Lead Generation Policy
Effective date: 6 November 2026
1. What a lead is A lead is a user’s genuine inquiry, consultation request, product request or RFQ shared for an identified purpose. It is not a guaranteed customer, verified budget, exclusive opportunity or assured sale unless a written campaign contract expressly states a measurable commitment. Lighthouse must explain the recipient category and purpose before sharing personal contact information. Professional discovery and a public portfolio do not authorise unrestricted prospect harvesting.
2. Information and routing Collect the minimum details needed to understand the request and route it appropriately. Use approximate location until a precise address is needed. Share confidential plans only with authorised recipients for the inquiry. Recipients may be selected by relevant category, geography, service area, capacity and other disclosed factors. [CONFIRM actual routing and ranking criteria.] Sponsored placement or paid routing influence must be clearly identified. A lead may be shared with more than one provider unless exclusivity is expressly stated. Do not sell a lead as exclusive while routing it to multiple paying recipients.
3. Recipient duties Contact the person only for the stated inquiry and within their permitted communication choices. Identify your business, keep follow-up proportionate, honour opt-outs and comply with applicable marketing/telecom rules. Do not resell, trade, scrape or upload leads to unrelated marketing lists; contact relatives or colleagues without authority; or use the data to train an external model. Protect copies and delete them when no longer needed except for a specific legal requirement. Do not promise a Lighthouse guarantee, quote on another provider’s behalf or use a referral as authority to collect money for Lighthouse.
4. Lead quality and charging Where a lead service is paid, the schedule must define the chargeable event, qualifying fields, duplicate period, invalid-lead criteria, dispute window, replacement/refund method and tax treatment. No fee is inferred merely because a profile receives an inquiry. Proposed invalid categories for a paid campaign: demonstrably fake identity, duplicate under the agreed rule, wrong category/location or no permission to share. Failure to answer, later cancellation or loss to a competitor is not automatically an invalid lead unless agreed.
Submit a claim with the lead ID and concise evidence. Lighthouse should investigate using limited records and communicate a reasoned outcome. No promise of conversion or revenue replaces these measurable terms.
5. Buyer choices and complaints A buyer may stop further referral or follow-up through [CONFIRM preference/support route]. We stop future distribution for that request and notify relevant processors; independent providers remain responsible for their own lawful records and communications. Report spam, fraud, a wrong recipient or misleading representation through the grievance channel. Good-faith complaints do not affect eligibility for statutory remedies.
6. Recordkeeping Keep the request source, notice/permission, recipient, routing event and charge record where relevant. Retention follows purpose and the Data Retention Schedule. Do not retain all prospect data indefinitely because it might become useful.
7. Enquiry creation and permission to share An enquiry must be submitted by the potential buyer or someone authorised to act for that buyer. State the service, location, expected scope and preferred contact method. Do not upload a third party’s phone number solely to generate a lead, enter a promotion or test supplier responsiveness. Before distribution, explain which categories of recipients will receive which data and for what purpose. Share a precise site address, private plan or household details only where necessary at the relevant stage. A public business contact is not blanket consent to unrelated marketing.
8. Recipient obligations and contact boundaries A recipient may use enquiry data to respond to the identified request and administer an ensuing lawful transaction. It may not resell the lead, add it to unrelated bulk campaigns, upload it to an advertising audience, pass it to undisclosed intermediaries or use it to profile the household. Contact must respect the user’s chosen channel and timing, applicable telecom and marketing rules, and withdrawal or do-not-contact requests. An operational response to an RFQ and a future promotional campaign are separate purposes. Agents and call centres are subject to equivalent restrictions. Recipients must identify themselves and their relationship with Lighthouse accurately. They must not imply Lighthouse guarantees their work, demand an undisclosed brokerage fee, impersonate another bidder or pressure a user to disclose OTPs, passwords or unnecessary identity documents.
9. Lead quality, allocation and paid programmes An enquiry is an expression of interest, not a guaranteed sale, exclusive appointment, confirmed budget or credit decision. Unless an agreed plan states otherwise, multiple eligible recipients may receive it. Any paid exclusivity, geographic protection or response commitment must be defined in the commercial schedule. If a paid lead is challenged as duplicate, fraudulent, outside the agreed category or containing unusable contact details, assess it against the written eligibility and credit rules. Keep the original submission and distribution history. A lead should not be denied as invalid merely because the user chooses another supplier. Allocation may consider geography, category, capacity and other disclosed factors. Paid priority must be labelled and must not be misrepresented as independent professional merit. No recipient may create fake buyer enquiries to obtain competitor prices or inflate conversion figures.
