquiry currently belongs to. Advisors never see each other's inquiries.
• What we do not do:
  • We do not sell the records Lead Desk creates about you, such as call recordings, transcripts, messages and reviews.
  • We do not use any Lead Desk data for advertising.
  • We do not use it to train AI models. Section 5 explains what our AI provider does with it.
• Connected meeting accounts. Zoom and Google are available when IBI switches them on; Microsoft is planned. Data from a connected account is used only for the consultation features: for the Advisor who connected it, and for IBI Admins to follow up on and check the quality of that Advisor's consultations (sections 7 and 8).
• Disconnecting Zoom. If an Advisor disconnects Zoom, removes our app in Zoom or switches to a different Zoom account, we delete at once the transcripts, reviews and Zoom recording IDs it brought in, and everything we stored about the Zoom account (section 7.6). After an unsigned removal notice, we delete once Zoom confirms the removal, normally within about an hour.
• Disconnecting Google. If an Advisor disconnects Google in Lead Desk or switches to a different Google account, we delete at once the Meet transcripts, reviews and Meet conference IDs it brought in, and everything we stored about the Google account. Consultations from the Advisor's Google Calendar stay as bookings. Removing our access in the Google account alone deletes nothing (section 8.2).
• How long we keep data. Consultation transcripts and their AI reviews are deleted automatically 365 days after the meeting by default. Inquiries, calls, messages, notes and accounts are kept until someone asks for them to be deleted. A few other items expire sooner, and an SMS opt-out is kept even after a deletion request, so that we keep honoring it (section 10).
• Your requests. To ask for access, correction or deletion, write to contact@immigrationbyinvestment.com (section 12).

3. Information Lead Desk holds

3.1 Leads (people who send an inquiry)

Booking links. When you open a booking link that points to Calendly or Cal.com, your name and email are pre-filled on the scheduler's page, so that scheduler receives them. This happens even if the Advisor has not connected a Calendly account. The link also carries a short reference code, so that the booking can be matched to your inquiry. Links to other schedulers open without your details. Pre-filling stops 30 days after the link is sent, and IBI can switch it off.

3.2 Admins and Advisors

3.3 Other meeting participants

A consultation transcript contains the display name and the words of everyone who spoke in the meeting.

3.4 Cookies and similar technologies

Lead Desk uses only what it needs to work:

• ibi_session keeps you signed in. It lasts 30 days and is HttpOnly, Secure and SameSite=Lax.
• ibi_oauth is an encrypted cookie used only while you connect an external account. It expires after 10 minutes and works only once.
• Browser local storage remembers when you last opened the notifications panel.

Lead Desk has no analytics, advertising or tracking cookies or pixels. This includes its public pages, such as this one.

4. How the data is used

Who is responsible for each use follows section 1.2:

• IBI is responsible until your inquiry is assigned to an Advisor.
• After that, the Advisor is, and IBI handles the data on the Advisor's behalf.
• IBI stays responsible for its own uses at every stage: choosing the Advisor (4.1), its own calls and messages with you (4.2 and 4.4), following up on inquiries and checking quality (4.4 and 4.6), alerts to its own team (4.8), and 4.9 and 4.10.

For people in the EEA, the UK and similar places, the legal basis is given after each use. The party responsible for a use relies on that basis.

4.1 Handling your inquiry and choosing an Advisor

We use your inquiry to contact you, to understand your goals and to decide which Advisor is best suited to help you. IBI staff choose the Advisor; the AI does not. IBI is responsible for this use.

Legal basis: steps you asked for before a contract; legitimate interests.

4.2 Communicating with you

IBI and, once your inquiry is assigned, the Advisor contact you by phone, SMS and email through Lead Desk. They also send booking links and follow-ups.

• Our first automated text message says that you can reply STOP to opt out. You can reply STOP to any of our texts. After that, we no longer text your number, and our AI assistant no longer calls you about the inquiries you sent before. If you ask us by text only to stop texting and to call you instead, we stop the texts, but our AI assistant may still call you. A reply of STOP does not stop calls from IBI staff or the Advisor; to stop those, tell them or write to contact@immigrationbyinvestment.com. Replying START turns texts back on and lets our AI assistant call you again about those inquiries, unless you also asked IBI or the Advisor another way not to be contacted.
• To stop emails, reply to any of our emails and ask us to stop, or write to contact@immigrationbyinvestment.com.

Legal basis: steps before a contract; legitimate interests; consent where the law requires it.

4.3 AI voice assistant calls

After you send an inquiry, an automated AI voice assistant may call you to confirm your details and understand your needs. The call is recorded and transcribed, and a summary is made.

Legal basis: legitimate interests; consent where the law requires it.

4.4 Calls with IBI staff or Advisors

IBI staff and Advisors can call you through Lead Desk. These calls are recorded (both sides) and transcribed. IBI staff can review every such call. An Advisor can review its own calls while your inquiry belongs to it.

