Privacy Policy

FIRSTKEY HOMES, LLC 
PRIVACY POLICY

firstkeyhomes.com

Last Updated: April 17, 2025

FirstKey Homes, LLC (“FirstKey”, “we”, “us” or “our”) respects and is committed to privacy. This privacy policy (“Privacy Policy”) applies to personal information we collect or otherwise process from or about you when you visit or use our websites or applications, such as firstkeyhomes.com, https://careers.firstkeyhomes.com, the FirstKey Homes mobile application, or any other website, application or material that links to this Privacy Policy, or when you otherwise engage with or use our services (collectively, “Services”). This Privacy Policy describes that categories of personal information we may collect, as well as how we may use and disclose that information with respect to the Services.

Depending on our relationship with you, a different or additional FirstKey privacy policy may apply to our collection, use and disclosure of your personal information. Specifically,

·         If you are a California resident, please see our California Notice at Collection and Privacy Policy.

·         If you are a resident of the State of Texas, please see our U.S. Privacy Supplement.

·         If you are applying for a job with FirstKey, please see our Job Applicant Privacy Notice (U.S.)

Please Note: By using or accessing or engaging with our Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy (as may be updated from time to time) and applicable additional policies linked herein, and hereby consent to the collection, use, and sharing of your information as described herein. If you do not agree with our policies and practices, please do not use our Services. Your use of our Services is at all times subject to our Terms of Service (available at firstkeyhomes.com/terms-of-use (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy that lack definitions here are defined in the Terms 
 

Information We Collect

Depending on our relationship with you and how you use our Services, we may collect and process information about you in various ways and from various sources when you use the Services. For example, you may provide personal information directly to us (or to vendors or unaffiliated entities who may be acting on our behalf), we may collect certain information about you automatically, or we may receive information about you from third-party sources or providers.

Information You Provide To Us

You may provide information to us directly or indirectly, such as via service providers and other entities we engage. Such information may include:

• Contact Information. This may include your name, email address, postal address and phone number, including in connection with registering to use our Services, signing up to receive communications from us, submitting a rental application request to view a property, completing a survey or participating in a focus group, or communicating with us in a business-to-business context as a vendor or service provider.

• Employment, Income and Credit Information. For example, when you submit a request to tour a home or a rental application. This may include your current income, housing debt, evictions history, bankruptcy history, criminal history, and information about your credit history.

• Financial and Payment Information. You may submit financial information, such as your credit card information, including in connection with self-guided tours and the submission of security deposits.

• Government Identifiers and Other Documentation. You may submit  documentation to us to apply for a rental property or at various points in the prospective rental applicant journey. Such documentation may include your government-issued ID, Social Security Number, date of birth, employment verification documentation, gender and information you submit to us in connection with us conducting anti-money laundering and sanctions checks.

• Photograph and Biometric Data. You may submit your photograph via a government-issued ID or a real-time photo, including in connection with submitting a rental application or required document or income verification. In some cases, we, our service providers, or other entities may derive biometric data (such as a facial scan or facial topology) from such images. For more information, please see our Biometric Data Policy below.

• Geolocation Data. We may collect the geolocation data associated with your IP address, identifying documentation, or device when you use our Services.

• Audio/Visual Recordings. We may record your voice, image, or likeness, such as when you interact with a call center representative or customer service agent, attend a videoconference or Event, or participate in a meeting with us.

• Information you submit when you communicate with us. This includes, for example, when you ask for more information about a property, request to schedule a tour of a home, provide your home interests or rental preferences and criteria, or submit a maintenance request as a resident of a FirstKey property. Such information may include your move-in date, whether you have pets, monthly income, caller ID, rental information, and rental history.

• Survey Responses and Sweepstakes. We process the information you provide when you complete research surveys, participate in focus groups or enter into sweepstakes we make available to you.

