Yes. I reviewed the policy you uploaded. Your current policy was written for a much broader insurance operation: it covers both agents and insurance consumers, lead vendors, consumer health information, insurance applications, data brokers, and financial-product sales. Pasted markdown For winnerscircle.info, which is your recruiting website, I would use a separate policy focused specifically on prospective agents.
Your existing policy already says texts are sent only when someone opts in and within the scope of that consent, which is a good foundation. Pasted markdown However, for A2P purposes, I would make the mobile-data and SMS-consent protections considerably more explicit.
Here is the complete copy-and-paste version.
Winner’s Circle Recruiting Privacy Policy
Last Updated: September 29, 2026
1. Overview
Winner’s Circle (“Winner’s Circle,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you provide to us.
This Privacy Policy describes how Winner’s Circle collects, uses, discloses, and protects personal information obtained through our recruiting website, winnerscircle.info, and through related recruiting, interview, licensing, contracting, onboarding, training, and communications activities.
This website is primarily intended for individuals who are interested in learning about opportunities to become independent life insurance agents with Winner’s Circle.
This Privacy Policy applies to information collected through our recruiting website and related recruiting communications. It does not replace any separate privacy notices that may apply after an individual becomes affiliated with Winner’s Circle, an insurance carrier, or another third party.
2. Personal Information We May Collect
When you interact with Winner’s Circle or submit information through our recruiting website, we may collect information that you voluntarily provide, including:
First and last name;
Mobile telephone number;
Email address;
State of residence;
Insurance licensing status;
Professional or employment background;
Information you provide regarding your interest in the independent life insurance agent opportunity;
Interview, meeting, or appointment information;
Communications you have with Winner’s Circle;
Information related to licensing, contracting, onboarding, or training if you choose to continue through our recruiting process; and
Other information you voluntarily provide to us.
We may also automatically collect limited technical information when you visit our website, such as IP address, browser type, device information, pages visited, referring website, and information concerning your interaction with the website.
3. How We Collect Personal Information
We may collect personal information directly from you when you:
Complete a recruiting or business-opportunity form;
Request information about becoming an independent life insurance agent;
Schedule a business-opportunity meeting or interview;
Communicate with us by telephone, SMS/text message, email, or another communication channel;
Begin the licensing, contracting, onboarding, or training process;
Attend a recruiting event or meeting; or
Otherwise voluntarily provide information to Winner’s Circle.
We may also receive limited information from service providers that assist us in operating our website, scheduling appointments, managing recruiting inquiries, communicating with prospective agents, or maintaining our technology systems.
4. How We Use Personal Information
Winner’s Circle may use personal information for legitimate recruiting and business purposes, including to:
Respond to inquiries regarding the independent life insurance agent opportunity;
Provide information about Winner’s Circle and the agent opportunity;
Schedule and conduct business-opportunity meetings or interviews;
Send appointment confirmations and reminders;
Determine where a prospective agent is in the recruiting or onboarding process;
Provide information regarding insurance licensing;
Assist with contracting and onboarding;
Provide training information and resources;
Communicate with prospective and current agents;
Respond to questions and requests;
Operate and improve our recruiting website;
Maintain the security and integrity of our systems;
Prevent fraud, misuse, or unauthorized activity;
Maintain appropriate business records;
Comply with applicable legal and regulatory requirements; and
Protect the rights, property, and safety of Winner’s Circle and others.
We will use personal information in a manner consistent with the context in which it was collected and the permissions provided by the individual.
5. SMS/Text Messaging
Winner’s Circle may offer prospective agents the option to receive conversational and informational SMS/text messages regarding the independent life insurance agent opportunity.
SMS participation is voluntary.
Individuals who wish to receive SMS communications may opt in through our recruiting website or another authorized Winner’s Circle opt-in mechanism.
Where our website provides an SMS consent checkbox, the checkbox is intended to allow the individual to affirmatively consent to SMS communications.
SMS communications may include:
Recruiting follow-ups;
Responses to inquiries;
Interview and appointment scheduling;
Appointment reminders;
Insurance licensing information;
Contracting information;
Onboarding information;
Training information; and
Other communications directly related to the individual’s inquiry regarding the independent life insurance agent opportunity.
Message frequency varies. Message and data rates may apply.
Consent to receive SMS messages is not a condition of purchase.
Individuals may opt out of SMS communications at any time by replying STOP.
For assistance with SMS communications, reply HELP, email [email protected], or call (909) 538-2548.
6. Mobile Information and SMS Consent
Winner’s Circle does not sell or share mobile phone numbers, SMS opt-in data, or SMS consent with third parties or affiliates for their own marketing or promotional purposes.
Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.
We may disclose information to service providers that perform services on our behalf and require access to information to provide those services, such as communications, CRM, website hosting, scheduling, data storage, and technology providers. Such service providers may use the information only as necessary to provide services to Winner’s Circle and subject to applicable contractual or legal obligations.
SMS opt-in consent and consent records will not be sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes.
The foregoing does not prohibit disclosures required by law, disclosures necessary to protect rights or safety, or disclosures to service providers acting on our behalf as described in this Privacy Policy.
