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About This Policy

TheKey, LLC and its subsidiaries, divisions, and affiliates (sometimes referred to as “TheKey,” “Company,” “us,” “we,” or “our”) adopted this privacy policy (“Policy”) to describe our policies and practices concerning the personal information we collect about you through our mobile websites, mobile apps, blogs and website (collectively, “Site”). TheKey is committed to the privacy and security of the personal information we collect.

Please read this Policy carefully before using the Site or submitting personal information to us. By accessing or visiting the Site, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy and our Terms of Use found at https://thekey.com/legal-notice. Except as otherwise noted, any capitalized terms not defined in the Policy have the meaning set forth in the Terms of Use. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this policy, please do not provide us with such information.

This Policy does not apply to third-party websites accessible through our Site or other applications.
1. Personal Information We Collect
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy:
  • Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
  • Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.
  • Characteristics of protected classifications under California or federal law – such as race, religion, and age.
  • Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Education information – such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
  • Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
  • Biometric information – such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.
  • Geolocation data – such as location information while using one of our apps.
  • Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.
  • Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
  • Sensitive Information — Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
2. How Long We Retain Your Personal Information
We retain your personal information for as long as necessary to provide you services/potential services and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.

To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements, etc.
3. Your Choices Regarding Your Personal Information
You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access or receive some of the services, offers, and information we offer through the Site.
4. Purposes We Collect and Use Personal Information
We collect and use your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law:

  • To communicate with you.
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders, transactions or requests for information, verifying customer information, processing payments, providing analytics services, or providing similar services.
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
  • To engage in marketing and advertising activities; contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
  • To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy.
  • To carry out our obligations and enforce our rights, including those arising from any contracts entered into with you for billing, payment, and collections.
  • To review, improve, and monitor our website, applications, online services, and overall consumer experience, including to provide customization to meet the specific needs.
  • For testing, research, analysis and product and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the Site and the services, products, and information we provide.
  • To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
  • As described to you when collecting your personal information.
  • As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
  • 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.
5. Disclosures of Personal Information
We may disclose your personal information to our affiliates/owners, services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services, advertising and social networks and data analytics providers, professional services organizations, such as auditors and law firms, and government entities, including licensing enforcement agencies.

We may also disclose your personal information to third parties, if necessary, to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer personal information to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.

We may disclose non-personally identifiable visitor information to other parties for marketing, advertising, or other uses.

Of the categories of PI noted above, during the past 12 months, we disclosed the following:
Categories of Personal Information Disclosed
Identifiers

Other elements

Characteristics of protected classifications under California or federal law

Commercial information

Education information

Internet or other electronic network activity

Biometric information

Geolocation data

Audio, electronic, visual, thermal, olfactory, or similar information

Professional or employment-related information

Consumer profile

Sensitive personal information
Categories of Third Parties to Whom Disclosed
  • Third parties as directed by you. We will disclose your PI with those third parties to whom you direct.
  • Our business partners. For example, we might disclose your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
  • Third parties who perform services on our behalf. For example, we disclose information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to disclose PI on our behalf for these purposes.
  • Governmental entities, legal service providers. We may disclose your PI to comply with the law and while providing our products and services and other business activities of the Company. We may also disclose information if a government agency or investigatory body submits a request.
  • Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.

6. Cookies, Tracking, and Certain Communications
Cookies. The Site uses cookies and similar web technologies. For more information on the web technologies we use and how you can manage them, please see our Cookie Policy found here https://thekey.com/cookie-policy.

Some of our digital services, including the TheKey website, use Google Analytics Advertising Features and its associated tracking technologies to help display TheKey ads you see on other sites, and to help us manage and optimize our digital advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page. Website users can also access the Google Analytics Opt Out Browser Add-on.

Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. TheKey leverages its third-party digital services to process the signals. If a user enables “Do Not Track” signals to communicate their privacy preference, then the users’ browser will send the “Do Not Track” signal to TheKey’s 3rd party vendors and the websites they visit to respect their privacy rights accordingly. We track visitors over time and across third parties’ websites.
7. Third Party Website Links
Some portions of our Site may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.
8. Email and SMS Communications
We may collect your email address via cookies and pixels on the Site through the use of trusted third-party partners. These partners may combine your email information with other information they have access to such as mailing address so that we may send relevant marketing offers to you via direct mail.