Lead Desk does not play a recording notice to you. The message "This call may be recorded" is heard only by the person who is calling you, before the call to you is placed. The person who calls you tells you that the call is recorded, and gets your agreement where the law requires it: IBI on its own calls, and the Advisor on the Advisor's calls.

Legal basis: legitimate interests; consent where the law requires it.

4.5 Scheduling

We use booking and meeting data to schedule consultations, show them on your record, and stop automated calls once you have booked.

Legal basis: steps before a contract; legitimate interests.

4.6 Consultation reviews

A consultation transcript can be added to Lead Desk only after the Advisor confirms that the participants were told and agreed (section 6). It is then used to produce an AI review for the Advisor and IBI staff (section 5). The Advisor is responsible for the review of its own consultation. IBI is responsible for its own use of reviews: following up on the inquiries it introduced, and checking the quality of the service.

Legal basis: consent, as confirmed by the Advisor; legitimate interests in the quality of the service.

4.7 Lead reports

We create AI-assisted summaries of inquiries to help decide the next steps.

Legal basis: legitimate interests.

4.8 Alerts

Important events are shown in Lead Desk. They may also be sent:

• to IBI's internal Telegram group;
• to an Advisor's own Telegram (only events on that Advisor's inquiries);
• as browser push notifications.

Events that trigger an alert include a new inquiry, a reply from you, a call summary, and a consultation readiness score. An alert can include your name and the text of a message you sent. Alerts never include consultation transcript text. IBI is responsible for the alerts to its own team.

Legal basis: legitimate interests.

4.9 Security and legal compliance

We verify incoming webhooks, limit sign-in attempts, keep logs, and meet our legal obligations.

Legal basis: legitimate interests; legal obligation.

4.10 Providing Lead Desk to Advisors

We provide accounts and workspaces, and connect the tools each Advisor chooses. IBI is responsible for this.

Legal basis: our agreement with the Advisor.

We do not:

• sell the records Lead Desk creates about you to anyone, such as call recordings, transcripts, messages and consultation reviews;
• share Lead Desk data for cross-context behavioral advertising (as California law uses that term), use it for advertising, or show ads in Lead Desk;
• use personal data to train or improve AI or machine-learning models. This includes data from Zoom, Google or Microsoft.

5. AI processing

We use AI models from Anthropic, PBC (USA), the maker of Claude, through Anthropic's commercial API. We use them for three things:

• Lead reports. The model receives your name, email, phone number, form answers, and the transcript and summary of the AI assistant call.
• Call summaries and reviews. The model receives the call transcript (up to about 12,000 characters) and the caller's call notes (IBI staff or the Advisor).
• Consultation reviews.
  • The model receives your name, program of interest and motivation; the meeting's time, platform and length; and the full transcript.
  • It returns a summary, an assessment of the Lead's readiness and concerns, the agreed next steps, and feedback for the Advisor.
  • The review runs automatically when a transcript is uploaded or imported. If it fails or never arrives, the Advisor or an Admin can run it again.

How Anthropic handles this data:

• We use Anthropic's commercial API. Under Anthropic's Commercial Terms, Anthropic may not train its AI models on this content.
• By its published policy, Anthropic automatically deletes API inputs and outputs from its systems within 30 days. It may keep them longer where the law requires it, or to enforce its Usage Policy. For example, content flagged by its automated safety systems may be kept for up to two years.
• The summaries and reviews we receive are stored in Lead Desk and kept as section 10 describes.
• For details, see https://www.anthropic.com/legal/commercial-terms and https://privacy.claude.com.

How we use the results:

• For lead reports and consultation reviews, our instructions tell the model to treat what participants say as material to review, not as instructions to follow.
• AI reviews can be wrong. They help Advisors and IBI staff, and are not a final judgment about anyone.

6. Recording and consent

Each Advisor is responsible for its own consultations. It decides whether to record them, tells everyone taking part, and gets their agreement where the law requires it. Lead Desk adds these safeguards:

• Uploaded transcripts.
  • An Advisor can upload a transcript only for a consultation marked as held.
  • Each time, the Advisor must confirm that everyone on the call was told it was recorded and agreed to the recording and its AI analysis. Without that confirmation, the upload is refused.
• Imported transcripts. Imports from Zoom and Google Meet are available when IBI switches them on; imports from Microsoft Teams are planned.
  • Importing stays off until the Advisor confirms, for their connected account, that everyone on their consultations is told the meeting is recorded and agrees to the recording and its AI analysis. For Google Meet, the Advisor confirms that everyone is told the meeting is transcribed and agrees to the transcript and its AI analysis.
  • The confirmation covers only recordings that start after it was given. Earlier recordings are never imported. For Google Meet, it covers only consultations that start after it was given.
  • The Advisor can turn importing off at any time. If they turn it on again, it covers only recordings from that moment on.
  • The confirmation is cleared when the Advisor disconnects Zoom, removes our app in Zoom, or connects a different Zoom account. For Google, it is cleared when the Advisor disconnects Google in Lead Desk or connects a different Google account. The Advisor must then give it again.
  • Zoom also shows participants that a meeting is being recorded. What exactly it shows depends on the host's Zoom settings.
• If someone does not agree. If a participant does not agree to the recording or its AI analysis, the Advisor must not record or transcribe the meeting. If a transcript of such a meeting reaches Lead Desk anyway, the Advisor or IBI can remove it. You can also ask us to delete it.
• Your choices. If you do not want a consultation recorded or analyzed, tell the Advisor before or during the meeting. You can ask us to delete a transcript at any time (section 12).