10. Attribution and off-platform transactions Where a signed plan charges an order fee, it must define the attribution event, period, completed-value base, returns, cancellations and proof of an existing relationship. A platform introduction does not create an indefinite entitlement to every later transaction with that person. Participants must not falsify order values or hide an attributable order to evade an accepted fee. Lighthouse may review proportionate supporting records, subject to confidentiality. A fee dispute does not justify harassing the buyer or withholding a statutory remedy.
11. Closure, deletion and international leads When an enquiry closes or contact permission is withdrawn, stop unnecessary contact and delete or restrict records according to the lawful retention purpose. Preserve only the records necessary for the actual transaction, disputes or compliance, and explain relevant exceptions. Before routing a lead across borders, disclose the destination and relevant recipient arrangement and implement the required data-transfer safeguards. A marketing opt-in valid for one channel or country must not be presumed valid for all countries. Local consent, unsolicited-communications and consumer rules must be assessed for each launched market.
12. Enquiry scope and recipient matching An enquiry should identify the user's requested product or service, approximate location, preferred contact method and any meaningful time or budget constraints. A request for one category does not authorise marketing of unrelated categories. Lighthouse should explain whether the enquiry goes to one recipient, a shortlist or multiple eligible businesses before sharing identifiable details. A recipient must use the enquiry only to evaluate and respond to that request and for any separately authorised follow-up. It must not resell the lead, add the person to a purchased
audience, upload their details to an advertising platform or disclose the request to unrelated businesses.
13. Contact frequency and opt-out handling Contact must be reasonable in frequency, relevant in content and consistent with the user's stated preference and applicable communications rules. A request to stop contact must be respected. A business must not evade an opt-out by changing numbers, using another branch or engaging an agent to repeat the same solicitation. Where a discussion becomes a separate customer relationship, the recipient must explain its own identity and relevant privacy practices. Transactional communication necessary for an accepted service is different from optional promotion. A lead-routing permission is not perpetual marketing consent.
14. Invalid, duplicate and disputed leads For any paid lead programme, the accepted programme schedule must define chargeable delivery and the criteria for a duplicate, wrong-category, unreachable, fabricated or otherwise invalid lead. It must state the evidence and review window without imposing an unreasonably short forfeiture of a genuine claim. A lead that does not convert is not automatically invalid. Conversely, a technical delivery event does not prove that the contact information was correct or the person requested the service. Lighthouse will assess the applicable criteria and relevant records and explain any adjustment. A fee dispute must not result in harassment of the prospective customer.
15. Exclusivity and outcomes No recipient receives exclusivity, a guaranteed appointment, conversion, order value or customer creditworthiness unless a separately accepted programme expressly provides it. Any express promise must identify its scope and remedy. A sales representative cannot convert a non-exclusive plan into an exclusive territorial appointment without authority. Where competing recipients receive the same request, ranking or allocation must not be represented as an independent endorsement when materially affected by payment. Lead recipients must not arrange sham competing quotes or pressure the user to cancel another supplier dishonestly.
16. Attribution and commercial evidence If a signed business schedule charges for an attributable completed order, the attribution rule must identify the originating enquiry, relevant customer and scope, applicable period, excluded pre-existing relationships and treatment of returns or cancelled items. An unexplained match of phone numbers is not enough to charge every future transaction. The parties may exchange proportionate evidence to resolve attribution, with unrelated customer information redacted. No blanket right to inspect an entire CRM, personal phone or bank account is created. Established commission obligations remain enforceable only within the agreed lawful scope.
17. Wrong recipients and closure A recipient who receives an enquiry in error must stop using it, notify the sender and delete or restrict it as lawfully required. The recipient must not exploit the error as a free marketing opportunity. A suspected exposure of confidential plans or personal details must be escalated as a security or privacy matter. Closing an enquiry stops ordinary new routing but does not erase necessary transaction records or an independently formed contract. Lighthouse will provide available correction and withdrawal routes and explain what information has already been supplied to independent recipients.
18. Paid lead programme activation A paid enquiry programme must define the exact chargeable event and distinguish an enquiry, quote, appointment and completed sale. A supplier’s payment must not be described as guaranteeing a customer or exclusivity unless a specific enforceable commitment is given. Before launch, publish the programme’s measurable eligibility and duplicate rules, claim route and refund or credit treatment. A closed or unresponsive enquiry is not automatically fraudulent. Do not impose an undisclosed lead charge on ordinary V1.0 discovery.