Legal Information

Privacy Policy

FIRSTKEY HOMES, LLC
PRIVACY POLICY


firstkeyhomes.com

Last Updated: June 13, 2024

FirstKey Homes, LLC (“FirstKey”“we”“us” or “our”) respects privacy of our users and we are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”), which describes the types of information we may collect when you visit or use our websites or applications (including firstkeyhomes.com, https://careers.firstkeyhomes.com, the FirstKey Homes mobile application, or any other website or application that links to this Privacy Policy) (“Websites”, “App” or Websites/App”), apply for a job at FirstKey or to become a renter (“Applicants”), or otherwise use our services or renter portal (collectively, “Services” ), as well as how we may use or share that information.

By using or accessing our Websites, App or Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy (and as updated from time to time), 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, you may choose not to use our Websites, App or Services. Your use of our Websites, App or Services is at all times subject to our Terms of Service (available at firstkeyhomes.com/terms-of-use (the firstkeyhomes.com/terms-of-use (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Summary of Information We Collect

We may collect information from and about Users and Applicants such as the time and date of your Website/App visits, your internet connection, the equipment you use to access our Websites/App, and other usage details. We may also collect information connected to you specifically, such as your name, mailing address, email address, and telephone number. Should you choose to complete a job or rental application, we will collect additional information about you to process your application (such as employment information and a background check).

Please see the Information We Collect section below for additional information on the data we collect and how we use it.

Summary of Information We Share

We may share personal information, or give others access to it, for the reasons described in this Privacy Policy. See the Information We Share section for additional details, including any opt outs offered. These reasons include, for example:

  • Delivering, operating, improving, and marketing our Services, Websites/App.
  • Processing job and rental applications.
  • Tailoring advertising to make it more relevant to your household and improve its effectiveness.
  • Supporting corporate transactions (e.g., merger or sale).
  • Cooperating with law enforcement and complying with legal requests (see Legal Requests below).
  • Facilitating your use of third-party services.

Summary of Security

Although we do use security measures designed to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. More at Security below.

 

Summary of Children's Privacy

Our Websites, App and Services are intended for adult use; registrants must be the age of majority in their jurisdiction to use them. FirstKey's policies and practices regarding children's personal information are explained in the Children's Privacy section below.

Summary of Your Information Rights

Through your account settings, you may access information you provided to us and edit or delete it in some cases. To learn more about your general ability to access and manage information via your account settings, please see Accessing and Changing Your Information below.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California residents, for example, are entitled to exercise certain rights as described in our California Consumer Privacy Policy. To learn more about your individual rights and how to exercise them, please scroll to the policy section for your jurisdiction.

 

DETAILED PRIVACY POLICY

Information We Collect

We may collect a range of personal information, including information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of information from and about Users and Applicants that we may collect include:

  • Contact Information – If you submit an inquiry or application, register for an account, or provide information on or through our Services, we may collect your contact information. This may include your name, address, email address, demographic information, phone number, social security number, and any other identifier by which you may be contacted online or offline. 
  • Commercial Information – If you submit an inquiry, or provide information on our Websites/App, we may collect commercial information including information about Services you have shown interest in. This may include financial information whenever the interaction involves a financial transaction (including, but not limited to, rent payments). 
  • Usage Information – When you use our Websites/App, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Websites), domain names associated with your internet service provider, and any other information regarding your interaction with our Websites.
  • Employment Information – If you apply for employment with us, we will collect information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
  • Communication Information – We may collect information contained within your communications with us. We may collect and maintain recordings of calls and other communications with our agents, representatives, or employees.

This Privacy Policy applies to information we collect, directly or indirectly, via:

  • Our Websites, App, and Services.
  • Email, text, and other electronic messages between you and us.
  • Interactions with our advertising and applications on third-party websites, apps and services (provided those third-party sources include links to this policy).
  • Third-party service providers, such as recruiters, job application portals, or background check providers.
  • Offline interactions, such as when you submit a paper application to rent a home, make a rent payment by check, or call or visit our office.

We gather various types of personal information from our Users, as explained in more detail below, and we use this personal information to provide you with our Services, including to personalize and improve our Services, to allow you to set up a user account and profile, to contact you, to fulfill your requests for certain products and services, to provide and improve the Services, and to analyze how you use the Services. In certain cases, we may also share your personal information with third parties as described below.

We are not responsible for the practices of third-party sites linked from the Services, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.