7. Zoom

The IBI CRM app for Zoom is optional, and it is for Advisors. An Advisor connects its own Zoom account under Integrations in Lead Desk. Only Advisors connect Zoom; IBI Admins only switch the integration on or off for everyone. If you start from the Zoom App Marketplace ("Add"), we send you through the Connect step in Lead Desk. If you are not signed in to Lead Desk at that point, we ask you to sign in first, and Lead Desk then continues to Connect Zoom by itself.

After a consultation with one of your Leads is held in Zoom and recorded to the Zoom cloud with an audio transcript, the transcript is added to that consultation and reviewed by AI. You do not have to upload it.

This needs a licensed (paid) Zoom user, such as Pro, Business, Education or Enterprise, with cloud recording and "Create audio transcript" switched on. The Integrations page shows a checklist for these three things. We refresh it when you connect, once a day, and when you click "Check again".

The Advisor who connected Zoom is responsible for the data it brings in, because that data belongs to the Advisor's own consultations (section 1.2). IBI uses Zoom data only within this feature as this section describes, including what IBI Admins can see (section 7.3), and for nothing else.

7.1 What we access

We also receive Zoom's notice when you remove the app, so that we can delete your data (section 7.6).

What we do not access or keep:

• We download only the audio transcript (VTT) files of a recording, and only for a recording that matches one of your consultations (section 7.2). We never download audio, video, chat files or Zoom AI Companion content.
• We do not store Zoom's notifications, its temporary download tokens or its download links.
• Every permission is read-only. We do not create, change or delete anything in your Zoom account. The only change we ever ask Zoom to make is to revoke our own access. We do that when you disconnect, when you switch to a different Zoom account, and when we refuse a connection that lacks the access we need.

7.2 How we use Zoom data

We use Zoom data only for the consultation-transcript feature: to give the Advisor who connected Zoom the transcript and AI review, and to let IBI Admins follow up on and check the quality of that Advisor's consultations (section 7.3).

Which recordings:

• We process only recordings of meetings that you host.
• We import a transcript only after you have confirmed participant consent, and only from recordings that started after you confirmed (section 6).
• Nothing is imported while your Lead Desk account is deactivated, or while IBI has the Zoom integration switched off.

Matching a recording to a consultation:

• We look only at your own consultations booked within 30 minutes before or after the recording's start.
• If one of them was booked with the same Zoom meeting number, the recording belongs to that one. If there are several, it belongs to the nearest.
• Otherwise, it belongs to a consultation only if exactly one in that window could be this Zoom meeting. That means one booked as a Zoom meeting or with no platform set, and with no other meeting number on file.
• Consultations booked on Google Meet, Microsoft Teams, by phone or with another meeting link never receive a Zoom recording.
• If the match is not clear, nothing is imported.

When a recording is not imported:

• The consultation a recording belongs to takes it only if the Lead still belongs to you and the consultation is scheduled or held (not canceled or marked as a no-show). Otherwise the recording is not imported anywhere, and it never goes to a different consultation.
• Each consultation takes one recording: the first one imported. If the recording was stopped and restarted, its parts are joined into one transcript.
• An imported transcript never replaces one you uploaded by hand.
• A Zoom transcript you removed, or replaced with your own upload, is not imported again. This also holds if you later remove that upload (section 7.5).
• Nothing is imported for a consultation that is already past the retention period (section 7.5).

Recordings that match no consultation:

• We do not download them.
• We only count them, so that the Integrations page can show you how many were skipped.
• To count each one only once, we keep a short one-way code (a hash) made from the recording's Zoom ID, for the latest 100 such recordings.

What we store, and what happens next:

• We store the transcript as text: speaker names as Zoom shows them, what was said, and when.
• We also store the Zoom recording ID on the consultation, so that the same recording is not imported twice.
• We do not keep the transcript file itself.
• If the consultation was still marked as scheduled and its start time has passed, it is marked as held.
• We then create the AI review described in section 5.

Daily check. Once a day we refresh the readiness checklist. While importing is on, we also look through your cloud recordings since the last check for transcripts whose notification we missed.

We never sell Zoom data, never use it for advertising, and never use it to train AI models.

