Last updated: January 30, 2023

This Privacy Policy applies to the use of the website www.firstkeymortgage.com, www.firstkeyholdings.com (the "Site"). This Privacy Policy is provided to give you specific information about how ("FKM", "we," or "us") protects your privacy, how we treat information we collect on the Site ("Personal Information") and how we may use this information. It also describes your choices regarding use, access and correction of your personal information. The Site is governed solely by applicable Federal and State laws and governmental regulations in the United States. This Privacy Policy applies solely to our collection of information through the Site and our use of that information and does not apply to our offline practices. Please refer to our EEA and UK Privacy Policy if we process your Personal Information under the EU General Data Protection Regulation ("GDPR"), the GDPR as incorporated into UK law by the Data Protection Act 2018 or the Swiss Federal Data Protection Act.

Privacy Policy; Consent.. Your use of the Site constitutes your acceptance and consent of this Privacy Policy. This Privacy Policy may be amended by FKM from time to time, your use of this site after any such amendment constitutes acceptance of the modified terms. If FKM makes any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. You should check the Privacy Policy and Terms of Use periodically for any changes. Please review this Privacy Policy carefully. This Privacy Policy applies to your use of this Site only. FKM does not own, control or operate the websites of any third-parties. Accordingly, this Privacy Policy does not apply to any third-party websites or their collection, use, storage or disclosure of your personal information.

Collection of Personal Information. The Site does not collect personally identifiable information about you unless you send us an email and expressly provide such information, such as your name, telephone number(s), and physical address to us on a voluntary basis.

Please see the FirstKey Mortgage, LLC Consumer Privacy Notice for additional information on how Personal Information may be shared.

Collection of Automatically Obtained Information. We automatically receive information through browser technologies when you access the Site. This may include information such as Internet Protocol addresses, and navigational data collection, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Site. The Site only uses Internet Protocol (IP) addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). FKM uses your IP address to diagnose problems with FKM's server, report aggregate information, determine the fastest route for your computer to use in connecting to the Site, and administer and improve the Site. FKM and its partners use tracking technologies such as etags and scripts to administer the Site and help improve its performance.

Cookies. The Site does not use cookies.

Use and Disclosure of Information. The primary purpose for collecting your Personal Data is so that FKM can communicate with you and confirm that we have a business relationship. FKM will not rent, sell or share with third-parties the Personal Information that you email us with from this Site except (i) to provide information that you have requested; (ii) with your permission, or (iii) under the following circumstances: FKM may disclose your Personal Data to FKM's affiliated entities worldwide that agree to treat it in accordance with this Privacy Policy. FKM may also disclose your personally identifiable information to third parties, located in the United States and/or any other country, but only (i) to contractors that FKM uses to support FKM's business (e.g., fulfillment services, technical support, delivery services, and financial institutions), in which case FKM will require such third parties to agree to treat it in accordance with this Privacy Policy, (ii) in connection with the sale, assignment, or other transfer of the business of the Site to which the information relates, in which case FKM will require any such buyer to agree to treat it in accordance with this Privacy Policy; or (iii) where required by applicable laws such as to comply with a subpoena or other legal process, court orders, or government regulations or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend the rights or property of FKM and its employees, affiliates, users of the Site or the public (c) act in urgent circumstances to protect the personal safety of FKM and its employees, affiliates, users of the Site or the public, or (d) protect against legal liability. In certain situations, FKM may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security. FKM takes reasonable steps to protect your Personal Data as you transmit your information from your computer to the Site, and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. E-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to the Site via e-mail.

Retention. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Children. This site is not directed to children under thirteen years of age. If you are younger than the age of 13, please do not provide any personal information on this Site.

Correction/Updating Personal Information. Upon request, FKM will provide you with information about whether we hold any of your personal information. To keep your Personal Data accurate, current, and complete, please contact FKM at the address below. FKM will take reasonable steps to update or correct personally identifiable information in its possession that you have previously emailed us with via the Site. We will respond to your request in a reasonable timeframe. In certain circumstances, FKM has no direct relationship with the individuals whose personal data it processes. The use of information collected in these instances shall be limited to the purpose of providing the service for which the Client has engaged FKM. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to FKM’s Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe. In certain circumstances, we may be required by law to retain your personal information or may need to retain your personal information in order to continue providing a service.

How to Contact FKM. If you have any questions, comments, or concerns about this Privacy Policy or the information practices of the Site, please contact FKM as follows:

FirstKey Mortgage, LLC
900 Third Avenue
Suite 500
New York, NY 10022
1-866-209-2576
[email protected]

EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD

FirstKey Holdings, LLC, FirstKey Mortgage, LLC and Harvest Innovations, LLC participate in and certify their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List.

FirstKey is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, FirstKey is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.