Key Equipment Finance Privacy Policy

Key Equipment Finance (KEF) is a member of the KeyCorp (Key) family of companies. KEF and Key are committed to protecting the privacy of our web site information. This Statement discloses our policies for the collection and use of web site information. Please read it carefully to learn more about our information-protection practices, and to find out about the choices you may have in the way your information is collected and used in certain cases.

Third-Party Websites

Key Equipment Finance and the KEF family of companies ("KEF") are committed to protecting the privacy of our web site information. This Statement discloses our policies for the collection and use of web site information. Please read it carefully to learn more about our information-protection practices, and to find out about the choices you may have in the way your information is collected and used in certain cases.

When you click on a link and visit a third-party website, you will be subject to that website’s privacy and security practices. You should familiarize yourself with the privacy statement, terms of use, and security practices of the linked third-party website before providing any information.

Information We Collect

When you visit our websites and mobile applications, we collect information about your online session, as well as any information that you provide to us during your session, such as when you log in or fill out an application for a product or service.

The following table describes the categories of personal information collected, as well as the business purpose for collecting each category of personal information.

Information Collected	Business Purpose
Identifiers such as 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	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with a consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Characteristics of protected classifications under California or federal law	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Undertaking internal research for technological development and demonstration.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Biometric information	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Geolocation data	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Audio, electronic, visual, thermal, or similar information	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Professional or employment-related information	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration.
Education information	Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Undertaking internal research for technological development and demonstration.
Inferences drawn from any of the above information to determine consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards Debugging to identify and repair errors that impair existing intended functionality Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. Undertaking internal research for technological development and demonstration.

How We Collect Information

Information is collected when you provide it to us as well as through “cookies” and other tracking methods. Cookies are small amounts of data stored by your web browser that provide a web site with information such as the time of your last site visit and the pages you viewed.

Most web browsers allow you to delete or decline cookies, however doing so may impact your online experience. For example, you may have to identify yourself more frequently, as services like Online Banking require you to accept cookies or similar files in order to function properly.

If you are a customer or have applied for a product or service with Key, we may also obtain your information from credit reporting agencies or other service providers, in order to verify the information you have submitted.

Key also collects prospective customer contact information from its marketing partners, credit reporting agencies, and via referrals from business partners and customers.

Other Ways Information Is Collected

Online Surveys and Forms

Information you provide while completing surveys and forms on Key’s websites or mobile applications may also be collected and stored. Unless otherwise stated, this information is used to help Key develop a superior Web experience and enhance products and services.

Email and Online Chat

Information sent via email or Key’s Online Chat functionality may be retained in order to respond to your requests or inquiries and for quality assurance purposes.

Online Behavioral/ Interest-Based Advertising

Key may partner with third-parties to deliver and monitor advertisements on Key’s websites and other sites across the web. Key and/or Key's partners may monitor and record advertisement "click-through" rates, Web traffic, activities on third-party websites, and other activities in order to improve visitor experience and provide relevant advertising. Key and/or Key's partners may use cookies, Web beacons, or other monitoring technology to compile statistics about website traffic.

To learn more about this type of advertising, including how to opt out of certain types of online advertisements, please visit the Network Advertising Initiative's website at www.networkadvertising.org.

Google Analytics

We have implemented several Google Analytics for Display Advertisers Features, including Google Display Network Impression Reporting. These features are used to understand how our advertising performs and to improve our marketing efforts and the Websites.

We and third-party vendors, including Google, use first-party Google Analytics cookies that may be of interest to you based on your past visits to the Website. For more information on how Google Analytics collects and processes data, please see http://www.google.com/intl/en/policies/technologies/ads/.

We will not use these features to track, collect or upload any data that personally identifies an individual (such as a name, email address or billing information), or other data which can be reasonably linked to such information by Google.

You Can Opt Out of Google Analytics for Display Advertisers Features By:

• Changing your settings at Google’s Ad Settings
  (http://www.google.com/settings/ads)
• Installing an Opt-Out browser add-on available at
  https://tools.google.com/dlpage/gaoptout/
• Adjusting the settings on your web browser
  (See http://www.google.com/intl/en/policies/technologies/managing)
• Opting out of a participating vendor’s use of cookies at the Network Advertising Initiative opt-out page

Social Media

Key provides information about our products, services, and community involvement on social media sites like Facebook and Twitter. Please keep in mind that any information you share on these social media sites is visible to all users. You should never post any sensitive personal information (such as account number or social security number) on these sites. Please carefully review the Terms of Use and Privacy Policy on these sites as they may be different than our own policies.