How We Collect Personal Information

We collect this information:

  • Directly from you when you provide it to us. See Information You Provide to Us below for more on what this entails.
  • Automatically as you navigate through our Websites/App. See Information We Collect through Automatic Data Collection Technologies for more information on what this category can include and how it is collected.
  • From third parties, for example, our business partners. For job applicants this could include, for example, recruiters and background check providers.

Information You Provide to Us

The information we collect from you may be provided while:

  • Signing up for our Services. This may include, for example, your name, email address, and phone number.
  • Submitting a rental application. For example, you may provide us with your employment and income information and information about individuals who intend to reside with you.
  • Submitting a job application. For example, you may provide us with your resume, employment information, education information, salary and compensation information, and referral or background check information.
  • Completing forms on our Websites/App. This may include, for example, registering to use our rental portal or other Website/App features, requesting maintenance or other services, or reporting a problem with our Websites/App or Services.
  • Interacting or corresponding with us in any manner, including via email, text, and other electronic messages.
  • Completing research surveys or participating in focus groups.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites/App, we may use automatic data collection technologies (including cookies, web beacons, and similar technologies) to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Websites/App, including traffic data, logs and other communication data and the resources that you access and use on our Websites/App.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites, apps, other online services, or across devices.

For more information on how and when we may share this information with third parties, please see the Information We Share section below.

Information We Collect and Share during the Resident Journey

These are the types of information we collect from you and who we may share that information with as you navigate through the resident journey:

Resident Journey Data we collect Partners who may see your information
Prospective Resident searches online or calls our Call Center IP address, caller ID, home interests, voice recording of call, interactions with the Website and ads Online analytics and advertising providers, call center services, internet listing service, self-guided tour providers
Prospective Resident submits a contact form. Name, email, postal address, phone number Online analytics and advertising providers, call center, pre-qualification providers
Prospective Resident schedules tours of our homes. Phone number, name, email, move-in date, pets, monthly income, housing debt, evictions history, bankruptcy history, criminal history, government-issued photo ID, real-time photograph, credit card info, social security number, credit history and rental history Call center, self-guided tour providers, payment processors, online analytics and advertising providers
Prospective Resident submits an application and becomes an Applicant. Name, email, postal address, phone number, credit card info, SSN, home interests, credit history, rental history, criminal history, government-issued photo ID, real-time photograph, biometric identification data, income and debt. Self-guided tour providers, call center, ERP system, internet listing service, credit check providers, identity verification service provider
Applicant submits identification and financial documents Income and employment info, driver's license number, passport number (or other government-issued ID), real-time facial image for biometric ID verification Self-guided tour, call center, ERP system, internet listing service, credit check providers. identity verification service provider
Applicant signs lease, pays deposit, and becomes a Resident. Names and ages of residents, renter's insurance policy, financial info, pets, gender, phone number, SSN, market location, date of birth ERP system, call center, utilities company, insurance company, rent payment company, payment processors, lawn care company, OFAC search provider, loyalty program provider; at user's election: furniture company, appliance company or other partners
Resident moves into home Move-in condition of home, satisfaction survey response, date of move-in Call center, resident portal provider, survey provider
Resident submits service request. Name, service request info, availability, satisfaction survey response Resident portal, maintenance vendors, survey provider, call center
Resident receives renewal notice/offers. Resident accepts and signs another lease. Name, email, postal address, phone number, financial/transaction info. Call center, resident portal, rent payment company, payment processors
Resident moves out of home Forwarding address Call center, resident portal

Information We Collect and Share during the Job Application Process

These are the types of information we collect from you and who we may share that information with as you navigate through the job application process:

Job Applicant Process Data types we may collect Partners who may see your information

Initial application

Personal identifiers, contact information, educational information, employment history and professional information, resume information, reference information, sensitive personal information and/or demographic information, location for employment, and any other information you provide in support of the application or that’s collected automatically while navigating the associated Websites.

Employee recruitment service providers (e.g., recruiters), hiring partners, human resource providers, website or mobile application hosting providers, email-service providers, and other service providers that provide services to us or on our behalf during the job application and hiring process. 

Interview and evaluation process

Information from any interviews you may have; reference, background, and/or credit check information, including performance information and other information provided by third parties; current or desired salary and other terms relating to compensation and benefit packages; job preferences; publicly available information.

Employee recruitment service providers (e.g., recruiters), hiring partners, human resource providers, website or mobile application hosting providers, email-service providers, and other service providers that provide services to us or on our behalf during the job application and hiring process.

Decision-making and potential onboarding

Banking information, income history and information, benefit information; sensitive personal information and/or demographic information (e.g., social security number, gender, information about citizenship or nationality, medical or health information, disability status, and/or racial or ethnic origin).

