Kealee Platform, Inc. ("Kealee," "we," "us," or "our") is committed to protecting your privacy and the security of your personal and financial information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use the Kealee Finance & Trust platform, including our website, mobile applications, and related services (collectively, the "Services").
By using our Services, you consent to the data practices described in this policy. If you do not agree with the practices described herein, please do not use our Services.
1. Information We Collect
1.1 Information You Provide
We collect information that you voluntarily provide when you register for an account, create an escrow account, make a payment, or communicate with us. This may include:
- Full name, email address, phone number, and mailing address
- Date of birth and government-issued identification for identity verification
- Bank account information, payment card details, and other financial information necessary to process transactions
- Business name, license numbers, and insurance information (for contractors)
- Project details, contract documents, and milestone schedules
- Communications, messages, and support requests you send to us
1.2 Information Collected Automatically
When you access our Services, we may automatically collect certain information, including:
- Device information (device type, operating system, browser type)
- IP address and approximate geographic location
- Usage data such as pages visited, features used, and time spent on the platform
- Cookies and similar tracking technologies (see Section 5)
- Log data including access times, error reports, and referring URLs
1.3 Information from Third Parties
We may receive information about you from third-party sources, including:
- Identity verification services for KYC (Know Your Customer) compliance
- Payment processors (such as Stripe) for transaction data
- Banking partners (via Plaid) for account verification
- Credit reporting agencies for fraud prevention
- Public databases for contractor license and insurance verification
2. How We Use Your Information
We use the information we collect for the following purposes:
- Provide and operate our Services: Create and manage accounts, process escrow transactions, facilitate milestone-based payments, and deliver the core platform functionality.
- Verify identity and prevent fraud: Comply with KYC and anti-money laundering (AML) regulations, verify contractor credentials, and detect fraudulent activity.
- Process payments: Execute deposits, fund releases, refunds, and disbursements through our payment processing partners.
- Communicate with you: Send transaction confirmations, milestone notifications, payment approvals, security alerts, and customer support responses.
- Improve our Services: Analyze usage patterns, troubleshoot issues, develop new features, and enhance platform performance and security.
- Comply with legal obligations: Meet regulatory requirements, respond to legal requests, and fulfill tax reporting obligations (such as generating 1099 forms).
- Protect our users: Enforce our terms of service, resolve disputes, and protect the rights and safety of our users and the public.
3. How We Share Your Information
We do not sell your personal information. We may share your information in the following circumstances:
- With project counterparties: Limited project-related information is shared between homeowners and contractors on the same project (such as names, contact information, and milestone status) as necessary to facilitate the project.
- With service providers: We share information with trusted third-party vendors who perform services on our behalf, including payment processing (Stripe), bank account verification (Plaid), identity verification, cloud hosting, and customer support tools. These providers are contractually obligated to protect your information.
- With banking partners: Financial information is shared with our FDIC-insured banking partner to create and manage escrow accounts and process transactions.
- For legal compliance: We may disclose information when required by law, regulation, legal process, or governmental request, including tax reporting to the IRS.
- For safety and fraud prevention: We may share information when we believe in good faith that disclosure is necessary to prevent fraud, protect safety, or enforce our agreements.
- In business transfers: If Kealee is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to the protections described in this policy.
4. Data Security
We take the security of your information seriously and implement robust technical and organizational measures to protect it, including:
- Encryption: All data is encrypted in transit using 256-bit SSL/TLS encryption and at rest using AES-256 encryption.
- Access controls: Role-based access controls ensure that only authorized personnel can access sensitive data, with multi-factor authentication required for all internal systems.
- Compliance certifications: We maintain SOC 2 Type II certification and PCI-DSS Level 1 compliance.
- Regular audits: We conduct regular security audits, penetration testing, and vulnerability assessments.
- Monitoring: Real-time transaction monitoring and anomaly detection systems alert our security team to suspicious activity.
- Data segregation: Customer escrow funds are held in segregated trust accounts separate from Kealee operating funds.
While we strive to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining industry-leading protections.
5. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our platform. These include:
- Essential cookies: Required for the platform to function, including session management, authentication, and security features.
- Analytics cookies: Help us understand how users interact with our platform so we can improve functionality and user experience.
- Preference cookies: Remember your settings and preferences for a more personalized experience.
You can manage cookie preferences through your browser settings. Disabling essential cookies may impact your ability to use certain features of our platform.
6. Data Retention
We retain your personal information for as long as necessary to provide our Services and fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law. Specifically:
- Account data: Retained for the duration of your account and for a reasonable period after account closure to comply with legal obligations.
- Transaction records: Retained for a minimum of seven (7) years to comply with financial regulations and tax reporting requirements.
- Communication records: Retained for a minimum of three (3) years or as required for dispute resolution.
- Usage data: Aggregated and anonymized usage data may be retained indefinitely for analytics purposes.
7. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Right of access: You may request a copy of the personal information we hold about you.
- Right to correction: You may request that we correct inaccurate or incomplete personal information.
- Right to deletion: You may request that we delete your personal information, subject to legal retention requirements. Note that transaction records may need to be retained for regulatory compliance.
- Right to data portability: You may request a machine-readable copy of certain personal information.
- Right to restrict processing: You may request that we limit how we use your information in certain circumstances.
- Right to object: You may object to our processing of your personal information for direct marketing purposes.
- Right to withdraw consent: Where processing is based on consent, you may withdraw your consent at any time.
To exercise any of these rights, please contact us at privacy@kealee.com. We will respond to your request within 30 days. We may ask you to verify your identity before processing your request.
8. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at privacy@kealee.com.
9. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date and, where required, by sending you a notification via email or through the platform. We encourage you to review this policy periodically.
10. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
11. State-Specific Disclosures
California Residents
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect and how it is used, the right to request deletion, and the right to opt out of the sale of personal information. Kealee does not sell personal information. To exercise your CCPA rights, contact us at privacy@kealee.com.
Maryland Residents
If you are a Maryland resident, you may have rights under the Maryland Personal Information Protection Act. We comply with all applicable Maryland data protection requirements. For questions about your rights under Maryland law, contact us at the address above.