7.3 Who can see it

• You (the Advisor): you see transcripts and reviews, but only while the Lead belongs to you.
• IBI Admins: Admins see transcripts and reviews. An Admin can hide a transcript's text from you. You then still see the review, but without verbatim quotes. Admins also see the status of your Zoom connection and the Zoom name and email it uses.
• After reassignment: if the Lead is moved to another Advisor, you lose access. The new Advisor sees only that the meeting took place (its date and status), not the transcript or the review.
• Other Advisors never see it.
• Alerts: when a review is ready, a short alert goes to the IBI team, and to you while the Lead belongs to you.
  • It contains the Lead's name, a readiness score and a short label, and never transcript text. In Lead Desk, the alert also stores the mood the review found.
  • It appears in Lead Desk, and in Telegram and browser push where these are switched on.

7.4 Who we share it with

• Anthropic, for the AI review (section 5);
• our hosting and database providers (section 9);
• for the short alert only: Telegram and browser push services.

We share Zoom data with no one else, except where the law requires it (section 9.3).

7.5 How long we keep it

• Transcripts, AI reviews and Zoom recording IDs:
  • Kept 365 days after the meeting by default. An IBI Admin can set any period from 30 to 3,650 days.
  • When the period ends, they are deleted automatically. The meeting's date and status remain.
  • They are deleted earlier when the Zoom connection closes: when you disconnect Zoom, remove our app in Zoom, or switch to a different Zoom account (section 7.6).
• A Zoom transcript you remove, or replace with your own upload:
  • If you remove it, the transcript and its review are deleted at once. Alerts about that review in Lead Desk lose their readiness score, label and mood.
  • If you replace it, your upload takes its place and the old review is deleted at once. Alerts about the old review in Lead Desk lose their readiness score, label and mood; the new review sends its own alert once it is ready. Your upload stays, even after the Zoom connection closes (section 7.6).
  • Either way, the only Zoom data we keep on that consultation is the Zoom recording ID, so that the same recording is not imported again, even if you later remove your upload.
  • That ID is deleted when the Zoom connection closes or when the retention period ends, whichever comes first. It never outlasts the Zoom connection.
• Access tokens: encrypted, and kept only while Zoom stays connected.
• Your Zoom account details and settings: kept only while Zoom is connected. These are your user ID, name, email, account ID, user type, readiness results, consent confirmation and import counters.

7.6 Disconnecting and deleting Zoom data

You can stop at any time:

• Turn off importing: Integrations, Zoom, "Turn off". Zoom stays connected, but nothing new is imported. If you turn it on again, only recordings from that moment on are imported.
• Disconnect in Lead Desk: Integrations, Zoom, Disconnect.
• Remove the app in Zoom: Zoom App Marketplace, Manage, Added Apps, IBI CRM, Remove.

You can turn importing off or disconnect even while IBI has the Zoom integration switched off.

When you disconnect in Lead Desk:

1. We ask Zoom to revoke our access. We delete our access and refresh tokens whether or not Zoom confirms.
2. We delete everything we stored about your Zoom user: user ID, name and email, Zoom account ID, user type, the permissions you granted, readiness results, your consent confirmation, and the import counters, including the codes kept for unmatched recordings.
3. At the same time, we delete every transcript and AI review that came from that Zoom connection, and every Zoom recording ID on your consultations, including those kept where you had removed a Zoom transcript or replaced it with an upload. Alerts about those reviews in Lead Desk lose their readiness score, label and mood.

When you connect a different Zoom account, the previous one is first disconnected in the same way.

When you remove the app in Zoom, Zoom revokes our access and sends us a notice. When we receive it, we erase our access and refresh tokens and delete at once the same data as in steps 2 and 3. This also works while your Lead Desk account is deactivated, while the connection shows "Needs reconnecting", and while IBI has the Zoom integration switched off.

• Zoom sometimes sends this notice without its signature. In that case we first check with Zoom that our access has really been revoked, so that a forged notice cannot delete anything while Zoom still accepts our access.
• If Zoom has not confirmed it yet, we check again automatically about an hour later, and keep checking until it is settled. If Zoom still accepts our access at that point, the app was not removed and nothing is deleted.
• A notice about a removal made before you connected again is ignored.

If something fails: if a deletion step fails, it is retried automatically within minutes. A removal notice that could not be completed at once is completed by the automatic check about an hour later.

What remains afterwards:

• the consultation itself, with its date and status;
• a record that your account had a Zoom connection — when it was made and closed, and why — with no Zoom identity, settings or tokens;
• in the activity history, the fact that a review was made (without its readiness score, label or mood), and that Zoom was connected and disconnected. These entries show names in Lead Desk (yours, and the Lead's for a review), never your Zoom details;
• alerts already delivered to Telegram or a browser. We cannot recall them, but they never contain transcript text;
• transcripts you uploaded by hand, including one that replaced a Zoom transcript. They are not Zoom data, so disconnecting does not delete them (only the Zoom recording ID kept with a replaced one is deleted, in step 3). They follow the retention period in section 7.5.