7. How We May Disclose Personal Information
Winner’s Circle may disclose personal information in limited circumstances, including:
Service Providers. We may provide information to vendors and service providers that help us operate our recruiting website, CRM systems, scheduling systems, communications platforms, email services, SMS services, data hosting, analytics, and other business systems.
Insurance and Contracting Organizations. If you choose to proceed with the licensing, contracting, or onboarding process, certain information may be provided to insurance carriers, insurance marketing organizations, contracting organizations, licensing services, or other organizations reasonably necessary to facilitate the process.
Legal and Regulatory Requirements. We may disclose information when reasonably necessary to comply with applicable law, regulation, subpoena, court order, governmental request, or other legal process.
Protection of Rights and Safety. We may disclose information where reasonably necessary to investigate fraud, protect our systems, enforce our rights, or protect Winner’s Circle, our users, or others.
Business Transactions. Information may be transferred as part of a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, subject to applicable law.
Notwithstanding the foregoing, SMS opt-in consent and mobile information are not sold or shared with third parties or affiliates for their own marketing or promotional purposes.
8. Cookies and Website Technologies
Our website may use cookies, pixels, analytics technologies, and similar tools to operate the website, understand how visitors interact with it, improve website performance, and measure our marketing activities.
These technologies may collect information such as:
IP address;
Browser type;
Device type;
Pages viewed;
Time spent on the website;
Referring pages;
General interaction data; and
Similar technical information.
Your browser may allow you to limit or disable certain cookies. Disabling cookies may affect the functionality of portions of the website.
9. Third-Party Websites and Services
Our website may contain links to or integrations with third-party websites and services.
Winner’s Circle is not responsible for the privacy practices of third-party websites or services that we do not control. We encourage users to review the privacy policies and terms of any third-party services they choose to use.
10. Data Security
Winner’s Circle uses reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, misuse, or destruction.
However, no method of transmitting information over the Internet or electronically storing information can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.
11. Data Retention
Winner’s Circle may retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, maintain appropriate business and recruiting records, comply with legal obligations, resolve disputes, enforce agreements, and protect our legitimate business interests.
When information is no longer reasonably necessary for these purposes, we may delete or anonymize it in accordance with our retention practices and applicable law.
12. Your Privacy Choices
Depending on where you live and subject to applicable law, you may have rights concerning your personal information, which may include rights to:
Request access to certain personal information;
Request correction of inaccurate personal information;
Request deletion of certain personal information;
Obtain information regarding certain disclosures of personal information;
Opt out of certain uses or disclosures where applicable; and
Appeal certain decisions concerning a privacy request where applicable.
These rights are subject to applicable legal exceptions and verification requirements.
To submit a privacy request, contact:
Please include sufficient information for us to understand and respond to your request. We may need to verify your identity before fulfilling certain requests.
13. California Privacy Rights
California residents may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), to the extent those laws apply.
Depending upon the circumstances and applicable exemptions, these rights may include the right to:
Know the categories of personal information collected;
Know the sources from which personal information is collected;
Know the business or commercial purposes for collecting personal information;
Know the categories of third parties to whom information is disclosed;
Request access to certain personal information;
Request correction of inaccurate personal information;
Request deletion of certain personal information;
Opt out of the sale or sharing of personal information where applicable; and
Exercise applicable privacy rights without unlawful discrimination.
To submit a California privacy request, contact [email protected].
We may request information reasonably necessary to verify your identity and process your request.
14. Nevada Privacy Rights
Nevada residents may have certain rights concerning covered information under Nevada law, including the right to submit a verified request to opt out of certain covered sales where applicable.
Nevada residents may submit applicable privacy requests to:
15. Residents of Other States
Residents of states with applicable comprehensive privacy laws may have additional rights regarding their personal information.
Depending upon applicable law, these may include rights to access, correct, delete, or obtain a copy of certain personal information and to opt out of certain processing activities.
Requests may be submitted to [email protected].
We will evaluate and respond to verified privacy requests in accordance with applicable law.
16. Children’s Privacy
The Winner’s Circle recruiting website and independent agent opportunity are not directed to children.
We do not knowingly use this recruiting website to solicit personal information from children under the age of 16.
If we learn that personal information has been collected from a child in circumstances prohibited by applicable law, we will take reasonable steps to delete the information.
17. Do Not Sell or Share
Winner’s Circle does not sell SMS opt-in consent or mobile phone information to third parties for their own marketing or promotional purposes.
Where applicable law provides a right to opt out of other activities that constitute the “sale” or “sharing” of personal information under a particular state privacy law, you may submit a request to:
18. Changes to This Privacy Policy
Winner’s Circle may update this Privacy Policy periodically to reflect changes in our recruiting practices, technology, legal requirements, or business operations.
When we make changes, we will update the “Last Updated” date at the top of this Privacy Policy.
We encourage users to review this Privacy Policy periodically.
19. Contact Us
If you have questions regarding this Privacy Policy, your personal information, or Winner’s Circle privacy practices, contact us at:
Winner’s Circle
Website: winnerscircle.info
Email: [email protected]
Phone: (909) 538-2548
For SMS assistance, reply HELP to a Winner’s Circle text message.
To stop receiving SMS communications, reply STOP.