PROGRAMBENEFITS PRIVACY POLICY

Last Updated: February 06, 2026

ProgramBenefits.com ("ProgramBenefits," "we," "us," or "our") is a digital marketing and consumer engagement platform operated by SurgePays Inc., a Nevada corporation, doing business as ProgramBenefits.

This Privacy Policy describes how we collect, use, share, rent, license, and sell personal information when you interact with ProgramBenefits.com, including when you submit information through our forms and are redirected to third-party partners.

If you see any undefined term in this Privacy Policy, it has the definition specified in our Terms of Use.

By accessing or using ProgramBenefits, you agree that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Use.

1. IMPORTANT DISCLOSURES

  • ProgramBenefits is not a government agency.
  • Submission of information does not guarantee eligibility for Lifeline, or any government or private benefit.
  • ProgramBenefits acts as an authorized marketing agent for certain service providers but operates independently.
  • Submission of information constitutes an affirmative consumer inquiry and request for information and offers.
  • By submitting your information, you expressly consent to the practices described in this Privacy Policy.

2. INFORMATION WE COLLECT

We may collect the following categories of personal information directly from you or from authorized third-party sources:

  • Identifiers: First name, last name, phone number, email address, mailing address
  • Demographic Information: Date of birth, ZIP code
  • Eligibility Indicators: Participation in public assistance programs (e.g., SNAP, Medicaid), income-related responses
  • Technical Information: IP address, device identifiers, browser type, operating system
  • Marketing & Interaction Data: Ad interactions, referral URLs, cookies, pixels, server-side events

We may also supplement, validate, enrich, or correct submitted information using third-party data sources, including commercial, marketing, and government databases, where permitted by law.

3. HOW WE USE YOUR INFORMATION

We use your personal information to:

  • Connect you with Lifeline, wireless, broadband, and other consumer offers, if qualified
  • Share information with multiple third-party marketing and service partners
  • Sell, rent, license, or otherwise monetize leads
  • Contact you via email, telephone (manual or autodialed), prerecorded voice, SMS/MMS
  • Maintain internal databases for future outreach pursuant to the consent disclosures to which you agree
  • Perform analytics, modeling, optimization, and fraud prevention
  • Conduct advertising, retargeting, hashed matching, and lookalike audiences
  • Comply with legal, regulatory, and contractual obligations

4. SHARING AND SALE OF PERSONAL INFORMATION

We may share, disclose, rent, license, sell, or otherwise transfer your personal information to:

  • Wireless providers and benefit service providers
  • Marketing partners, lead buyers, and advertisers
  • Advertising platforms, analytics providers, and data processors
  • Vendors and service providers acting on our behalf

This may include cross-context behavioral advertising, audience modeling, and data enrichment.

These activities may constitute a "sale" or "sharing" of personal information under applicable federal and state privacy laws.

5. COMMUNICATIONS & TCPA CONSENT

By submitting your information and by providing your phone number, you are providing express written consent under the Telephone Consumer Protection Act (TCPA) and its correspondence FCC Regulations, Telemarketing Sales Rule (TSR), and all applicable state laws and regulations to be contacted at the number you provided by ProgramBenefits and its marketing partners, which have been identified, through the following means:

  • Manual or automatic telephone dialing systems
  • Prerecorded or artificial voice messages
  • SMS/MMS text messages
  • Email and electronic communications

Message and data rates may apply. Consent applies even if your number is listed on a federal or state Do-Not-Call registry. Consent is not a condition of purchase or for use of any services.

You may opt out:

  • SMS: Reply STOP, END, QUIT, or HELP
  • Email: Use the unsubscribe link in any message

6. COOKIES, TRACKING & ADVERTISING

We use cookies, pixels, SDKs, server-side tracking, and similar technologies, including Meta, Google, TikTok, and other partners, to:

  • Measure performance and conversions
  • Retarget advertisements
  • Share hashed identifiers
  • Build custom and lookalike audiences

We do not currently respond to browser Do Not Track (DNT) signals.

7. YOUR PRIVACY RIGHTS

California (CCPA / CPRA), Colorado, Virginia

You may have the right to:

  • Know, access, correct, or delete personal information
  • Opt out of the sale or sharing of personal information
  • Designate an authorized agent

To exercise these rights, visit:

Do Not Sell or Share My Personal Information

We may verify requests using email, phone number, ZIP code, and/or date of birth.

We will not discriminate for exercising privacy rights.

8. DATA SECURITY & RETENTION

We use reasonable administrative, technical, and physical safeguards. No system is completely secure. Data may be retained, archived, or stored in databases for business, legal, compliance, and marketing purposes.

9. CHILDREN'S PRIVACY

ProgramBenefits is not intended for individuals under 18. We do not knowingly collect children's data.

10. UPDATES TO THIS POLICY

We may update this Privacy Policy at any time. Continued use constitutes acceptance.

11. CONTACT INFORMATION

SurgePays Inc. (DBA ProgramBenefits)

Email: [email protected]

Address: 3124 Brother Blvd, Ste 104, Bartlett, TN 38133