You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use information automatically collected based on your actions while on our Sites and may prompt messaging such as cart abandon messages. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages.
9. Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
10. Security
We employ reasonable and appropriate administrative, physical and technical measures designed to safeguard the personal information we collect from you. However, no system for safeguarding personal or other information is 100% secure and we cannot fully eliminate security risks associated with personal information. In addition, although we use reasonable measures to protect our Site and your information, the Internet is not 100% secure and we encourage you to use caution when using the Internet.
11. Applicable law
This Policy is governed by the laws of the State of California without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within California. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
12. Notice to Site Users Located Outside the U.S
The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
13. Contact Us
If you have additional questions, you may call us at (888) 601-8638 or reach us by email at HCAprivacy@TheKey.com.
14. Changes to this Policy
Effective Date: January 1, 2023

From time to time, we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates.
15. NOTICE TO CALIFORNIA RESIDENTS
Shine the Light. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of the Company to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding 2021 sharing activities). You may submit your request using the contact information in this Policy.

California Consumer Privacy Act. The section concerning the California Consumer Privacy Act (“CCPA Section”) applies solely to individuals who are residents of the State of California (“consumers” or “you”) as required under the California Consumer Privacy Act, as amended (“CCPA”).

This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through other channels, including but not limited to visiting one of our locations, phone and email conversations, attending our events, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.

This CCPA Section supplements and amends the information contained in the Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. All other terms shall have the meaning set forth in the Policy or Terms of Use as applicable. The other provisions of the Policy continue to apply except as modified in this CCPA Section.

Please read this CCPA Section carefully before using the Site or submitting information to us. IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.

Sources of Personal Information
  • You. We may collect personal information directly from you or your device, such as through your use of our website, when you send us an email, contact us by phone, or otherwise communicate or interact with us. We may also collect information when you attend an event, or participate in a sweepstakes, contest, promotion, or program we sponsor. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
  • Related Entities and Affiliates. We may collect information about you from our related parties and affiliates.
  • Social media and related services. We may collect information about you through your social media services consistent with your settings on such services.
  • Service providers and contractors. When you obtain products and services from us, we may collect your PI from service providers and contractors who collected information about you that is needed to provide those products and services.
  • News outlets, surveys, and certain third parties. We may collect information about you from third parties such as your family members or friends who may inquire about our services or other individuals who may refer you to us, vendors to whom you have provided your information, sales representatives, advertising and social networks, or other third-party sources that are lawfully entitled to share your data with us. In the course of performing our services or marketing activities we, or third parties on our behalf, may conduct research and other activities resulting in the collection of PI about you.

Rights. Under the CCPA, California residents have certain rights. Subject to verification and certain limitations, these rights include the following.

Right To Know About Personal Information Collected or Disclosed. We generally describe in this Privacy Policy our current and practices for the prior 12 months related to the categories of personal information we collect, how we collect and use the personal information, and how we disclose your personal information. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics for the preceding 12 months, to the extent applicable:
  • the categories of personal information,
  • the categories of sources from which the personal information is collected,
  • the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,
  • the categories of third parties to whom the business discloses personal information, and
  • the specific pieces of personal information the business has collected about you.

Upon receipt of a verifiable consumer request (see section 17), and as required by the CCPA, we will provide a response to such requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.

Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintain about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers, contractors and third parties to whom we disclosed your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers, contractors or third parties to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:
  • Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
  • Help to ensure security and integrity to the extent the use of the consumer’s PI is reasonably necessary and proportionate for those purposes.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  • Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.
  • Comply with a legal obligation.

Upon receipt of a verifiable consumer request (see section 17), and as required by the CCPA, we will provide a response to such requests.

Right to Request Correction of Your Personal Information. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see section 17), and as required by the CCPA, we will provide a response to such requests.

Right to Opt Out of the Sale or Sharing of Your Personal Information. You have the right to opt out of our sale or sharing of certain personal information we collect about you.

If you would like to opt out of our sale or sharing of this information, we recognize and process opt out preference signals in a frictionless manner and the signal shall apply to the browser/device.

You may also opt-out of our sale or sharing of your personal information by emailing us at HCAprivacy@thekey.com or by completing the form at the following link: Do Not Sell/Share.

