Last updated: September 29, 2023
"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
through the Site and our use of that information and does not apply to our offline practices. Please refer
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.
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
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
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
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
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
the business of the Site to which the information relates, in which case FKM will require any such buyer to
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.
the information practices of the Site, please contact FKM as follows:
FirstKey Mortgage, LLC
900 Third Avenue
New York, NY 10022
Data Privacy Framework
FirstKey Holdings, LLC, FirstKey Mortgage, LLC, and Harvest Innovations, LLC complies with the EU-U.S. Data
Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
as set forth by the U.S. Department of Commerce. FirstKey has certified to the U.S. Department of Commerce
adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom
Gibraltar) under the UK Extension to the EU-U.S. DPF. FirstKey has certified to the U.S. Department of
Commerce that it
adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the
personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between
the terms in
shall govern. To
learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit
FirstKey is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK
Extension to the
EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its
complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of
from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over FirstKey's compliance with the EU-U.S. DPF, the UK
Extension to the
EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, FirstKey may be required to disclose personal
response to lawful requests by public authorities, including to meet national security or law enforcement
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, FirstKey
refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S.
DPF, the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider
based in the
United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us,
or if we
have not addressed your DPF Principles-related complaint to your satisfaction, please visit
for more information or to file a complaint. These dispute resolution
services are provided at no cost to you.
For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF compliance not
any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding
Further information can be found on the official DPF website: