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Privacy Policy for Masterkey

Effective Date: October 16, 2024

1. Introduction

Welcome to Masterkey (“we,” “us,” or “our”), operated by Dabudage LLC (“the Company”). We are committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you use our platform (“Masterkey” or “the Service”).By accessing or using Masterkey, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this policy, please do not access the platform.

2. Information We Collect

We collect the following types of information:

a. Personal Information

  • While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information” or “Personal Data”) may include, but is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, ZIP/Postal code, City

  • Usage Data

  • Profile Picture

  • House Buying Process Information: Throughout your journey on Masterkey, we may ask you to provide documents and information related to the home-buying process. This may include financial information, property preferences, and other relevant details.

b. Usage Data

  • Technical Data: We may collect information such as your IP address, browser type, device information, operating system, and the pages you visit on our platform, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

  • Cookies and Similar Technologies: We use cookies and similar tracking technologies to authenticate users and enhance your experience. Third-party services integrated into our platform may also use cookies for analytics purposes. The technologies we use may include:

    • Cookies or Browser Cookies: A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our Service may use cookies.

    • Web Beacons: Certain sections of our Service 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 permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

3. How We Use Your Information

We use your information for the following purposes:

  • Providing and Maintaining the Service: To offer personalized guidance and improve your user experience.

  • Communication: To contact you with updates, notifications, and information related to your account.

  • Security and Fraud Prevention: To detect, prevent, and address technical issues and protect against unauthorized access or fraudulent activity.

  • Legal Compliance: To comply with legal obligations and protect our legal rights.

Note: We do not use your information to train AI models or for marketing purposes beyond direct communication with you.

4. Disclosure of Your Information

We may share your information in the following circumstances:

a. Service Providers

We employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related tasks, or assist us in analyzing how our Service is used. These third parties have access to your Personal Information only to perform these tasks and are obligated not to disclose or use it for any other purpose.Our Service Providers include:

  • Supabase: For database management and hosting.

  • Sentry: For error monitoring.

  • OpenPanel: For analytics.

  • Stripe: For payment processing.

  • Vercel: For hosting and deployment.

  • Upstash: For data caching.

  • OpenAI and Anthropic: For AI services.

Under certain circumstances, the Company may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).The Company may disclose your Personal Information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation

  • Protect and defend the rights or property of the Company

  • Prevent or investigate possible wrongdoing in connection with the Service

  • Protect the personal safety of Users of the Service or the public

  • Protect against legal liability

c. Business Transactions

If Dabudage LLC is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

d. With Other Users

When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

We may disclose your personal information for any other purpose with your consent.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to authenticate users and enhance your experience. Cookies are small data files stored on your device.

  • Essential Cookies: Used for authentication and to prevent fraudulent use of user accounts.

  • Analytics Cookies: Third-party services may use cookies to collect information about how you use the Service to help us improve it.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service.

6. Data Security

We are committed to protecting your data. We implement appropriate technical and organizational measures, including:

  • Encryption: Data transmitted to and from our Service is encrypted using SSL/TLS technology.

  • Secure Servers: We use secure servers hosted by Vercel and managed databases provided by Supabase.

  • Access Controls: We employ row-level security and role-based access controls to limit access to your data.

Please be aware that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

7. Data Retention

We retain your Personal Information and documents for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

  • Account Information: Retained until you delete your account or request deletion.

  • Documents and Uploaded Information: Retained for the duration necessary to provide the service or as required by law.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

8. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

9. Your Rights

You have the following rights regarding your Personal Information:

  • Access and Correction: You may access and update your Personal Information by logging into your account settings.

  • Deletion: You may request that we delete your Personal Information by contacting us at support@trymasterkey.com

  • Opt-Out: You may opt out of receiving promotional communications from us by following the unsubscribe link or instructions provided in any email we send.

10. International Users

While Masterkey primarily targets users in the United States, your information may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ.If you are located outside the United States and choose to provide information to us, please note that we transfer the data to the United States for processing.

11. Children’s Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect Personal Information from anyone under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us at support@trymasterkey.com.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any significant changes by email and by updating the “Effective Date” at the top of this policy.We encourage you to review this Privacy Policy periodically for any changes.

13. Contact Information

If you have any questions about this Privacy Policy, please contact us at:

  • Email: support@trymasterkey.com

  • Address: Dabudage LLC 247 West Broadway New York, NY 10013 United States

  • Phone: (831) 435-6036

14. Data Controller

Dabudage LLC is the data controller responsible for your Personal Information.

15. Email Marketing

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you according to your newsletter subscription preferences. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

16. Payment Processing

We use Stripe as our third-party payment processor. We do not store or collect your payment card details. Payment information is provided directly to Stripe, whose use of your Personal Information is governed by their Privacy Policy. Stripe adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

17. CCPA Privacy Policy

Please refer to Annex A for the privacy notice section for California residents that supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

18. User Content and Document Analysis

When you upload documents to Masterkey, including for the purpose of interacting with our AI features:

  • Data Handling: Uploaded documents and any content you provide are stored securely and used solely to provide you with the requested services, such as AI-powered assistance and document analysis.

