CA Privacy Policy

This Privacy Notice for California Residents supplements the information contained in Standard Mortgage Capital, LLC’s dba Right Key Mortgage (“Standard Mortgage’s”) website and mobile application Privacy Policy 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.
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (" B2B personal information“) from some its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information"). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial datas;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our website and mobile application has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Example	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	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, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data	Physical location or movements.	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information	Current or past job history or performance evaluations.	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Our website and mobile application obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you request.
Indirectly from you. For example, from observing your actions on our website or mobile application.
Through web videos, such as Zoom, where there is interactive exchange.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
From data integrations with specific vendors.

Use Of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request offers from various lenders for a mortgage loan 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 use a product or service, we will use that information to enable our business partners, lenders and/or brokers that subscribe to our service to compete for your business and offer you the best loan terms available based on the information or data that you provide to us, whereupon we will charge them for the lead to your business once you select that partner, lender or broker. We may also save your information to facilitate new product or service orders and requests.
To provide, support, personalize, and develop our website, mobile app, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests and transactions, and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your website and mobile app experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, mobile app, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our website, mobile app, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our website, mobile app, 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
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 about our website and mobile app users/consumers is among the assets transferred.

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.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Category	Category of Third-Party Recipients (Business Purpose Disclosures)	Sales
Identifiers	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Protected classification characteristics under California or federal law	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Commercial information	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Biometric information	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Internet or other similar network activity	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Geolocation data	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Sensory data	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Professional or employment-related information	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	None	None
Inferences drawn from other personal information	Subsidiaries and Affiliates; Business Partners; Service Providers; Advertising Partners; Data Analytic Providers; Internet Service Providers; Operating Systems and Platforms; Data Aggregators; Social Networks; Internet Cookie Data Recipients, like Google Analytics	None

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

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:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Right to Delete

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 (the “right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information 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 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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise rights to know or delete described above, please submit a request by either:

Calling us at (508) 644-0105.
Emailing us at info@rightkeymortgage.com
Visiting www.rightkeymortgage.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Loan number
- Phone number
- Email address
- Social Security Number
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.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights .

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact info@rightkeymortgage.com
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.

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. 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 by visiting the following Internet Web page link:

Do Not Sell My Personal Information

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 in to personal information sales at any time by:

Emailing info@rightkeymortgage.com

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

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. The more information and documentation you provide concerning yourself, your borrowing scenario, credit history, current income situation, available assets, and supporting documentation, the more you can save in closing costs, and lenders will be able to optimally compete on loan terms, such as the interest rate, how quickly they can close a loan, rate lock days and more.

Other California Privacy Rights

California’s “Shine the Light" law (Civil Code Section § 1798.83) permits users of our website and mobile app 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 email to info@rightkeymortgage.com or write us at: 53 NW 100th Ave Plantation, FL 33324

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes .

Contact Information

If you have any questions or comments about this notice, the ways in which Standard Mortgage collects and uses your information described here and in the privacy-policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (508) 644-0105

Website: www.rightkeymortgage.com

Email: info@rightkeymortgage.com

Postal Address:
53 NW 100th Ave Plantation, FL 33324
Attn: Compliance Department
53 NW 100th Ave Plantation, FL 33324

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