Disconnecting does not affect recordings stored in your Zoom account. To ask us to delete specific Zoom data at any time, write to contact@immigrationbyinvestment.com.

8. Other connected services

8.1 Calendly

If an Advisor connects Calendly:

• What we read: the Advisor's event types and bookings, and each invitee's name and email. We use them to attach bookings to the Advisor's own inquiries.
• What we can do: when the Advisor or an Admin cancels a booking or marks a no-show in Lead Desk, we pass that to Calendly.
• Unmatched bookings: bookings that match none of the Advisor's inquiries are deleted 30 days after they were created, once the event is more than a day in the past.
• Disconnect: we delete the webhook subscription, ask Calendly to revoke the token, and erase the stored tokens. Meetings already imported stay with the inquiry; their stored booking details (such as the invitee's email) are cleared when the retention period in section 10 ends.

8.2 Google Calendar and Google Meet

The Google integration is optional, and it is for Advisors. It is switched off by default. IBI can switch it on for all Advisors or only for some. An Advisor connects its own Google account under Integrations in Lead Desk, on the Google Meet & Calendar card. IBI Admins do not connect Google accounts. On Google's screens, Lead Desk appears as IBI CRM.

With it, a consultation held in Google Meet gets its transcript and an AI review, and consultations on the Advisor's Google Calendar with one of their Leads appear on that Lead.

Before you connect. Lead Desk first shows a short statement of what it does with your Google data, and you agree to it. You see it every time before Google's consent screen: to connect, to reconnect, and to grant access you did not grant before. We record which version you agreed to, and when.

Each part needs its own access. On Google's screen you can allow Meet access and Calendar access separately. Each part works only with its own access. You can grant the other one later from the card.

The Advisor who connected Google is responsible for the data it brings in, because that data belongs to the Advisor's own consultations (section 1.2). IBI uses Google data only within this feature, as this section describes, and for nothing else.

What we access:

We also ask Google to notify us when the events on your primary calendar change. A notice says only that something changed. We then read the changes with your access.

What we do not access or do:

• We do not request access to Google Drive, Google Docs or Gmail, or to the settings of your meeting spaces.
• We never download recordings, audio or video, or any file from Google Drive.
• We read only your primary calendar.
• All the access we request is read-only. We never create, change or delete events, meetings or settings in your Google account. Besides reading, we only ask Google to start and stop the notifications about your calendar, and to revoke our own access.

Google Meet transcripts:

• We look only for your own consultations on Leads assigned to you now, booked on Google Meet with a meeting code. For example, a consultation booked through Calendly with Google Meet, one marked as booked with a Meet link, or one from your Google Calendar.
• We import a transcript only after you have confirmed participant consent, and only for consultations that started after you confirmed (section 6).
• Google lists only the calls that your connected Google account organized. We use only the records of the consultation's meeting code from 30 minutes before its start to 30 minutes after its end.
• A record belongs to the consultation only if, among your consultations booked with that meeting code within 30 minutes of the record's start, this one is the nearest. If two are equally near, nothing is imported. A record that starts later in the booked time, no more than 10 minutes after the matched part of the call ended, joins it (for example when people leave and rejoin), unless another of your consultations could be that call.
• For records that belong to none of your consultations, we read nothing more and keep nothing.
• We look from 10 minutes after the consultation ends, at growing intervals. We stop once the transcript is imported or it is clear there is none, and at the latest 30 days after the consultation started.
• Nothing is imported while your Lead Desk account is deactivated, while IBI has Google switched off for you, or while the connection needs reconnecting. Nothing is imported for a consultation that is canceled or marked as a no-show, whose Lead is no longer yours, that already has a transcript, or that is past the retention period.
• A Meet transcript you removed, or replaced with your own upload, is not imported again. A transcript too short or too long to review is not imported.

What we store from a call:

• the transcript as text: speaker names as Google Meet shows them, what was said, and when;
• the Meet conference ID on the consultation, so that the same call is not imported twice.

We do not keep the list of participants, their Google user IDs, or anything else from the call. If the consultation was still marked as scheduled and its start time has passed, it is marked as held. We then create the AI review described in section 5.