Information We Collect Automatically 

When you use or engage with our Services or otherwise communicate with us, we may use automatic data collection technologies (including cookies, web beacons, and similar technologies) to collect certain information, including personal information, from your devices and your interaction with our Services. The information we collect automatically will depend on the Services you access and use and your engagement with them. It may include:

• Technical Information. We may automatically collect information about your device or web browser, such as:
  • Device Model
  • Device Name
  • Operating System
  • Hardware Version
  • IP Address
  • Referring URL
  • Websites or services you visit before or after visiting our Services
  • Browser or Device Characteristics
  • Language Preferences
  • Country and General Location Information
     
• Usage Information. We may automatically collect information regarding your interaction with and usage of our Services.  Such usage information may include the following:  
  • Details regarding when and how frequently you use the Services.
  • Information regarding your interaction with the Services. This may include what pages you visit, how long you spend on them, the links you click, features and portions of the Services you interact with, and the actions you take.
  • Information regarding your interaction with our emails and messages. This may include whether you open the messages or click links within them or forward the messages. 

Data collected automatically may include information about your online activities over time and across third-party websites, apps, other online services, or across devices. For more information, please see Cookies and Online Tracking Technologies below, along with information regarding how to manage such technologies under Your Choices.

Information We Receive From Other Sources

• Identity and Income Verification Information. In some cases, such as when you apply to tour a rental or submit a rental application, we will ask you to submit documentation for verification purposes. This may include your government-issued ID, documents to verify your employment and income, and other details. We may rely on outside providers to verify that the information and documentation you’ve provided to us is accurate, and in connection with doing so, they may provide additional information about you to us, including information they generate about you based on their review of the documents and information you’ve submitted and information or reports on your credit and employment history.

• Information Obtained Via Third-Party and Social Media Login Features. In some instances, such as with Facebook Connect (also known as Facebook Login) and Google Sign-In, we may give you the option to login using your credentials for a third-party or social platform rather than creating a separate FirstKey login, thereby linking your activity to that platform and account. If you elect to do sign in via one or more of these methods, you will receive a point-in-time notice in which we will ask permission to access certain information from your account associated with the sign-in provider (e.g., Facebook), such as your name. For more information on how data is collected and processed once this third-party login feature is initiated, and how our access can be managed or stopped, please see the terms and conditions and privacy policy of the relevant individual platforms (for example, please see Facebook’s Privacy Policy if you elect to login using Facebook Connect).

•  Information From Social Media Interactions. You may choose to engage with us on such third-party social media platforms. We collect and receive information from you in connection with your use of social media platforms, including when you interact with our social media pages or accounts or via posts you make that are visible to us or messages you send to us.

• Information From Data Suppliers and Internet Listing Providers. We may receive or license information from data suppliers and internet listing providers, which may include name, contact details and other information about current and prospective residents, vendors, suppliers and business partners.

 

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information, in a variety of ways, including:

• To present our Services and their content to you.
• To provide you with information on products or services that you request from us.
• To operate, maintain, and provide to you the features and functionality of the Services and otherwise for the purposes for which you provide your information to us.
• To process transactions that you have requested, including any payments or changes to your account information.
• To analyze how the Services are used, diagnosing service or technical problems, maintaining security, and personalizing content.
• To provide you with notices about your account, including expiration and renewal notices.
• To communicate with you, including regarding information, features, or offers that we believe will be of interest to you, in response to your questions and requests, and to notify you about changes to our Services, policies, and terms.
• To conduct surveys.
• To reach out to you about and market new products or services to you, including via email and via SMS/text.
• To engage in targeted advertising, which may include providing your information to third parties throughout the advertising ecosystem. Please see Cookies and Other Tracking Technologies and Third-Party Rights to Information below for additional details.
• To create deidentified, statistical and aggregate information which is no longer personal information.
• To improve our Services.
• To satisfy our legal obligations and as may otherwise be permitted or required by law.
• To carry out our obligations and enforce our rights arising from any contracts entered into with you.
• As permitted by law or as we may notify you.
• In any other way we describe when you provide the information, or otherwise at your direction or with your consent.

