Privacy Policy

2. Under this Privacy Policy, personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.

– Information excluded from the CCPA and CPRA’s scope and covered by certain sector-specific privacy laws, including but not limited to Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

3. Business purposes for which we may use or disclose your personal information. We use the categories of personal information listed above to provide our products and services to you, to operate, manage, and maintain our business, and to accomplish the following business and commercial purposes, including the following:

• To fulfill or meet the reason for which the information is provided;
• To provide you with information, products or services that you request from us directly or indirectly;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing;
• To provide customer service, maintain and servicing accounts, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business;
• To improve our website and present its contents to you;
• To establish and maintain your user account with us;
• To authenticate you;
• To detect fraud and prevent loss, or as necessary or appropriate to protect the rights, property, or safety of us, our users and customers, or others;
• To debug, to identify and repair errors that impair existing intended functionality;
• To allow you to contact us and facilitate your communication with us;
• To respond to your feedback, requests, questions, or inquiries;
• To provide offers to eligible users or customers;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA and the CPRA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. Sources from which we obtain your personal information. We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

From social media websites that you use to log in or subscribe

5. Use of Personal Information. We may use, or disclose the personal information we collect for one or more of the following business purposes:
   • To fulfil or meet the reason for which you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
   • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses, products and services.
   • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
   • As described to you when collecting your personal information or as otherwise set forth in the CCPA and CPRA.
   • We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. Sharing Personal Information. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Payment processors (e.g. Paypal, Stripe, or Plaid) for the purposes of facilitating a payment;
• Google Analytics for website metrics;
• Hosting such as Amazon Web Services. However, we don’t explicitly share any information with web service providers.
• Transactional partners or affiliated entities such as brokers, lenders, banks, real estate agents, title officers, escrow officers, insurers, purchasing parties, professional service providers, transactional service providers, etc.
• Disclosures of Personal Information for a Business Purpose: In the preceding twelve (12) months, RealKey has not explicitly disclosed personal information for a business purpose.
• Sales of Personal Information in the preceding twelve (12) months: RealKey has not sold personal information in the preceding twelve (12) months.

7. Your California Consumer Rights. The California Privacy Laws provide California residents with specific rights regarding their personal information. You may submit these requests to us as described below, and we honor these rights where they apply.

(1) Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you (also called a data portability request);
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

(2) Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions listed in Sec. 8 below. 

(3) Right to Opt-Out of Sale/ Sharing. You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so. We do not sell or share any personal information as defined by the CPRA. Therefore, we include this disclosure of information for informational purposes only.

(4) Right to Non-Discrimination. We will not discriminate against you, in terms of price or services that we offer, if you submit one of the rights requests listed above.

(5) Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you. Our goal is to keep your personal information accurate, current, and complete.

(6) Right to Limit. In limited circumstances, a Consumer has the right to limit the use and disclosure of Sensitive Personal Information. Our use of your Sensitive Personal Information is solely for Business Purposes, and not for those purposes for which a Consumer may exercise right to limit the use or disclosure under the California Privacy Laws. Therefore, we include this disclosure for informational purposes only.

8. Exercising your California consumer rights.

1. 1. Request Submission. To exercise your California privacy rights,, you need to submit a verifiable consumer request to us by sending us a message to our customer service at Support@RealKey.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
      • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
      • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
   2. Response Timing and Format. Upon receiving a request to know, request to delete, or request to correct, we will confirm receipt of the request within [ten (10)] business days and provide information about how we will process your request. The information provided will describe our verification process and when you should expect a response from us. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
   3. Delivery. Except as otherwise provided by applicable law, the information will be provided in writing or through our website. We will respond by mail. If we do not take action on your request, we will, without delay and, at the latest, within the time period permitted for our response, inform you of the reasons that we did not take action and any rights you may have to appeal the decision.We are committed to responding to your requests to exercise Consumer rights in accordance with applicable law and the California Privacy Laws. However, your rights are subject to certain limitations:
      1. We will respond to requests to know by the same user no more than twice in a twelve (12) month period.
      2. A response to a Request to Know may be limited to the 12-month period preceding receipt of the request if it would be impossible, involve disproportionate effort, or the request is for data for a specific time period.
      3. In response to a Right to Know request, we are prohibited from disclosing social security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you whether we have collected that type of information.
      4. Other limitations to consumer rights under the California Privacy Laws may apply. For example, we will not able to comply with your request to delete your personal information if it is necessary for certain legitimate business purposes or exercising legal obligations.

      We are not required to delete your personal information if it is reasonably necessary for us, our service providers, or our contractors to maintain the personal information in order to:

      1. Complete the transaction for which the personal information was collected, provide a service that you requested, take actions reasonably anticipated by the you within the context of our ongoing business relationship with you, or otherwise perform a contract with you.
      2. Help ensure the security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
      3. Identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Ca. Penal Code § 1546 et. seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
      7. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
      8. Comply with a legal obligation.

      If we deny a verified request to exercise Consumer’ right under the California Privacy Laws, in whole or in part, because of a conflict with federal or state law, or an exception under applicable law, we will inform the requestor and explain the basis for the denial. We will take action, in accordance with your request and California Privacy Laws, for those categories of personal information not subject to those exceptions.

   4. Verification procedure. We are required by the CPRA to verify the identity of individuals who submit a request to know, request to delete, or request to correct. In accordance with our internal policies and in compliance with the California Privacy Laws, we will take steps to verify your identity before granting you access to such Personal Information or acting on your request to exercise your rights, as outlined below:

To determine whether the individual making the request is the consumer about whom we collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As part of this process, you will be asked to provide your full name, address, and phone number. We will inform you if we cannot verify your identity.

1. 1. 1. If we cannot verify the identity of the person making the request for specific pieces of information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer
      2. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response an explain why we have no reasonable method by which we can verify the identity of the requestor.

If we cannot verify your identity based on the information already maintained, we may request additional information from you. We will try to limit the information collected, and we will only use this information to verify your identity and for security or fraud-prevention purposes. Except as required by law, we will delete any new personal information collected for the purposes of verification as soon as practical after processing the request.

1. 1. 5. Authorized Agents. You may designate an authorized agent to make requests on your behalf by sending us written authorization in writing at RealKey, Inc. 301 Main Street #4G, San Francisco, CA, 94105, USA. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with written permission to do so; and (2) verify your identity directly with us. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from the agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
      6. Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested
      9. Non-Discrimination. We will not discriminate against you for exercising any of your California Privacy rights. Unless permitted by the California Privacy Laws, we will not:
         • Deny you goods or services;
         • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
         • Provide you a different level or quality of goods or services;
         • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the California Privacy Laws that can result in different prices, rates, or quality levels. Any California Privacy Laws-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
      11. Changes to this Privacy Policy. We reserve the right to amend, add to, change, update, or modify this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will notify you by email or through a notice on our website homepage. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the website for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting this California Privacy Policy. The date on which this policy was last modified is identified at the beginning of this California Privacy Policy.
      12. Contact information. If you have any questions or comments about this California Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to lodge a complaint with us, you may contact us using the information below and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by email or telephone as follows:

By email: Support@RealKey.com

By mail: RealKey, Inc. 301 Main Street #4G, San Francisco, CA, 94105, USA.