We do not have actual knowledge that we have sold or shared personal information of minors under the age of 16.

Right to Limit Use of Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA, as described above. This includes but is not limited to: (A) denying good or services to you; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services; or (D) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. It also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

Submitting Consumer Rights Requests.

How to submit. To submit a California Consumer Rights request as outlined in this CA Section, please contact the Company by calling us at (888) 601-8638 Monday-Friday from 6am–5pm PST, emailing us at HCAprivacy@TheKey.com, or using our contact form. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct. A verifiable consumer request is one made by any individual who is:
  • the consumer who is the subject of the request,
  • a consumer on behalf of the consumer’s minor child, or
  • the authorized agent of the consumer.

For additional information on submitting a request including the verification process and use of authorized agents, please see section 17, below:

Changes to this California Section

From time to time, we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates.

Effective Date: January 1, 2023
16. NOTICE TO VIRGINIA RESIDENTS
Virginia Consumer Data Protection Act. The section concerning the Virginia Consumer Privacy Act (“VCDPA Section”) applies solely to individuals who are residents of the State of Virginia (“consumers” or “you”).

This VCDPA Section describes our policies and practices regarding the collection, use, and disclosure of personal data we collect about you, including personal data we obtain when you access or use the Site, or through other channels, including but not limited to visiting one of our locations, phone and email conversations, attending our events, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.

This VCDPA Section supplements and amends the information contained in the Policy with respect to Virginia residents. Any terms defined within the VCDPA have the same meaning when utilized within this VCDPA Section. All other terms shall have the meaning set forth in the Policy or Terms of Use as applicable. The other provisions of the Policy continue to apply except as modified in this VCDPA Section.

This VCDPA Section does not apply to personal date we collect about you in a commercial or employment context.

Please read this VCDPA Section carefully. IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS VCDPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.

Categories of Personal Data We Process. Please see section 1, above.

Purposes We Collect and Use Personal Data. Please see section 4, above.

Categories of Personal Data Shared with Third Parties. Please see section 5, above.

Categories of Third Parties with Whom We Share Personal Data. Please see section 5, above.

Rights. Virginia residents have specific rights with respect to personal data we collect about them. Subject to verification (see section 17) and certain limitations, these rights include the following:

Right to Confirmation and Access. You have the right to request that we confirm whether we are processing your personal data and to access such personal data.

Right to Request Correction of Your Personal Data. You have the right to request that we correct any inaccurate personal data we maintain about you.

Right To Request Deletion of Your Personal Data. You have the right to request that we delete personal data we collected or maintain about you.

Right to Obtain a Copy. You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format where the processing is carried out by automated means.

Right to Opt Out of the Processing of Personal Data. You have the right to opt out of processing personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise any of your rights under the VCDPA, please submit your request by calling us at (888) 601-8638 Monday-Friday from 6am–5pm PST, emailing us at HCAprivacy@TheKey.com, or using our contact form. For additional information on submitting a request including the verification process and and appeal process, please see section 17, below.

Changes to this Virginia Section

From time to time, we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates.

Effective Date: January 1, 2023
17. Submitting a Consumer Request Under the CCPA or VCDPA
What to submit. To help protect your privacy and maintain security, we will take steps to verify your identity before granting access to your personal information or complying with your request. If you request access to or request to correct or delete your personal information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Verifying Your Request. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.

Our response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

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. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA or VCDPA, we will respond to no more than two requests during any 12-month period.

Authorized Agent (CA consumer only). You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under the California Sections. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Right to Appeal (VA residents only). If you are a VA resident, you have the right to appeal a decision we make in response to a request to exercise one of your rights. We will provide instructions on how to appeal our decision in our written response to you. You can also appeal our decision by sending a written appeal to TheKey, LLC 7777 Fay Ave, Suite 210, La Jolla, CA 92037.
18. Questions
If you have questions about this Privacy Policy, please contact us as described above in the Policy or at:

TheKey, LLC
777 Fay Ave, Suite 210
La Jolla, CA 92037
HCAprivacy@TheKey.com
(888) 601-8638 — Monday-Friday from 6am–5pm PST

This Privacy Policy is available in alternative formats upon request. Please contact HCAprivacy@TheKey.com to request this Statement in an alternative format.
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