Privacy Policy

This website is operated by RealKey, Inc. (“RealKey”, “We” / “Us” / “Our”/ “Company“). We respect your personal information and therefore we have established a comprehensive privacy policy, which describes the types of information that we collect from you and our practices for collecting, using, maintaining, protecting and disclosing this information.

This privacy policy applies to the information that we collect through this website https://www.realkey.com (the “Website“), through e-mail or other electronic messages or means between you and the Website. For avoidance of any doubt this privacy policy will not apply with regards to personal information provided by the users of this website during purchase transactions executed through Stripe.com, and Plaid.com. All personal information collected during such transactions shall be subject to the applicable privacy policies established by Stripe (https://stripe.com/us/legal) and Plaid (https://plaid.com/legal/).

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website.

Introduction

RealKey is a web-based platform that brings together all parties involved in buying a house and getting a mortgage, into a single unified portal, where all documentation and communication are kept in a single secure place.

Personal Information Defined

Personal information is any information that can be used to personally identify an individual user, such as name, physical address, e-mail address, telephone number, social security number and any other similar information that can be used to uniquely identify, contact or locate an individual.

Information we collect about you

Personal information from individuals.
The personal information that we collect is:

  • contact information: names; e-mail addresses, addresses and phone numbers;
  • financial information about income, assets, tax, current employment and employment history, bank statements;
  • credit information: credit scores, all credit data required for loan processing;
  • geographical location.

Other information. Additionally, we will be collecting also:

  • housing information;
  • details of transactions you carry out through this website;
  • your search queries on this website;
  • any information that you post on our website;
  • your log-in and password details.

Usage details, IP address.

While you use/navigate through our website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

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

Cookies and other tracking technologies

The information that we collect automatically is statistical data and cannot be used to identify you as an individual. It helps us to improve our Website and to deliver a better and more personalized service. The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that allow us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics.

Usually personal data cannot be collected via cookies and tracking technologies, however we may tie the above automatically collected information to your personal information.

Notice. Purpose for collecting personal information.

The purpose for which we collect your personal information is to fulfill your specific request(s) and to fully provide you with our services.

How we use your information.

  1. We will use the personal information you provide:
    • to provide you with information about our services and products;
    • to administer your account with us;
    • to notify you about changes to our Website, including this privacy policy, or any products or services we offer or provide though it.
    • to price mortgages and qualify consumers for mortgages;
    • to provide to consumers disclosures on mortgages;
    • to submit consumer data and files to mortgage underwriters, lenders and banks for approval and processing of mortgages
  2. We will use the non-personally identifiable information:
    • to customize our services for you and to personalize and improve your experience on the Website.
    • to understand how the visitors use the Website and estimate their usage patterns.
    • to collect information about your preferences about browser type and operating system;
    • to recognize the visitors when they return to our Website;

Information Sharing

Sharing information with service providers:
We may share the personal information submitted by individual end users with the service providers, contractors and other companies in order to be able to fulfill your orders, operate our business, communicate with you and enable us to provide our services and this Website. These service providers may help us perform any of the activities that fall within the scope of our services. For instance, we may share certain of the information we collect or receive with companies that help us with mortgage pricing, mortgage approval, information processing, extending credit, fulfilling customer orders, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. All these companies are obligated to protect your information and are bound by confidentiality agreements.

Sharing information with marketers and advertisers.
We may share personal information with third parties to provide or help us to provide advertising and marketing services such as advertisers and their marketing providers, to provide targeted content and advertising to you with other third parties that target advertising.

Sharing your information if required by law.
We reserve the right to disclose your personal information to third parties if required by a court order, law or legal process, including responding to any government or regulatory request. We may also disclose your personal information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of RealKey, our users or others.

Security

We take reasonable measures and precautions designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored row encrypted PCI compliant vault. We restrict access to personal information to employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

Areas of our Website that collect personal data use two factor authentication SSL/HTTPS connections and bank level encryption SOC2, ISO 27001 and SSAE 16. We also use IP range blocking, port blocking, we isolate each subsystem and require credentials for any and all communications without subsystems.