How We Share Information

The personal information described in the “Information We Collect” section above may be shared with third parties for Key’s business purposes and to comply with applicable law. These third parties may include: marketing partners and service providers, data analytics providers, consultants and advisors, technology service providers, and government agencies as required or permitted by law. We disclose this information for business purposes including to provide you with information regarding Key’s products and services; for analytics purposes; to our service providers to support our operations; and to maintain compliance with applicable laws and regulations.

KEF reserves the right to share all information we collect but only as this policy describes or as disclosed to you when the information is collected.

Without limiting the above, we will disclose information (a) to service providers who do contract work for or within the KEF operations, or (b) to complete transactions initiated by you, or (c) when you request or authorize the disclosure, or (d) if the disclosure is required or allowed by law. At times it is necessary to disclose information to enforce or apply the terms and conditions of an agreement we have with you or to protect the rights, property, or safety of KEF, our customers or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

In addition, KEF will disclose your information, without notice, if KEF in good faith believes that such action is necessary: (a) to conform to the requirements of the law or comply with legal process served on KEF, or (b) to protect or defend the rights or property of KEF or employees or customers, or (c) to protect the personal safety of employees or customers of KEF, its web site users, or the public.

Please note, Key does not sell personal information as that term is defined in the California Consumer Privacy Act.

How We Safeguard Information

At Key, we are committed to safeguarding personal information. We use physical, technical, and administrative security measures that comply with applicable federal and state laws and regulations. When you log in to Key’s online services or enter application information, Key uses technology to encrypt and privately transfer your information to our network. Additional details on how Key protects information online, plus measures you can take to protect yourself, can be found on the Privacy & Security page on key.com.

How You Can Manage Information Collected

When you register, or otherwise give us information, KEF will not share that information with third parties without your permission, other than for the purposes stated above. Your information will generally be stored in KEF databases, which are located mainly in the United States, Asia Pacific or Europe. KEF strives to keep your information accurate. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access.

California Consumer Privacy Act (CCPA) Requests

If you are a California resident, the CCPA allows you to request information about the data Key collects and uses about you, including:

• The categories of personal information Key has collected about you;
• The categories of sources from which your personal information is collected;
• The business or commercial purpose for collecting your personal information;
• The categories of personal information Key disclosed about you for a business purpose;
• The categories of third parties with whom Key shares personal information; and
• The specific pieces of personal information Key has collected about you.

If you are a California resident and wish to make a request for the above information, please visit our CCPA request page. You may authorize another individual to submit this request on your behalf.

To submit this request, you must submit your:

• Name;
• Address;
• Last 4 digits of SSN.
• If you do not have an SSN, you may enter 0000 ;
• An email address, if you wish to receive a response via email.

Once your request is submitted, we will conduct a search of our systems and provide you with a response within 45 days.

California Non-Discrimination

California prohibits businesses from discriminating against you for exercising any rights under the CCPA, including, but not limited to, by:

• Denying you goods or services;
• Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, you may be charged a different price or rate, or provided a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your data. Businesses may offer financial incentives to you, including payments as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information.

California Data Deletion Requests

If you are a California resident, you have the right to request that Key delete any personal information we hold about you. To submit a deletion request, please visit our CCPA request page. You may authorize another individual to submit this request on your behalf. Please note, however, that there are many instances in which Key is required to maintain, or otherwise is not required to delete, your personal information. For example, Key is not required to delete your information if it is being used:

• To complete a transaction or provide a good or service requested by you;
• To detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity;
• To enable solely internal uses based on your relationship with us, such as a Do Not Solicit request;
• To comply with a legal obligation, such as federal recordkeeping requirements; or
• Internally, in a lawful manner that is compatible with the context in which the you provided the information.

Online Tracking

How web browsers communicate Do Not Track signals is not yet uniform. As a result, this site is not currently equipped to interpret or respond to Do Not Track signals communicated by your browser. To learn more about online tracking, you can visit the Future of Privacy Forum’s “All About Do Not Track” website.

Children’s Information

Key’s websites, mobile applications, and online services are not directed to individuals under the age of thirteen, and do not knowingly collect information from these individuals. We request that those under the age of thirteen do not provide information through our websites or mobile applications. You can learn more about the Children's Online Privacy Protection Act (COPPA) at the Federal Trade Commission’s website. 

Changes to Key's Online Privacy Statement

Key's Online Privacy Statement is subject to change from time to time. When changes are made, we will communicate these changes to you by posting the revised Statement on this page and adjust the “Last Updated” date. Any changes to this Statement will become effective on the date of posting unless indicated otherwise.

Last updated: January 1, 2020