Google Calendar:

• We use only events you organize. We skip all-day events, events that are not meetings (such as out of office or focus time), and events without guests.
• We compare the guests' email addresses with the emails of the Leads assigned to you now. Your own address, rooms and guests who declined are left out. We store only events whose guest is one of those Leads. Other events are not stored, and nothing about them is kept.
• A matching event becomes a consultation on that Lead. Like any booking, it marks the Lead as booked and stops automated calls (section 4.5).
• For it we store the time and time zone, the call link and meeting code (Google Meet, Zoom or Microsoft Teams), the Lead's email, Google's ID for the event, when the event last changed, and whether it repeats. We never read event titles, and we do not store the other guests.
• New consultations are added for events from the day before up to a year ahead. When an event is moved, a scheduled consultation moves with it. When the event is deleted, the Lead declines it, or the Lead is removed from its guests, a scheduled consultation is canceled. If the event is restored, or the Lead is a guest again, it is booked again.
• If the same call also comes through Calendly, Calendly's booking is the consultation: the calendar's copy is not added, or is canceled if it came first. If Calendly's booking has no meeting code yet, it takes the event's meeting code (and its call link, if it has none), which then stay on that booking.
• The first sync after you connect adds what is already on your calendar, without alerts.
• Besides Google's notices, we check your calendar every 3 hours (every 15 minutes while the notices are not working), and go through it from yesterday to 60 days ahead once a day.
• Lead Desk cannot change your calendar. While your calendar syncs, you cancel such a consultation by deleting the event in Google Calendar. A consultation that is not synced (for example after you disconnect or switch Google accounts, while Google refuses access to your calendar, or after its event becomes all-day or is no longer organized by you) stays booked, and you cancel it in Lead Desk.
• If the Lead is moved to another Advisor, a consultation already added from your calendar stays yours and keeps following your calendar. Alerts about it then go only to IBI Admins.

Who can see it:

• You (the Advisor): you see transcripts, reviews and the consultations from your calendar, but only while the Lead belongs to you.
• IBI Admins: Admins see them too, and where the search for each Meet transcript stands. An Admin can hide a transcript's text from you. You then still see the review, but without verbatim quotes. Admins also see the status of your Google connection and the Google email it uses.
• After reassignment: if the Lead is moved to another Advisor, you lose access. The new Advisor sees only the consultation's date, status and platform, not its link, transcript or review.
• Other Advisors never see it.
• Alerts: when a consultation from your calendar is booked, moved or canceled, or a review is ready, a short alert goes to the IBI team, and to you while the Lead belongs to you.
  • It contains the Lead's name and the consultation's time and platform, or a readiness score and a short label. It never contains transcript text. In Lead Desk, a review alert also stores the mood the review found.
  • It appears in Lead Desk, and may also be sent to Telegram and browser push where these are switched on.

Who we share it with:

• Anthropic, for the AI review (section 5);
• our hosting and database providers (section 9);
• for the short alerts only: Telegram and browser push services.

We share Google data with no one else, except where the law requires it (section 9.3).

Limited Use. IBI CRM's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular:

• We use Google user data only to provide the calendar-matching and consultation-transcript features shown in Lead Desk.
• We transfer Google user data only:
  • to the service providers needed for those features (hosting, database, the AI review in section 5, and the short alerts sent through Telegram and browser push services);
  • when needed for security or to comply with the law;
  • as part of a merger or acquisition, with notice to users.
• We do not use or transfer Google user data for advertising, and we do not sell it.
• We do not use Google user data to develop, improve or train AI or machine-learning models. Our AI provider's terms do not allow it to train on this data either (section 5).
• People do not read Google user data, except:
  • with the user's agreement;
  • when necessary for security;
  • when necessary to comply with law;
  • in aggregated, anonymized form for internal operations.
• Showing transcripts and reviews to the connecting Advisor and to IBI Admins is part of the feature the Advisor agrees to when connecting.

How long we keep it:

• Meet transcripts, AI reviews and Meet conference IDs:
  • Kept 365 days after the meeting by default. An IBI Admin can set any period from 30 to 3,650 days.
  • When the period ends, they are deleted automatically. The meeting's date and status remain.
  • They are deleted earlier when the Google connection closes: when you disconnect Google in Lead Desk, or switch to a different Google account.
• A Meet transcript you remove, or replace with your own upload: the transcript and its review are deleted at once, and alerts about that review in Lead Desk lose their readiness score, label and mood. We keep only the Meet conference ID, so that the call is not imported again, until the Google connection closes or the retention period ends.
• Consultations from your calendar: kept with the Lead, like other bookings (section 10). When the retention period ends, the Lead's email on them and what we keep about the event (when it last changed, whether it repeats) are deleted. The consultation itself remains.
• Access tokens, and the secret of the calendar notifications: encrypted, and kept only until the Google connection closes.
• Your Google account details and settings: kept only until the Google connection closes. These are your account ID, email and Workspace domain, the access you granted, your agreement to our statement, your consent confirmation, the calendar sync state, and the results of the last checks.

Disconnecting and deleting Google data. You can stop at any time, also while IBI has Google switched off for you:

• Turn off importing: Integrations, Google Meet & Calendar, "Turn off". Google stays connected and your calendar still syncs, but no new transcript is imported. If you turn it on again, only consultations that start after that are imported.
• Disconnect in Lead Desk: Integrations, Google Meet & Calendar, Disconnect.

