Privacy Policy

KeyLake Capital Group LLC, its parents, subsidiaries, and affiliates (collectively "KeyLake", "Company", and "We"), are committed to maintaining the privacy of website users in accordance with the provisions herein.

This policy describes the types of information we may collect from you or that you may provide when you visit this website (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual that we collect online when they seek our Services on behalf of their business and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Site and Services:

Apply for Financing. To apply for financing with or through us, you will create an account with us and provide us with your name, email address, telephone number, and you will create a password for future logins. You will also provide us with your physical address, Social Security number, business information including business name, size, and type, and financial information including bank statements, credit card statements, average bank balance, personal and business credit history, payment behavior, bank account information, and tax identification number. We may also collect your beneficial ownership information.
Chat. If you use our chat feature, you will provide your name, phone number, and any other information you choose to provide in your message. Wix.com, Inc. (heretofore "Wix",) provides our chat feature and may collect, record, and store the information you provide in the chat. Please review Wix's privacy policy for further information.

Information As You Navigate The Site

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
Device Information. For example, IP address, hardware model, operating system, application version number, and browser.
Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
Location Information. Location information from Site visitors on a city-regional basis.

Third Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of our chat feature, you may provide the name and phone number of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

Third Party Sources

To provide our Services, we may receive Personally Identifiable Information about you from third parties including but not limited to credit reporting agencies, identity verification and fraud detection providers, and the government.

How We Use Your Information

How We Share Your Information

We may share the information that we collect about you in the following ways:

Third-party brokers, lenders, lending platforms, and other companies that we partner with;
With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
With vendors to prepare, deploy and analyze advertising content;
To the extent that we are required to do so by law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
With any other person or entity where you consent to the disclosure; and
For any other purpose disclosed by us when you provide the Personally Identifiable Information or for any other purpose we deem necessary, including to protect the health or safety of others.

Sharing excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Cookies and Other Information Technologies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

Estimate audience size and usage patterns;
Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
Advertise new content and services that relate to your interests;
Keep track of advertisements and search engine results;
Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
Recognize when you return to the Site.

We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information, to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Facebook and other similar companies.

You can block Cookies by changing your Internet browser settings. You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Other Types of Collecting Activities

The Site and Services may use Cookies and similar technologies third-party vendors provide to collect information on user behavior (e.g., screens and pages visited, buttons and links clicked, limited information entered, and user taps and mouse movements). This information enables us to monitor and improve the user experience.

Opt-Out Preference Signals

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out and this will be indicated in the banner notice that appears when you visit our website. You can manually indicate your preferences via the Do Not Sell or Share My Personal Information link at the bottom of the website. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Controlling Your Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at info@keylake.org or by writing to us at:

KeyLake Capital

30 Wall Street, 8th Floor

New York, NY 10006

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You may also access the email preferences in your account settings page, submit a request to us at info@keylake.org, or write to us at the contact information below.

Our Site offers publicly accessible blogs or community forums. To request removal of your Personally Identifiable Information from our blog or community forum, please contact us at info@keylake.org or write to us at the contact information below.

We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@keylake.org or write to us at:

KeyLake Capital

30 Wall Street, 8th Floor

New York, NY 100006

Protecting Your Information

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security. If you allow us to see your banking information online rather than in paper form, it is on a read-only basis. We do not have access to change, edit, or modify bank account information in any way. KeyLake employees cannot view your banking username and passwords.

Children's Privacy

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us via email at info@keylake.org.

Notice to Nevada Residents

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to info@keylake.org

Notice to California Residents

Effective January 1, 2023, the California Privacy Rights Act(“CPRA”) provides specific rights to California residents related to their “personal information,” as defined under the CPRA. CPRA provides you with certain rights with respect to this information. This section enumerates the CPRA required disclosures and details those rights under the CPRA. Personal information does not include information that is publicly available, deidentified, or aggregated. This section only applies to California residents. The rights discussed in this section do not extend to individuals who are not California residents.

Throughout your interactions with KeyLake, we collect various types of information about you. In the past 12 months, we have collected the following categories of personal information about California residents who are website visitors, users, and businesses that access Services provided by or through KeyLake:

Category

Examples

Identifiers

First and last name, mailing address, Internet Protocol (IP) address, email address, social security number, driver’s license number, or other similar identifiers

Categories of information described in the California Customer Records Statute

First and last name, social security number, address, primary telephone number, job title, bank account number, or any other financial information

Commercial or transactions information

Products or services purchased, obtained, or considered

Sensory data

Audio or similar information

Internet or other electronic network activity information

Information about your internet connection, including IP address, geographical location, operating system, browser type, referral source, time and length of visit, button clicks and/or page views, and your mobile device identifier (IDFA or AAID)

Professional or employment-related information

Job title

Income

We collect the information listed above from the following categories of sources: (i) information provided by you, (ii) information we collected when you use our Services, or (iii) information received from third parties. We may use information we collect for purposes set forth above.