The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Although we do our best to protect your personal information, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Access

We will provide you with access to your personal information that we store to the extent it is available and allow you to correct or amend inaccurate information.

You may also send us an email at Support@RealKey.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your content submission from this Website, copies of your content submissions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including content submissions, is governed by our Terms of Service (https://realkey.com/terms-of-service/).

California Civil Code Section § 1798.83 permits the users of this Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to Support@RealKey.com or write us at: RealKey, Inc. 301 Main Street #4G, San Francisco, CA, 94105, USA.

Your California Privacy Rights

RealKey welcomes residents of the State of California to use its Website, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident, you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Please send a written request to RealKey, Inc. 301 Main Street #4G, San Francisco, CA, 94105, USA.

Privacy Notice For California Residents Under The California Consumer Privacy Act.

This Privacy Notice for California residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

  1. Categories of Information We Collect. Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:
    • Identifiers, such as: names, e-mail addresses, Internet Protocol addresses, or other similar identifiers.
      Collected: [YES]
    • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as: a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
      Collected: [YES]
    • Protected classification characteristics under California or federal law such as: Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, sexual orientation, veteran or military status.
      Collected: [YES]
    • Commercial information obtained, purchased or considered, such as records of personal property, records of products or services purchased or other purchasing or use histories or tendencies
      Collected: [YES]
    • Biometric information
      Collected: [NO]
    • Activity information relating to internet or other electronic networks such as browsing or searching history, or interaction with a website, ad or app
      Collected: [NO]
    • Geolocation information
      Collected: [YES]
    • Audio, visual, thermal, electronic, olfactory or other similar information
      Collected: [NO]
    • Information related to employment or other professional standings
      Collected: [YES]
    • Information related to education
      Collected: [YES]
    • Any inferences drawn using any of the above information in order to profile a consumer and reflect the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
      Collected: [YES]
  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’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. 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
  4. Use of Personal Information. We may use, or disclose the personal information we collect for one or more of the following business purposes:
    • To fulfill 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.
    • 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.
  5. 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[IB3] , 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[IB7] .
  6. Your Rights and Choices. The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
    1. Access to Specific Information and Data Portability Rights. 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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
      • We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
        • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
        • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
        • Debug products to identify and repair errors that impair existing intended functionality.
        • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
        • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
        • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
        • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
        • Comply with a legal obligation.
        • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
    3. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, 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.
    4. (4) Response Timing and Format. 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.

  7. Personal Information Sales Opt-Out and Opt-In Rights. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at: Support@RealKey.com

    Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

  8. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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 CCPA that can result in different prices, rates, or quality levels. Any CCPA-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.

      California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to Support@RealKey.com or write us at: RealKey, Inc. 301 Main Street #4G, San Francisco, CA, 94105, USA.

International Users

RealKey, Inc. is a U.S. company, and the Website is hosted in the United States. If you access the Website from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from the United States laws, please be advised that through your continued use of the Website or our services, you may be transferring your personal information to the United States and you consent to that transfer. Additionally, you understand that your personal information may be processed in countries (including the United States) where laws regarding processing personal information may be less stringent than the data protection laws in your country. We will protect your personal information according to the terms of this Privacy Policy, regardless of where it is collected, processed, and stored.

Children’s Online Privacy Protection Act

This Website is not intended for use by children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, you should not use or provide any information on this Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information received from a child under 13, please contact us at RealKey, Inc., 301 Main Street #4G, San Francisco, CA, 94105, USA.

Changes to this Privacy Policy

Please note that this privacy policy may change from time to time. We will keep you informed of any amendments that we make to this privacy policy. We will post any changes that we make to our privacy policy on the Website home page with a notice that the privacy policy has been updated.

If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the website home page. It is your responsibility to provide us with an up-to-date e-mail address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Contact information

If you have any additional questions or concerns about this privacy policy, please feel free to contact us any time through this Website or by writing to us at the following address:
RealKey, Inc.
301 Main Street #4G
San Francisco, CA, 94105, USA
Last Updated: October 1, 2020