Legal Information

CCPA Privacy Policy

FIRSTKEY HOMES, LLC
CALIFORNIA CONSUMER PRIVACY POLICY


firstkeyhomes.com

Last Updated: June 14, 2024

This California Consumer Privacy Policy (“Policy”) applies to FirstKey Homes, LLC (“FirstKey”, “Owner” “we”, “us” or “our”) and “Consumers” (“Consumer” or “you”) as defined by the California Consumer Privacy Act and/or the California Privacy Rights Act (together, with related regulations, the “CCPA”) and applies along with our Privacy Policy located at www.firstkeyhomes.com/legal/privacy-policy and any other privacy policy or notice presented to you in connection with our Services. In the 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.

Consumers have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.

The below chart reflects the categories of personal information we have collected from Consumers during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information. For purposes of the table below, resident services providers include call

center vendors, maintenance technicians, security providers, and other similar vendors.

Categories of Personal Information Sources of Collection Business or Commercial Purpose for Collection Categories of Third Parties Receiving Personal Information Retention Period
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.

For job applicants: Recruiters; background check 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.
  • For job applicants: Process and assess your application.

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.

For job applicants: Background check providers; human resource providers; technology providers and technology support services.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
2. Customer Records Information This may include 

(per Cal. Civ. Code § 1798.80(e)): name,: 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.

For job applicants: Recruiters; background check 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.
  • 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.

For job applicants: Human resource providers; technology providers and technology support services.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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. The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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 The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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, including identity verification and/or background check providers.

For job applicants: Human resource providers; technology providers and technology support services.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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.

For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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.

For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms; payroll and benefit providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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.

For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms; payroll and benefit providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
9. Professional or Employment Information

Directly from you on your interest forms, application, or resident portal.

For job applicants: Recruiters; background check 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;
  • Protecting against malicious, deceptive, or illegal activity;
  • Internal research and development
  • For job applicants: Process and assess your application.

Data analytics providers, pre-qualification service providers, marketing services companies.

For job applicants: Background check providers; human resource providers; technology providers and technology support services; payroll and benefit providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
10. Educational Information For job applicants: Recruiters; background check providers. For job applicants: Process and assess your application. For job applicants: Background check providers; human resource providers. The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
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. The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

 

 

 

Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140 Sources of Collection Business or Commercial Purpose for Collection Categories of Third Parties Receiving Personal Information Retention Period

Social security number, driver’s license number, state

identification card, or passport number.

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.

For job applicants: Recruiters; background check 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.
  • For job applicants: Process and assess your application.

Background check providers; human resources software providers; payroll and benefit providers; technology providers and technology support services

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

Barring any legally required additional retention period, up to three years for non-hired applicants.

Citizenship or Immigration Information

Directly from you on your interest forms, application, or resident portal.

For job applicants: Recruiters; background check providers.

  • To satisfy legal obligations
  • For job applicants: Process and assess your application.

Human resources software providers;payroll and benefit providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

Account access credentials (user names, account numbers, or card

numbers combined with required access code, security code or password

to access an account).

Directly from you

Fulfill or meet the reason you provided the information; provide you with our products and services; protect and secure our environment.

Payroll and benefit providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms. The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

Precise geolocation

(location within a geographical area of a circle with a radius of 1850 feet or less).

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Racial or ethnic origin

 

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Religious or philosophical beliefs

 

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Union membership

 

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Genetic Data

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Mail, email, or text messages where the content is not directed to us.

 

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Unique identifying biometric information

Directly from you

Verify your identity, protect and secure our environment.

Identity verification, background check, or security providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

Personal information collected and analyzed concerning health.

 

We do not collect

Not applicable.

Not applicable.

Not applicable.

Personal information collected and analyzed concerning sex life, or sexual orientation.

 

We do not collect

Not applicable.

Not applicable.

Not applicable.

In addition, each of the above referenced personal information categories may be shared with government agencies or other third parties as required by law or compelled by legal process; to assignees as part of a merger or asset sale; to respond to an emergency or otherwise protect the rights, property or security of our customers, third parties, or FirstKey; exercise or defend the legal rights of FirstKey and its employees, affiliates, customers, contractors, and agents; or to other parties at the Consumer’s request (or to the Consumer directly).