Operating Agreement

Terms & Conditions

Version 2026-10-21 · updated October 21, 2026

The terms of service that govern your use of the platform.

These Terms are between you and Virtual Closer ("the Platform", "we", or "our") and govern your access to and use of the Virtual Closer platform and everything offered through it. By using the platform or selecting "I agree", you agree to these Terms, individually or on behalf of the organization you represent. To use the platform you must be at least 18 years old and reside in the United States.

Your account

You are responsible for keeping your credentials confidential and for all activity under your account. You agree to provide accurate, complete, and current information. We may suspend or close an account that breaches these Terms.

Purchases, wallet, and pricing

• You fund a wallet and purchase leads at the price shown before you confirm. Applicable charges and taxes are disclosed before checkout.
• Payments are handled by our third-party payment processor; we never store your full card details.
• Until payment is received, you have no rights to the purchased leads.
• All lead sales are final. Your sole remedy for an eligible lead-quality issue is a replacement under our Lead Replacement Policy.

Chargebacks and disputes

If you reverse, dispute, or charge back a payment for purchased leads without first submitting a written dispute notice to support@virtualcloser.com and allowing us a reasonable period to resolve it, a $500 administrative recovery fee will be assessed to your account. A chargeback is not a remedy for a lead-quality issue and forfeits your right to a replacement.

Subscriptions

Recurring plans (such as a weekly lead subscription or a monthly platform fee) renew automatically using your payment method until you cancel. A plan with a stated minimum term cannot be cancelled before that term is fulfilled. You will be notified before a renewal and may cancel from your account or by contacting us; cancellation takes effect at the end of the current billing period.

Acceptable use

You agree to use the platform lawfully, not to resell or scrape leads or the platform, not to build a competing product from it, and not to interfere with its operation or security.

Your contacts, Do Not Call, and consent

Virtual Closer is software. You are the caller and sender (the "initiator") of every call, text, voicemail, and email you place, schedule, or trigger through the platform, including those an AI feature places or sends for you under settings you control. Following the laws that govern those communications is your responsibility alone. For every contact you upload, import, or reach through the platform, you are solely responsible for:

• Having valid prior express consent to contact them by each method you use, and prior express written consent where the law requires it, including consent for calls or messages that use an artificial, prerecorded, or AI-generated voice.
• Scrubbing your contacts against the National Do Not Call Registry, every applicable state do-not-call list, and your own internal do-not-call list, before you contact them and as often as the law requires.
• Honoring every opt-out and do-not-call request promptly, on every channel.
• Following calling-hour limits, call-frequency limits, caller-identification rules, and every other federal and state rule that applies, including the Telephone Consumer Protection Act (TCPA), the Telemarketing Sales Rule (TSR), state telemarketing and "mini-TCPA" laws, and the CAN-SPAM Act.

We do not scrub contacts you supply against the National Do Not Call Registry or any other do-not-call list, and we do not verify the consent behind them. The opt-out handling, quiet hours, and other safeguards the platform offers are conveniences, not a compliance program, and they do not shift any of your obligations to us.

You represent and warrant that every contact you upload, import, or reach through the platform was lawfully obtained and may lawfully be contacted by every method you use to contact them.

You will defend, indemnify, and hold harmless Virtual Closer and its owners, officers, directors, employees, and agents from all claims, demands, fines, penalties, damages, settlements, and costs, including reasonable attorneys' fees, arising out of or related to your contacts or your communications, including any claim under the TCPA, the TSR, or any federal or state do-not-call or telemarketing law.

We may, at our discretion and without notice, suspend or remove contacts, campaigns, numbers, or accounts we believe are not compliant. We have no obligation to monitor your contacts or communications, and not acting is not approval.

Disclaimers and liability

The platform is provided "as is" and "as available" without warranties of any kind. To the fullest extent permitted by law, Virtual Closer is not liable for any indirect, incidental, or consequential damages, or any loss of profit, data, or goodwill, arising from your use of or inability to use the platform.

Governing law

These Terms are governed by the laws of the State of Florida, without regard to conflict-of-law principles. Questions: support@virtualcloser.com — 382 NE 191st St #875614, Miami, FL 33179.

AI Usage & Health Information Agreement

Version 2026-10-21 · updated October 21, 2026

How our AI works, where health information may and may not go, and who is responsible for it.

This agreement explains how Virtual Closer uses artificial intelligence, which parts of the platform are built to handle health information and which are deliberately not, how to collect health information safely, and who carries the risk when it is collected the wrong way. Read it — the rest of this agreement holds you responsible for following it, and that is only fair if we have told you exactly what to do.

1. How the AI works

The platform is not a single AI. It is a set of separate AI features, each sending a specific, limited payload to a large language model and writing the result back into your account. Nothing is sent to a model except in service of a feature you have turned on.