When you disconnect in Lead Desk:

1. We ask Google to stop the notifications about your calendar and to revoke our access. We delete our access and refresh tokens, and the secret of the notifications, whether or not Google confirms.
2. We delete everything we stored about your Google account: the details listed above under "Your Google account details and settings".
3. At the same time, we delete every Meet transcript and AI review that came from that Google connection, and every Meet conference ID on your consultations, including those kept where you had removed or replaced a Meet transcript. Alerts about those reviews in Lead Desk lose their readiness score, label and mood. If this fails, it is retried automatically within minutes.
4. Consultations from your calendar stay on your Leads as bookings: their time, call link and meeting code, the Lead's email, and Google's ID for the event. What else we kept about the event is deleted. They no longer follow your calendar. A Calendly booking keeps a meeting code and call link it took from your calendar.

When you connect a different Google account, the previous one is first disconnected in the same way.

When you remove our access in your Google account (https://myaccount.google.com/permissions), Google ends our access, and we can no longer read anything. This alone deletes nothing in Lead Desk: what was already brought in stays until you press Disconnect in Lead Desk, or until the retention period ends. The next time Lead Desk tries to read from Google, the connection shows "Needs reconnecting". If you can no longer sign in to Lead Desk, write to contact@immigrationbyinvestment.com and we will delete it.

What remains after you disconnect:

• the consultations, with their date and status, and the bookings from your calendar described in step 4;
• a record that your account had a Google connection — when it was made and closed, and why — with no Google identity, settings or tokens;
• in the activity history, the fact that a review was made (without its readiness score, label or mood), the alerts about consultations from your calendar (with the Lead's name, time and platform), and that Google was connected and disconnected. These entries show names in Lead Desk, never your Google details;
• alerts already delivered to Telegram or a browser. We cannot recall them, but they never contain transcript text;
• transcripts you uploaded by hand. They follow the retention period above.

Apart from ending our access, disconnecting does not change anything in your Google account: your calendar and your Meet transcripts there stay as they are. To ask us to delete specific Google data at any time, write to contact@immigrationbyinvestment.com.

8.3 Microsoft Teams (planned — not yet available)

Not yet available. This section describes a planned integration. It does not apply today. Lead Desk does not yet ask for access to any Microsoft account.

If an Advisor connects a Microsoft work account, we plan to:

• read transcripts (VTT) of their Teams online meetings through Microsoft Graph;
• receive notifications when a new transcript is ready.

Your organization's administrator may need to approve this. The same limits will apply as for Zoom:

• the data is used only for the Advisor's own consultations;
• it is never sold, never used for advertising, and never used for AI training;
• the retention in section 7.5 applies;
• the data is deleted after you disconnect (section 7.6).

8.4 Telegram

If you link Telegram, we store your Telegram chat ID, and the chat's Telegram username or name, so that we can send you alerts. Linking codes expire after 15 minutes. If you disconnect in Lead Desk, or send /stop to our bot, the chat is unlinked and we stop sending alerts to it. The record of the unlinked chat is kept with your account until deletion is requested (section 10).

9. How data is shared

9.1 Service providers

These providers process data for us to run Lead Desk. The last two rows are services an Advisor chooses to use with Lead Desk:

9.2 Within IBI and its Advisors

• An inquiry belongs to one Advisor at a time.
• Inquiry data is visible to IBI staff and to the Advisor the inquiry currently belongs to.
• Advisors cannot see other Advisors' inquiries, meetings, connected accounts or alerts.
• When an inquiry is moved to a different Advisor, the previous Advisor loses access. The new Advisor sees only when the previous Advisor's calls, messages and meetings took place and how they ended. It does not see their content, recordings or AI summaries.
• Advisors do not pay for Lead Desk. They pay IBI for the inquiries IBI introduces to them, under separate agreements (section 1.2).

9.3 Legal and business transfers

We may disclose information:

• if the law requires it;
• to protect the rights, safety and security of our users and others;
• as part of a merger, acquisition or sale of assets. In that case we will give notice, and this Policy will continue to apply.

9.4 Where we receive data from

• IBI's ads and lead forms. IBI's main Privacy Policy (https://www.immigrationbyinvestment.com/privacy) explains how IBI collects your inquiry.
• Meta (Facebook and Instagram Lead Ads) sends us the forms you submit there. Meta's own privacy policy covers your use of its platforms.

10. How long we keep information

Copies kept by our providers follow those providers' own retention settings. Examples are message logs at our SMS and email providers, and alerts already delivered to Telegram. Anthropic deletes API data as described in section 5.