  • Confidentiality: We treat your documents and content as confidential. We do not share them with third parties except as necessary to provide the service or comply with legal obligations.

  • Retention: Documents are retained only as long as necessary to provide the service or as required by law.

  • AI Usage: We do not use your documents or content to train our AI models.

19. Third-Party Services

Our Service may contain links to other sites or services that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

We may disclose your Personal Information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation.

  • Protect and defend the rights or property of Dabudage LLC.

  • Prevent or investigate possible wrongdoing in connection with the Service.

  • Protect the personal safety of users of the Service or the public.

  • Protect against legal liability.

21. Do Not Track Signals

Our Service does not respond to Do Not Track (“DNT”) signals.

22. Data Protection Rights

Depending on your jurisdiction, you may have the following data protection rights:

  • Right to Access: You have the right to request copies of your Personal Information.

  • Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or incomplete.

  • Right to Erasure: You have the right to request that we erase your Personal Information under certain conditions.

  • Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Information under certain conditions.

  • Right to Object to Processing: You have the right to object to our processing of your Personal Information under certain conditions.

  • Right to Data Portability: You have the right to request that we transfer your data to another organization or directly to you under certain conditions.

  • Rights to opt-out of or prevent personal information sales and sharing personal information for cross-context behavioral advertising (sale and sharing opt-out and opt-in rights).

  • Rights to limit the use or disclosure of sensitive personal information to specific, statutorily permitted purposes (limitation rights).

  • Non-discrimination rights.

To exercise these rights, please contact us at support@trymasterkey.com.

23. Opt-Out of Communications

You may opt out of receiving promotional emails from us by following the instructions in those emails or by contacting us at support@trymasterkey.com. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

24. Data Breach Notification

In the event of a data breach, we will promptly notify you and the appropriate authorities as required by applicable law.

25. Governing Law

This Privacy Policy is governed by the laws of the State of Colorado, without regard to its conflict of law principles.

By using our Service, you consent to our Privacy Policy.

Annex A

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.1. Categories of Personal Information CollectedWe collect 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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

  • Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers. Collected: Yes.

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: 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. Collected: Yes.

  • Category C: Protected classification characteristics under California or federal law. Examples: 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). Collected: No.

  • Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: Yes.

  • Category E: Biometric information. Examples: 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. Collected: No.

  • Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes.

  • Category G: Geolocation data. Examples: Approximate physical location. Collected: No.

  • Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.

  • Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No.

  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: 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. Collected: No.

  • Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.

Under CCPA, personal information does not include:

  • Publicly available information from government records

  • Deidentified or aggregated consumer information

  • Information excluded from the CCPA’s scope, such as:

  • 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 data

  • Personal Information covered by certain sector-specific privacy laws, including 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

2. Sources of Personal InformationWe obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.

  • Indirectly from you. For example, from observing your activity on our Service.

  • Automatically from you. For example, through cookies we or our Service Providers set on your device as you navigate through our Service.

  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to you.

3. Use of Personal Information for Business Purposes or Commercial PurposesWe may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

  • To operate our Service and provide you with our Service.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.

  • To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, 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.

  • 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.

  • For internal administrative and auditing purposes.

  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.4. Disclosure of Personal Information for Business Purposes or Commercial PurposesWe may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  • Category D: Commercial information

  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.When we disclose personal information for a business purpose or a commercial purpose, Wwe 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.5. Sale of Personal InformationAs defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  • Category D: Commercial information

  • Category F: Internet or other similar network activity

6. Share of Personal InformationWe may share your personal information identified in the above categories with the following categories of third parties:

  • Service Providers

  • Payment processors

  • Our affiliates

  • Our business partners

  • Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

7. Sale of Personal Information of Minors Under 16 Years of AgeWe do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.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 the sale of personal information 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 contacting us.If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.8. Your Rights under the CCPAThe CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

  • The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your 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

    • If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:

    • The categories of personal information categories sold

    • The categories of personal information categories disclosed

  • The right to say no to the sale of Personal Data (opt-out).You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us.

  • The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your 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 Providers 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.

  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:

    • Denying goods or services to you

    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

    • Providing a different level or quality of goods or services to you

    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

9. Exercising Your CCPA Data Protection RightsIn order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by sending us an email: support@trymasterkey.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 request related to your personal information.Your request to us 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 the required information if we cannot:

  • Verify your identity or authority to make the request

  • And confirm that the personal information relates to you

  • We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.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.10. Do Not Sell My Personal InformationYou have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt-out on every browser that you use. You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.Mobile DevicesYour mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.