Employee recruitment and hiring partners (e.g., recruiters), human resource providers, benefit and payroll providers, website or mobile application hosting providers, email-service providers, and other service providers that provide services to us or on our behalf during the job application and hiring process.

     

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Websites/App and their content to you.
  • To provide you with information on products or services that you request from us.
  • To process your rental or job application.
  • To provide you with services or process transactions that you have requested.
  • For analyzing 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 operate, maintain, and provide to you the features and functionality of the Services.
  • To communicate with you regarding information, features or offers that we believe will be of interest to you.
  • To communicate with you regarding the rental or job application process.
  • To respond to your questions or other requests.
  • To contact you regarding our Websites/App and Services.
  • To process any payments or changes to your account information.
  • To process other information that you submit through our Websites/App.
  • To conduct surveys.
  • To notify you about changes to our Websites/App, policies, terms or any products or services we offer or provide though them.
  • To allow you to participate in interactive features on our Websites/App.
  • To fulfill any other purpose for which you provide it.
  • To satisfy our legal obligations.
  • According to any other way we described when you provide the information.

We use tracking technologies like cookies, web beacons, embedded scripts, log file, location-identifying technologies, device recognition technologies, and device and activity monitoring to:

  • Remember information so that you will not have to re-enter it during your visit or the next time you visit our Websites/App, including across devices when possible.
  • Provide custom, personalized content and information, including location-relevant content.
  • Optimize your experience within our Website/App, such as facilitating and speeding up searches.
  • Monitor the effectiveness of our Services.
  • Monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns.
  • Diagnose or fix technology problems, prevent fraud, and otherwise improve security.
  • Market our Services or other products and services that may be of interest to you.
  • Help you efficiently access your information after you sign in.

For more information about cookies and related technologies, including how and when we share it with third parties, please see the section on Cookies and Other Tracking Technologies.

 

Information We Share

We may your Personal Information in the following circumstances:

  • Service Providers – We disclose your personal information with service providers as necessary to enable them to support our Services or other aspects of our business. This includes, without limitation, service providers that send communications, process payments, analyze data, assist with utility billing or renter's insurance, provide credit checks, resident screening, or collection services, provide marketing assistance, or create, host and/or provide customer service on our behalf. This also includes service providers involved in our recruitment and hiring processes, including but not limited to those involved in processing job applications like recruiters and background check providers.
  • 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 the products or services we think may interest you.  Please note that no mobile information will be shared with third parties/affiliates for marketing/promotional purposes
  • Business Partners – We may disclose personal information with trusted business partners or corporate affiliates. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with. 
  • Event-Related Disclosures – From time to time, we may run contests, special offers, or other events or activities ("Events") on the Service together with a third-party partner. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent.
  • 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.
  • Merger, Change of Control, or Asset Transfer – We may disclose personal information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business or an asset transfer, including but not limited to, a bankruptcy or similar proceeding.

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Websites.  We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Websites, to enhance your experience through personalization, and to help us better understand the features of our Websites that you and other users are most interested in. 

  • Website Delivery and Appearance – We may incorporate content from third party providers like Font Awesome. We 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).  We also use services to enable certain customer interaction opportunities—such as Google Maps (available per the Google Maps/Google Earth Terms of Service and Google’s Privacy Policy) or enable specific content delivery like audio and video via YouTube (for more information about YouTube, see Google’s Privacy Policy).
  • Website Analytics and Session Replay – We use analytics and session replay services, that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Website traffic and site usage. These include, but are not limited to, the following third-party services:
  • Session Replay: We also use third-party session replay services, including Qualtrics, to 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.
  • AdvertisingWe allow or enable third parties to collect Personal Information to provide their interest-based advertising services, and we use Google Ads (including Google Dynamic Remarketing and DoubleClick), and other third parties to serve ads for our Services across various websites. To opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.

In addition, some of the advertisers and Service Providers that perform advertising-related services for us 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. Some of these companies 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. Please note this does not opt you out of all ads, only targeted ads. You will continue to receive generic advertisements online.

Most browsers also provide you with the ability to block, delete, or disable cookies, 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 or Websites may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.