KeyLake may share your personal information with third party service providers to help us conduct the business purposes listed above, including, but not limited to, sharing with service providers to assist us in providing the Services. Our service providers are authorized to use your personal information only as necessary to provide their services to us. Additionally, KeyLake may share your personal information: (i) as required by law; (ii) in connection with an audit or the sale of KeyLake to a third party; or (iii) with your consent. We do not sell or otherwise share your personal information.

Under the CPRA, California residents have the right to request that KeyLake disclose what information we have collected, used, disclosed, or sold over the past 12 months. Once we receive and confirm your verifiable consumer request for such information, (see “How You Can Exercise Your Rights Under CPRA”), we will disclose to you:

The categories and specific pieces of personal information we collected about you over the past 12 months
The categories of sources from which such personal information has been collected over the past 12 months
The business or commercial purpose for collecting, disclosing or selling such personal information over the past 12 months
The categories of third parties with whom we shared your personal information over the past 12 months; and
If we disclosed your personal information for a business purpose, the personal information categories that each category of recipients obtained.

Under the CPRA, California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, and direct our service providers to do the same, unless an exception applies.

Under the CPRA, California residents have the right to direct us to not sell your personal information (the “right to opt-out”). KeyLake does not and will not sell or otherwise share personal information of consumers.

Under the CPRA, California residents have the right not to be discriminated against for having exercised the rights established by the CPRA. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

Deny you goods or services

Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties

Provide you with a different level or quality of goods or services

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

We may, however, offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Such financial incentives may include gift cards, credits, and other monetary offerings; additional details related to the material terms of these financial incentives will be provided to you at the time the incentive is presented to you. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

In order to exercise the right to know/right to access information and the right to request deletion, you or your authorized agent may submit a verifiable consumer request either by contacting us by phone at (718) 799-3642 with a brief description of your request. Please note that we may request additional information from you or your agent as needed to authenticate your request. You may only make a verifiable consumer request to know or request for access twice within a 12-month period.

The verifiable consumer request must do the following:

• Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information or that you are an authorized representative.

• Describe your request with sufficient detail so that we can properly understand, evaluate, and respond to it.
If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

We will not disclose information to you or delete information if we cannot verify your identity.

Only you as a California resident, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request to know/request for access, request for deletion, or request to opt-out. To appoint an authorized representative to submit requests on your behalf, please provide us with written instructions stating the identity of the authorized representative and your authorization to have the representative act on your behalf by emailing us. We may also request additional information from you as needed to authenticate your request. If an authorized representative is acting on your behalf, your representative may contact us by phone at (718) 799-3642 with a brief description of your request. Please note that we may request additional information from your representative as needed to authenticate your request.

Changes to the Privacy Policy

By visiting the Sites or using our Services, you accept the practices described in this Privacy Policy. We may update this Privacy Policy from time to time by making available a revised, dated version on the Sites. If the revised version includes a substantial change, we will provide a more prominent notice (including, for certain services, an email or other type of notification of Privacy Policy changes) prior to the change becoming effective. Your continued use of the Sites shall constitute your acceptance of such updated Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Site and Services, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

Compile, save, use, and analyze your Personally Identifiable Information in both a personally identifiable form and as part of aggregated data;
Operate, maintain, improve, and provide to you the Services and to conduct our business activities, including our own credit products and referring you to third party small business lenders;
Verify your identity and conduct appropriate due diligence;
Register you as a user and identify you when you sign into your account;
Process your business’ application and determine whether or not your business qualifies for our products;
Service your business product account, including deducting automatic payments;
Communicate with you regarding your account, respond to customer service requests, send marketing communications, and send account update notifications;
Post and review your comments on our blog;
Conducts tests, research and analyses to better understand our customers;
Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
Provide support;
Maintain and improve our Site and Services;
Protect the security and integrity of our Site and Services;
Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use, and to otherwise fulfill our legal obligations;
Monitor compliance with and enforce this Privacy Policy and any other applicable agreements and policies;
Defend our legal rights and the rights of others;
Fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate;
Efficiently maintain our business;
Comply with applicable law;
Produce data analytics and reports containing de-identified summaries of Personally Identifiable Information and other information that is not Personally Identifiable Information (such information, “General Information”) that we share with business partners. General Information may include Personally Identifiable Information that has been aggregated and will not identify you.