• Lead messaging: an autonomous SMS assistant reads a prospect's text thread and drafts, reviews, and sends replies, asks a few questions about the prospect's coverage needs, and books a call on your calendar with a licensed agent to find which plan fits them.
• Lead intelligence: scoring, ranking, conversation labeling, objection detection, and re-engagement of cold leads.
• Rep assistance: reply drafting, email triage and drafting, call and meeting summaries, and after-call disposition suggestions.
• Underwriting and policy analysis: reviewing case facts, quoting guidance, and analyzing an existing policy you upload.
• Operations: internal summarization, quality review of the AI's own output, and reporting.

What is sent to a model, and what is not

Each feature sends only the content it needs. A messaging feature sends the message thread; an underwriting feature sends the case facts. Model providers are contractually barred from using your content to train general-purpose models, and we do not sell your data.

Two things follow from how language models work, and you should plan around both. First, anything present in a conversation, note, or field that a feature reads is part of what that feature sends — the model has no way to see some of a thread and not the rest. Second, AI output is probabilistic: it can be wrong, and it is a drafting and prioritization aid, never professional, legal, medical, or underwriting advice.

2. Which parts of the platform are built for health information

AI processing on this platform runs over more than one lane, and they are not interchangeable. The distinction is deliberate, and it is the single most important thing in this document.

The protected lane — built for health information

Features whose entire purpose is health information run on AI infrastructure covered by an executed business associate agreement (a "BAA") with our AI infrastructure provider, with encryption in transit and at rest and the provider contractually walled off from the content. These features are designed and operated to carry protected health information:

• The secure intake and insurability forms, and the answers a consumer submits through them.
• The underwriting assistant and underwriting reports, including their free-text notes.
• The policy analyzer, including policy documents you upload.
• Call recording analysis and transcription of recorded calls.
• Messaging with your existing policyholders (as distinct from prospect messaging).
• Secure document collection.

The general lane — NOT built for health information

Prospect text messaging and the lead-intelligence features around it run on general-purpose AI providers that do not offer a business associate agreement. This is a deliberate design choice, and it is safe only because of what those features are limited to sending: a prospect's own text messages, their first name, their age (not their date of birth), and facts derived from what they themselves wrote — keyed to an internal record identifier rather than assembled into an identified health profile.

These features are NOT a HIPAA-compliant channel, are not offered as one, and must not be used as one:

• Outbound and inbound prospect SMS, including every AI-drafted reply.
• Lead scoring, conversation labeling, objection mining, and cold-lead re-engagement.
• Email drafting and triage, and general rep-assistance drafting.

Free-text fields follow the lane they are read into

Notes your reps type on a lead, a meeting, or a call are read by AI features. Where those notes would otherwise reach a provider outside the protected lane, the platform withholds them and leaves a marker instead. That protection exists because rep free text is unpredictable by nature — but it is a backstop, not a license. Do not type health information into a notes field.

Architecture changes; the obligation does not

Which provider serves which feature can change as models improve, and this map describes the platform's design rather than freezing a vendor list. What does not change is the boundary: health information belongs in the protected lane, and the channels named in section 4 are how you keep it there. We will update this agreement's version when the boundary itself moves.

3. What the platform does to steer health information out of text

We do not rely on your reps remembering. The assistant is built to push health conversations off text, and you should know exactly what it does and what it cannot do.

• When a prospect starts describing their health, the assistant does not engage with the detail. It says once, casually, that health questions are not its lane, and moves the person to the secure intake form or to a call with a licensed agent — never a scold, never a dead end.
• A question that discloses nothing — "does this cover diabetes?" — is answered normally. The deflection is aimed at disclosure, not at coverage questions.
• Health statements are stripped from the model-facing copy of a thread, so a single disclosure is not replayed to the model on every later turn. The message itself stays in your records, unchanged.
• A reply that quotes a prospect's health detail back to them is caught after drafting and sent back for a rewrite.
• One screening question during discovery asks whether a prospect has major health conditions, as a Yes or No, with no details taken. It is asked with consent and used only to route the conversation to the right product and the right channel.

These controls are best-effort engineering, not a guarantee, and they are not a substitute for your own practices. They reduce what a prospect volunteers. They cannot undo what one of your users deliberately asks for: if a rep asks a health question by text, the answer arrives as an ordinary message, in the ordinary thread, on the ordinary lane. There is no mechanism by which we can hold it back.

4. How to collect health information safely

There are three correct channels, and they cover every case that arises in this business:

• A phone call with a licensed agent. Health questions belong in a live conversation. If a prospect raises health over text, move to a call — booking one is the assistant's default response.
• The secure intake or insurability form. Send the link; let the consumer answer there. Form answers land in the protected lane and are exactly what the underwriting features are built to read.
• Secure document collection, for anything a consumer needs to upload.

What must never happen

• Never ask a prospect for health information by text — conditions, diagnoses, symptoms, medications, prescriptions, treatment, height and weight, tobacco or substance use, disability, or pregnancy.
• Never type health information into a text message, a lead note, a meeting note, or a call note.
• Never paste health information into an AI chat, prompt, or drafting box outside the underwriting and policy-analysis features.
• Never continue a health conversation in a text thread because a prospect started it. Acknowledge, and move it to a call or the form.
• Never route health information into a webhook, export, integration, or API destination that is not itself appropriate for it.