FirstKey Homes is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Links to Other Websites and Social Media Plugins

We share information with third-party apps and websites that integrate with our Services, or those with an API or Service with which we integrate. Our Websites include links to other websites whose privacy practices may differ from those of FirstKey. If you submit personal information to any of those websites, your information is governed by their respective privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Our Websites include social media buttons, widgets, application program interfaces (APIs), and/or plug-ins (Plug-ins) from social networks, including Facebook, LinkedIn, Xing, X (formerly known as Twitter), Instagram, YouTube, Tumblr, Pinterest and/or other companies. These features may use a cookie to collect your IP address, the page(s) you are visiting on our Services, and otherwise enable the feature to function properly. Your interactions with these features are governed by the privacy policies of the companies providing them. For more information about how YouTube collects and processes personal information, for example, please see Google’s privacy policy.

In some instances, such as Facebook Connect (also known as Facebook Login), we may give you the option to login using the credentials for that platform rather than creating a separate FirstKey login, thereby linking your activity to that platform and account. If you elect to do so, you will receive a point-in-time notice in which we will ask permission to access certain information from that account, like your name. For more information on how data is collected and processed once this alternative login feature is initiated, and how our access can be managed or stopped, please see the terms and conditions and privacy policy of the individual platform (for example, please see Facebook’s Privacy Policy if you elect to login using Facebook Connect).

Security

We have 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 Websites or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must 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 information you share in public areas on social media platforms may be viewed by other Users. We'll never email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.

Unfortunately, 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 with our Services.

Children's Privacy

We do not knowingly collect, solicit, or maintain personal information from minors as defined under applicable law or knowingly allow such persons to register for our Services. If you are a minor, please do not send any personal information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected personal information from a minor without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us at [email protected] if you believe we have information from or about a minor.

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, including name and password, email address, location, user profile information, including any content you have uploaded to the Services.

The information that you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].

We may send you notifications of activity on the Services to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Services, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your request [email protected]. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Services-related emails.

Retention of Your Information

You may be able to add, update, or delete information as explained above. You may request deletion of your account by emailing us at [email protected].

Following termination or deactivation of your account, we may retain your profile information. Following termination or deactivation of your account, we may retain your personal information and other data, but will maintain it as confidential according to this Privacy Policy and as required by applicable law. We have the right to delete all of your personal information and other data after termination of your account without notice to you.

California Consumer Privacy Notice

California residents, please click here for additional information about your California privacy rights.

Colorado Consumer Privacy Notice

Colorado’s Privacy Act (CPA) gives customers the right to request: (1) confirmation of whether we process their personal information and to access it; (2) correction of inaccurate personal information; (3) deletion of certain personal information, (4) a copy of their personal information in a portable format; and (5) to opt-out of personal information processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.

While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CPA. The CPA broadly defines “sale” in a way that may include activities such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. For more information on how and when we share such information, please see the above policy section on Information We Share. If you would like to opt out of this sharing, you may exercise your right by modifying your cookie settings, or you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, visit: https://globalprivacycontrol.org/.

To exercise your rights, or appeal the denial of a request, you (or your authorized agent) may contact us via email at [email protected], call us at 844-395-3959, or write to us at the address found below in the “Contact Us” section.

When requests are received via email or mail, we may verify residents via their account, or for non-account holders through a third-party service that uses information about your 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 work with the third-party service to verify your identity. Agents may also need to provide evidence of their authority to act on behalf of the Consumer, in addition to verifying their identity and that of the Consumer involved. We will use personal information 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.

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].

Texas Consumer Privacy Notice

Texas law provides state residents with rights to: (1) confirm whether we process their personal information; (2) access and delete certain personal information; (3) correct inaccuracies in their personal information; (4) obtain a copy of their personal information in a portable format; and (5) opt-out of personal data processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise your rights, or appeal the denial of a request, you may contact us via email at [email protected] or write to us at the address found below in the “Contact Us” section.

Biometric Privacy Notice

This Biometric Privacy Notice defines our policy and procedures for the collection, use, safeguarding, storage, retention, and destruction of biometric data, which includes "biometric information" and "biometric identifiers" as defined under applicable laws (collectively, "Biometric Data") collected by us and our Service Providers. We use biometric identification systems to detect and prevent fraud in our application process, and as a result, biometric data is only disclosed to and stored with trusted Service Providers that provide security, authentication, and fraud-prevention services to us. Our policy is to protect and store biometric 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 biometric data with prior written consent. We will not sell, lease, trade, or otherwise profit from an individual’s biometric data. We will not disclose biometric data unless (a) consent is obtained, (b) disclosure is required by law, or (c) disclosure is required by a subpoena. We will permanently destroy all biometric data within a reasonable time, and in no event will we retain biometric data for longer than thirty (30) days.

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

1850 Parkway Place. Suite 900

Marietta, GA 30067

Attn: Legal Department - Privacy Team