Use of AI

Please note that we may use tools or programs powered by artificial intelligence (“AI” and (“AI Tools”)) to process your personal information. Some AI Tools may be developed by us and others may be developed by other entities and deployed by us, or by our others on our behalf. We or entities we engage may leverage AI Tools in various circumstances, including in connection with our review of documentation you provide when submitting a rental application, where we may use an AI Tool to, for example, identify fraudulent documents or statements. We may also leverage AI Tools in our communications with you. For example, we may use AI tools to generate responses to common questions or in an effort to improve our conversations and interactions with you, including based on the types of inquires we may receive from you.

How We Share or Otherwise Disclose Your Information

We may share your information with affiliates and nonaffiliated entities, including our service providers and other entities we rely on or with whom we do business. For example, the instances in which we may share or otherwise disclose your personal information include, but are not limited to:

• To provide the Services and fulfill your requests. We share your personal information as necessary to provide the Services, fulfill your requests, and otherwise in connection with the operation of our business.
• Service Providers, Business Partners and Other Third-Party Entities. We may disclose your personal information to our service providers and other entities we engage and may otherwise permit such entities to process your personal information. This includes, without limitation, service providers, business partners and other entities that send communications, process payments, analyze data, assist with utility billing or renter's insurance, provide credit checks, resident screening, offer collection services, provide marketing assistance, engage in advertising, or create, host, and/or provide customer service on our behalf. We may also disclose your Personal Information to companies whose products or services we think may be of interest to you.
• Affiliates and Subsidiaries. We may disclose your information to affiliates and subsidiaries for their and our business purposes and for marketing purposes, including to provide you information about products or services we think may interest you.  
• Legal Obligation or Safety Reasons. We may disclose personal information to third parties when we have a good faith belief that such disclosure of personal information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or governmental request; (b) enforce or investigate a potential violation of any agreement you have with us; (c) detect, prevent, or otherwise respond to fraud, security, technical concerns, or illegal activities; (d) support auditing and compliance functions; or (e) protect the rights, property, or safety of FirstKey, its employees and clients, or the public against harm.
• In Connection With a Sale of All or Part of Our Business, or Other Transaction. Please note that if FirstKey or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we may possess about you, and information collected pursuant to this Privacy Policy, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
• Otherwise at your direction or with your consent.

Cookies and Other Tracking Technologies

We and entities we engage, including our service providers, may use cookies (i.e., small text files that are stored on your browser, computer, or mobile device), web beacons, pixel tags, browser analysis tools, server logs and other tracking technologies to automatically collect information, including personal information, such as your IP address, from your browser. For more detail regarding the type of information that may be collected automatically please see Information We Collect Automatically above.

We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Website or Services.

We use cookies and other tracking technologies for a variety of purposes, including functional, analytics, session replay, marketing and advertising purposes. For example, we, our service providers and other entities we engage use cookies and other tracking technologies:

• For functional purposes, such as to provide the Website and its content to you.
• For website delivery and appearance purposes. For example, we may incorporate content from third-party providers like Font Awesome via their content delivery networks. We may use Font Awesome to serve icons on our Websites and to enhance the performance of our Websites (for more information, please see the Font Awesome Privacy Policy).
• To enable customer interaction opportunities and provide customized content, including location-relevant content. For instance, we may use Google Maps or enable specific content delivery such as audio and video via YouTube, each of which may result in Google placing a pixel or cookie that collects information about your use of our Services. For more information, please see Google’s page on “How Google uses data from sites or apps that use our services” and Google’s Privacy Policy.
• To optimize your experience within our Services, such as facilitating and speeding up searches.
• For analytics purposes, such as to provide us with information about which portions of our Services are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page, and what communications are of interest to a user. For example, we may use Google Analytics. To learn more about how Google uses data collected from you via Google Analytics, please visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
• To market our products and Services, and other products and Services we believe you may be interested in, to you.
• To better understand user behaviors and usage of the Services through third-party session replay services. We use third-party session replay services, including Qualtrics, to record and better understand user behavior, friction points, and to inform future service or technology improvements. For more information on Qualtrics, including its data collection and processing practices, please see their privacy policy here.
• To personalize your experience on our Website or in our interactions with you (e.g., to recognize you by name when you return to our Website, to save your password in password-protected areas, or to tailor content, or product and service offerings to you).
• For advertising and related purposes, such as to provide targeted ads to you that we or third parties believe may be relevant to your interests, or to measure attribution and other advertising-related statistics. For example, we use Google Ads (including Google Dynamic Remarketing and DoubleClick), and other third parties to serve ads for our Services across various websites.
• To diagnose or fix technology problems, prevent fraud, and otherwise improve security.

Third-Party Rights to Your Information

We may permit our third-party partners to obtain information about you when you use our Services, including in an effort to serve targeted, interest-based advertisements to you, for analytics purposes, and in connection with session replay services. This information may include your IP address, mobile device ID, and advertising ID and other information that is collected from you automatically. Such information is obtained through cookies and other tracking technologies. These third-party partners and others may collect similar information from you across other websites and over time. We, our third-party partners and others may use this information, including to engage in targeted advertising and display ads or other targeted content to you that is believed to be relevant to you based on your use of our Services, other sites, and other information we may collect about you. Such ads and targeted content may appear on or within our Services and/or across other domains, services, or applications. In connection with services provided by these third parties, we may grant such third-party partners independent rights to your personal information (e.g., your IP address), including rights to use your personal information for their own purposes. In such cases, we do not control those third parties’ further use of your personal information and such use is governed by those third parties’ respective privacy policies.

Your Choices

Opting Out of Cookies & Other Tracking Technologies

Cookie Management Tool. We have implemented a cookie consent management tool. To manage your preferences with respect to certain categories of cookies, please click the Cookie icon on firstkeyhomes.com and make your selections.

DAA Self-Regulatory Program. Some of the advertisers, partners and other entities that we rely on to serve ads may participate in the Digital Advertising Alliance’s ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding online interest-based advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps.

NAI. Some companies we work with or rely on may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for its members, visit the Network Advertising Initiative Opt-Out page.

Browser Settings. Most web browsers provide you with the ability to block, delete, or disable cookies and other tracking technologies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features or functionality of our Services may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

Please Note. Managing your cookie settings via the mechanisms set forth above will not opt you out of all online advertisements. You will continue to receive generic advertisements online, though they may not be relevant to your perceived interests.

Your selections regarding cookies and other tracking technologies are typically browser and device specific. This means that if you use a different browser or device, or clear your cookies, any choices you have made with respect to cookies and other tracking technologies, including any opt-outs, will no longer apply.

Opting Out of FirstKey Commercial Communications

We may send you communications and notifications of activity on the Services to the email address or phone number you provide to us.

We may use your email address and other contact information (e.g., phone number) to communicate with you to send you other messages or content, such as, but not limited to, newsletters, notices regarding additions or changes to the Services, or special offers. If you do not want to receive such commercial messages, you may opt out by emailing us your request [email protected] or opting-out via the unsubscribe link contained in the email.

Please note that you cannot opt out of transactional messages, such as certain Services-related emails, including those that alert you to the status of your rental application.

Accessing and Changing Your Information

Through your account settings, you may access, and in some cases, edit or delete certain information you have provided to us, which may include your name and password, email address, location, user profile information, or other content you have uploaded to the Services.

The information that you can view, update, and delete may change, particularly as the Services change. Please note that even if you request to delete information or deactivate or delete your account, we retain your personal information as set forth in Retention of Your Information below. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].