Your obligations

You are responsible for training every user of your account on this section, for supervising them, and for enforcing it. You confirm that you have read this agreement, that you understand which parts of the platform are built for health information and which are not, that you understand the safe channels available to you, and that you will use them.

5. Who is responsible

Any business associate agreement, vendor commitment, or security control Virtual Closer holds governs our own arrangements with our providers. It does not make your use of the platform compliant with HIPAA or any other law, it does not authorize you to collect health information through a channel this agreement tells you not to use, and it is not a representation that prospect text messaging or the general lane described in section 2 is suitable for protected health information.

We have told you, specifically and in advance, how the AI works, which parts of the platform are built for health information, which are not, what the platform does to steer health information out of text, and exactly which channels to use instead. If you, your reps, or anyone using your account solicits, invites, enters, or continues an exchange of health information outside those channels — or configures the platform to send it somewhere this agreement tells you not to — that is your act, not ours.

To the maximum extent permitted by law, Virtual Closer has no liability of any kind for the collection, transmission, storage, AI processing, disclosure, or exposure of health information introduced in breach of this agreement, whether under HIPAA, any state health-privacy or consumer-protection law, or any other theory. You will defend, indemnify, and hold harmless Virtual Closer and its officers, employees, and agents from any resulting claim, investigation, penalty, demand, loss, or cost, including reasonable attorneys' fees. Nothing in any business associate agreement between us extends our obligations to information introduced in breach of this agreement.

Reporting and contact

If you believe health information has entered the platform through the wrong channel, tell us promptly at support@virtualcloser.com so we can help you contain it. Reporting is not an admission and does not by itself change the allocation above — it is how we limit the damage together. Questions about this agreement: support@virtualcloser.com — 382 NE 191st St #875614, Miami, FL 33179.

Privacy Policy

Version 2026-10-21 · updated October 21, 2026

How we collect, use, and protect your personal data.

Virtual Closer ("us", "we", or "our") operates the Virtual Closer platform (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Information we collect

We collect information to provide and improve the Service, including:

• Personal data you provide: name, email address, phone number, mailing address, and professional details such as your NPN and licensed states.
• Usage data: IP address, browser type and version, pages visited, and diagnostic data.
• Cookies and similar technologies used to operate and secure the Service.

How we use your data

• To provide, maintain, and improve the Service.
• To deliver leads you have purchased and route them per your settings.
• To process payments and manage your wallet and subscriptions.
• To provide customer support and send you service-related notices.
• To detect, prevent, and address technical and security issues.

Sharing and disclosure

We do not sell your personal data. We may share it with service providers who help us operate the Service (such as payment and communications vendors), and we may disclose it when required by law or to protect our rights, users, or the public.

Data retention and security

We retain personal data only as long as necessary for the purposes above. We take reasonable measures to protect your data, but no method of transmission or storage is completely secure.

Contact

Questions about your privacy? Contact us at support@virtualcloser.com — 382 NE 191st St #875614, Miami, FL 33179.

Lead Replacement Policy

Version 2026-07-22 · updated July 22, 2026

Our policy on lead replacements, credits, and quality guarantees.

Virtual Closer is committed to providing every agent with quality leads. By purchasing leads from Virtual Closer, you understand that all sales are final. You waive your right to a refund and your right to dispute lead charges for any reason. By purchasing leads you acknowledge that you understand and agree to this policy.

What you are buying

• Leads are raw consumer inquiries generated from advertising — they are not verified, qualified, screened, or scheduled appointments.
• Lead quality is inherently variable. Aged leads may have been previously contacted by other agents, but they have not been sold.
• Virtual Closer makes no guarantee of contact rate, answer rate, conversion, sales, or return on investment.
• Your sole remedy for an eligible lead-quality issue is a replacement request submitted within the replacement window; a chargeback is not a remedy and forfeits it.

How replacements work

All replacement requests must be submitted within 72 hours of us filling your order. Flag the lead in your dashboard with a reason code within that window; we verify the claim and ship a fresh lead of the same type and filters at no extra cost.

Eligible for replacement

• Disconnected phone numbers only (our team calls every request to verify the number is actually disconnected).
• Duplicate lead received within 60 days (aged and real-time).
• Lead is older than age 85 (aged and real-time).
• Lead is outside the geographic territory you ordered (aged and real-time).
• An aged lead that was previously sold by an agent who purchased it from us.

Not eligible for replacement

• Unresponsive numbers, voicemails, wrong numbers, or wrong info.
• Duplicate leads received more than 60 days apart.
• Any free leads.
• Any OTP (SMS-verified) lead, unless aged.

We will only replace up to 20% of a lead order for eligible replacement reasons. This policy applies to every lead order so we can keep quality high and pricing competitive.