11. Security

• All connections to Lead Desk use HTTPS.
• Encrypted tokens:
  • Access tokens for connected accounts are encrypted in our database with AES-256-GCM.
  • Each encrypted value is bound to its own record.
  • Tokens are decrypted only on our servers. They are never sent to the browser or written to logs.
• Connecting accounts. Accounts are connected through OAuth with PKCE and a single-use, encrypted state value. An authorization that does not come back with our own state value is never used. We never ask for or store your Zoom, Google, Microsoft or Calendly password.
• Passwords. User passwords are stored as bcrypt hashes. Repeated failed sign-ins are throttled.
• Separation between Advisors:
  • every request for an inquiry's data is checked against the signed-in user;
  • Advisor lists are filtered in the database;
  • data from a connected account is matched only to that Advisor's own inquiries;
  • each Zoom or Google account can be connected to only one Lead Desk user.
• Incoming webhooks:
  • Zoom notifications must carry a valid HMAC-SHA256 signature and be no more than 5 minutes old. The one exception is Zoom's app-removal notice, which Zoom sometimes sends unsigned. We act on an unsigned one only after checking with Zoom, so that a forged notice cannot delete anything while Zoom still accepts our access.
  • Google Calendar notices are accepted only if they carry the secret token of the notification channel we opened for that calendar (compared in constant time) and that channel's resource ID. Notices for unknown channels are ignored. A notice carries no event data: we then read the changes with the Advisor's own access.
  • Webhooks from Calendly, Meta, Resend, ElevenLabs and Telegram, our own lead-intake and call-data connections, and our phone provider's call-status, recording and text-message notifications are verified with signatures or shared secrets.
  • For the few other requests from our phone provider, we act only on data fetched again from the provider, or on a single-use call that our servers created moments earlier for a signed-in user who may still work on that inquiry.
• Zoom downloads. We download Zoom transcript files only from Zoom's own servers over HTTPS, and only up to 2 MB.
• Provider links. Before storing data from connected services, we remove provider download tokens and links.
• AI assistant call audio is played back only through a route that checks access.

No system is perfectly secure. If a breach affects your personal data, we will notify you and the authorities as the law requires.

12. Your rights

Depending on where you live, you may have the right to:

• access your data and get a copy;
• correct it;
• delete it;
• restrict or object to processing, including processing based on legitimate interests;
• receive it in a portable format;
• withdraw consent where it is the basis for processing. This does not affect processing that happened before you withdrew.

California residents can also ask:

• to know what personal information is collected, used and disclosed;
• to delete it;
• to correct it;
• to opt out of its "sale" or "sharing".

Lead Desk does not share personal information for cross-context behavioral advertising. Section 1.2 and IBI's main Privacy Policy explain how IBI introduces inquiries to Advisors. If you have questions about this, write to us.

We will not discriminate against you for using these rights.

How to ask: email contact@immigrationbyinvestment.com with the subject "Privacy request". Include your name and the email or phone number you used with us.

• This one address is for every request about your data in Lead Desk, whoever is responsible for it (section 1.2). If you write to an Advisor instead, the Advisor forwards your request to us.
• We carry out the request in Lead Desk: for IBI's own record and uses, as IBI; for data an Advisor is responsible for, on that Advisor's behalf, and we tell the Advisor what we did. A deletion an Advisor asks for does not remove IBI's own record (section 10); a deletion you ask for does, except what the law requires us to keep and an SMS opt-out (section 10).
• Copies that an Advisor keeps outside Lead Desk, for example in its own email or files, are for that Advisor to handle. Ask the Advisor about those.
• We may need to verify your identity first.
• We will reply within the time the law requires.
• An authorized agent may make a request for you, with proof of authority.

In the EEA or the UK, you can also complain to your data protection authority.

Advisors can also, in Lead Desk:

• remove a consultation transcript from the Lead's page, while the Lead belongs to them;
• turn off Zoom or Google Meet importing, or disconnect a connected account, under Integrations.

Admins can remove any consultation transcript, and deactivate an account.

Anything else is handled on request at contact@immigrationbyinvestment.com. Examples are deleting the data of an inquiry or an account, and deleting the Zoom data of a deactivated Advisor, who can no longer sign in to disconnect. (That Advisor can also remove the IBI CRM app in Zoom, which works while their account is deactivated; section 7.6.)

13. International transfers

Lead Desk is hosted in the United States. If you are outside the US, your data is transferred to and processed in the US, where data protection law may differ from yours.

Where the law requires a safeguard for these transfers, we rely on the mechanisms it allows, such as the European Commission's Standard Contractual Clauses where a provider's terms include them.

14. Children

Lead Desk is meant for adults considering residence or citizenship by investment. It is not directed to anyone under 18.

• We do not knowingly collect personal data from children.
• An inquiry may mention family members, such as children included in an application.
• If you believe a child has sent us personal data directly, contact us and we will delete it.

15. Changes to this Policy

We will post updates here and change the "Last updated" date. Sometimes a change materially affects how we use data from connected accounts or other personal data. In that case, we will tell Advisors in Lead Desk or by email before the change takes effect.

16. Contact us

immigration by investment (DBA) - Immigration Diligence LLC

• Email: contact@immigrationbyinvestment.com
• IBI: https://www.immigrationbyinvestment.com
• IBI's main Privacy Policy: https://www.immigrationbyinvestment.com/privacy
• Lead Desk: https://ibicrm.com
• Support: https://ibicrm.com/support