Legal Information

CCPA Privacy Policy

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CCPA Privacy policy background image

FIRSTKEY HOMES, LLC
CALIFORNIA CONSUMER PRIVACY POLICY


firstkeyhomes.com

Last Updated: September 16, 2022

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for information identifying the personal information we shared with third parties for their own direct marketing purposes. If you are a California resident and would like to request this information, please submit a written request to :[email protected] or write us at:

FirstKey Homes
1850 Parkway Pl, Suite 900
Marietta, GA 30067
Attn: Legal Department -Privacy Team.

This California Consumer Privacy Policy (“Policy”) applies to FirstKey Homes, LLC (“FirstKey”, “Owner”, “we”, “us” or “our”) and “Consumers” as defined by the California Consumer Privacy Act and/or the California Privacy Rights Act (together with related regulations the “CCPA”) and should be read along with our other privacy notices found on www.firstkeyhomes.com. Inthe event of a conflict between any other FirstKey policy, statement or notice and this Policy, this Policy will prevail as to California Consumers’ rights under the CCPA.

This Policy covers our Collection, use, disclosure, and Sale of California Consumers’ "Personal Information" ("PI") as defined by the CCPA, for the past twelve months.
You can click on the following links to navigate to the different sections in this Policy

1. Categories of PI We Collect

 

The table below provides the categories of PI we Collect about California Consumers, examples of the PI we Collect, and the types of recipients we share PI with, in connection with our Business.

For purposes of the table below resident services providers include call center vendors, maintenance technicians, security providers, and other similar types of vendors.

Categories of Personal Information Sources of Collection Business or Commercial Purpose for Collection Categories of Third Parties Receiving Personal Information
1. Identifiers
This may include: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
Directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, operating systems, suppliers, public databases, social media platforms, data append services, and other data providers.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services.
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity.
  • Troubleshooting to identify and repair issues.
Data analytics providers, pre-qualification service providers, credit and collection agencies, e-signature service providers, marketing services companies, internet listing service providers, rental insurance providers, and resident services providers.
2. Customer Records Information This may include: signature, social security number, physical characteristics or description, address, telephone number, government issued ID numbers, education, employment history, credit or debit card number, or other financial information. Directly from you on your interest forms, application, or resident portal.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services.
  • Protecting against malicious, deceptive, or illegal activity.
  • Troubleshooting to identify and repair issues.
  • Quality and safety assurance, and improving, upgrading, and enhancing our services.
  • Processing and managing interactions and transactions for our services
Data analytics providers, credit reporting agencies, e-signature services, marketing services companies, credit and collection agencies, resident services providers, and rental insurance providers.
3. Characteristics of protected classifications under CA or Federal Law
This may include: age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.
Directly from you on your interest forms, application, or resident portal.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services.
  • Internal research and development.
  • Quality and safety assurance, and improving, upgrading, and enhancing our services, including reasonable accommodations.
Advertising networks, marketing services companies, data analytics providers.
4. Commercial Information
This may include: records of personal property, services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.
Directly from you, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, operating systems, suppliers, and other data providers.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services.
  • Troubleshooting to identify and repair issues.
  • Internal research and development.
  • Processing and managing interactions and transactions for our services
Data analytics providers, marketing services companies, collection agencies, resident services providers
5. Biometric Information
This may include but is not limited to: voice or other biometric data
Driver's license, passport, or other government photo ID, real-time facial image.  For biometric ID verification.  Resident and applicant service providers. 
6. Internet or other electronic network activity information
This may include: browsing history, search history, information regarding your interaction with our website, application, or advertisements.
Directly from you, your devices or browser, vendors that assist us in providing our services, data analytics providers, advertising networks, operating systems, public databases, social media platforms, and other data providers.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services.
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity.
  • Internal research and development.
Advertising networks, data analytics providers, marketing services companies, resident services providers.
7. Geolocation Data
We obtain location data from your IP address.
Directly from you, vendors that assist us in providing our services, data analytics providers, operating systems, and other data providers. Providing our services, including maintaining and servicing our homes, marketing, selling advertising, analytics services, and similar functions and services Data analytics providers, resident services providers, marketing services companies.
8. Sensory Data
This may include: audio recordings of resident care and sales calls, electronic, visual, or similar information.
Directly from you or our resident services providers Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services Data analytics providers, call center providers, marketing services companies.
9. Professional or Employment Information Directly from you on your interest forms, application, or resident portal.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services;
  • Protecting against malicious, deceptive, or illegal activity;
  • Internal research and development
Data analytics providers, pre-qualification service providers, marketing services companies.
10. Educational Information We do not collect. We do not collect. We do not collect.
11. Inferences
This may include: creating a profile about a Consumer reflecting the Consumer's characteristics, interests, and preferences.
Directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, operating systems, suppliers, public databases, social media platforms, data append services, and other data providers.
  • Providing our services, including maintaining and servicing our homes, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services;
  • Troubleshooting to identify and repair issues;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing our services;
  • Processing and managing interactions and transactions for our services
Data analytics providers, marketing services companies.

In addition, each of the above referenced categories of PI may be shared with government agencies, other third parties as required by law or compelled by legal process, to the Consumer or other parties at the Consumer's request, and to assignees as part of a merger or asset sale.

2. Your California Privacy Rights

 

Your California privacy rights are described in this section. California Consumers have the right to exercise these rights via an authorized agent who meets the agency and verification requirements of the CCPA. Consumers or their authorized agents should email [email protected] to make requests.

a. Right to Know

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information.

b. Do Not Sell

We do not sell California resident PI and, therefore, we do not offer consumers the option to opt out of the sale of their PI. We do not have actual knowledge of selling the PI of minors under 16 years of age. 

c. Right to Delete

California residents have the right to request deletion of the personal information we have collected from them 

d. Right to Non-Discrimination

We do not discriminate against California residents who exercise their privacy rights.

e. Exercising Your CCPA Rights

We encourage Consumers to make CCPA requests via our privacy mailbox at [email protected] or directly to our mailing address listed below.

We verify residents via their account, or for non-account holders through a third-party service that uses information about Consumer's history to ask questions the answers to which will help us determine if you are who you say you are. If you are not a FirstKey resident, you do not have to create a resident portal account with FirstKey to make a request, but you will have to set up identity verification credentials to exercise your rights. We will use PI provided for purposes of identity verification only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose.

5. Contact Us

For more information on your California privacy rights contact us at [email protected]. You may also write to us at:
FirstKey Homes
1850 Parkway Pl, Suite 900
Marietta, GA 30067
Attn:  Legal Department - Privacy Team