Biometric Privacy Notice

In some cases, we or entities we engage may collect or otherwise process information about you that may be considered “biometric data,” “biometric information,” or “biometric identifiers” under applicable laws (collectively, “Biometric Data”). This Biometric Privacy Notice defines our policies and procedures for the collection, use, safeguarding, storage, retention, and destruction of Biometric Data that may be collected, stored, or otherwise processed by us or entities on which we rely. 

We and entities on which we rely may use biometric identification systems, which may be powered by AI, in an effort to detect and prevent fraud in our resident application process. Specifically, we or entities we engage may process photos of you and collect Biometric Data (specifically, facial scans or facial topology) from them. Such data is processed by us and/or entities acting on our behalf for purposes of providing security, authentication, and fraud-prevention services. Our policy is to protect and store such data in a manner that is the same as or exceeds the standards we follow in maintaining other confidential and sensitive information. We only collect such data with prior written consent. We do not sell, lease, trade or otherwise profit from an individual’s Biometric Data. We rely on other entities and their providers to process and collect Biometric Data, and such data is disclosed to them, but we do not otherwise disclose such Biometric Data unless consent is obtained or disclosure is required by law, such as by a subpoena. Subject to applicable legal requirements, which may require us to retain Biometric Data for a longer time period, we do not retain facial scans or facial topology that constitutes Biometric Data for longer than thirty (30) days.

Third-Party Links and Connections

Our Services include links and connections to third-party websites, applications and services whose privacy practices may differ from those of FirstKey.  These third-party sites and services are not operated or controlled by us, unless specifically stated otherwise thereon. The entities operating these sites and services may use cookies and other similar technologies to collect information, including about your navigation from our Services to the relevant third-party site or other service, which may be used for attribution purposes or in connection with targeted advertising. We are not responsible for the privacy practices of third-party sites and services, and you should consult the other third-party sites and services’ privacy notices in order to better understand their privacy practices. 

Social Media Networks

Our Services may include social media buttons, widgets, application program interfaces (APIs), and/or plug-ins (Plug-ins) from third-party social media networks, including Facebook, LinkedIn, Xing, X (formerly known as Twitter), Instagram, YouTube, Tumblr, Pinterest and/or other companies. These features may use cookies or other tracking technologies to collect your IP address, the page(s) you are visiting on our Services, and other information, including information that enables the feature to function properly.

Please remember that the ways in which social media networks use, store, and disclose your information is governed by the privacy policies of the companies providing them and FirstKey is not responsible for those companies’ privacy and data sharing practices or other actions of any social media network through which you may engage with FirstKey.

Security

FirstKey has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password secure. You should not share your password with anyone. You can help prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

The transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your personal information, we cannot guarantee the security of your personal information transmitted to us or which we obtain. Any transmission of personal information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites or used by us, providers on which we rely, or within our Services.

Children's Privacy

Our Services are not intended for users under the age of 16, and FirstKey does not knowingly collect information from anyone under the age of 16. No one under the age of 16 is permitted to access or use our Services or provide us with personal information. If you are a parent or guardian and believe we have collected information from your child, please contact us at [email protected].

Retention of Your Information

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. This includes retention of your personal information and other data, including your profile information, following termination or deactivation of your account. Please note that we have the right to delete all your personal information and other data after termination or deactivation of your account without notice to you.

Nevada Consumer Privacy Notice

Nevada consumers may opt out of the “sale” of “covered information” as such terms are defined under Nevada law. We do not currently sell data triggering that statute’s opt-out requirements. If you have questions about this, you can email us at [email protected].

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. We will alert you to changes by placing a notice on our Websites, as part of the Services, or otherwise in accordance with applicable law.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please email us at [email protected].

You may also write to us at:

FirstKey Homes

600 Galleria Parkway, Suite 300

Atlanta, GA 30339

Attn: Legal Department - Privacy Team