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Privacy and Data Protection Policy

Terms of Service here.
Privacy and Data Protection Policy Table of Contents
What this Privacy and Data Protection Policy Covers
Personal Data
  • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting Personal Data
How We Share Your Personal Data
Tracking Tools and Opt-Out
Data Security and Retention
Personal Data of Children
California Resident Rights
European Union and United Kingdom Data Subject Rights
Changes to this Privacy and Data Protection Policy
Contact Information
What this Privacy and Data Protection Policy Covers
Category of Personal Data 
Examples of Personal Data We Collect
Categories of Third Parties With Whom We Share this Personal Data: 
  • First and last name – but you may choose to provide a pseudonym instead
  • Email address
  • Phone number – but only if you choose to provide it to us as an additional contact method
  • Mailing address – mailing addresses are only collected when shipping you physical goods, and they are deleted after you have received the shipment and finished successful setup of your Casa account
  • Unique identifiers such as account name and passwords 
  • Service Providers
  • Business Partners
  • Parties You Authorize, Access or Authenticate
  • Driver’s license number – but only if you choose to provide it to us in connection with our Inheritance service or creating a Shared Account.
  • Service Providers
  • Payment card type
  • Credit or debit card number (last 4 digits)
  • Billing address and email
  • Our payment processor, which is Stripe, Inc. 
  • Purchase history for Casa product purchases
  • Consumer profiles based on information you provide to Casa
  • Service Providers
  • Analytics Partners
  • IP address
  • Email domain
  • Type of device/operating system/browser used to access the Services
  • Service Providers
  • Analytics Partners
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • IP-address-based location information
  • Service Providers
  • Analytics Partners
  • Photos, videos or recordings of yourself or your environment– but only if you choose to provide it to us in connection with our Emergency Security and Recovery Key services
  • Service Providers
  • Profiles reflecting user attributes, behavior, preferences
  • Service Providers
  • Analytics Partners
  • Identifying information in emails or letters you send us
  • Service Providers
Categories of Sources of Personal Data
You
  • When you provide such information directly to us.
    - When you create an account or use our interactive tools and Services.
    - When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    - When you send us an email or otherwise contact us.  
  • When you use the Services and such information is collected automatically.
    - Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
    - If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
    - If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties
  • Vendors
    - We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    - We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners
    - We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Commercial or Business Purposes for Collecting Personal Data

  • Creating and managing your account or other user profiles.
  • Processing orders or other transactions; billing.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
  • Marketing and selling the Services.
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Services or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Services or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.
  • Hosting, technology and communication providers.
  • Support and customer service vendors.
  • Payment processors.
    - Our payment processing partners, Stripe, Inc. and BTCPay, collect your voluntarily-provided payment card information as necessary to process your payment. Please see their respective terms of service and Privacy Policy for information on their use and storage of your Personal Data.
  • Ad networks.
  • Marketing providers.
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
  • Businesses that you have a relationship with and choose to connect with Casa.
  • Companies that we partner with to offer joint promotional offers or opportunities.
  • Third parties you access through the services.
  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. 
    - Profile or Contact Data
    - Identifiers
    - Sensory Data
    - Payment Data
    - Other Identifying Information that You Voluntarily Choose to Provide
  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: 
    - Commercial Data
    - Device/IP Data
    - Web Analytics
    - Geolocation Data
    - Inferences Drawn From Other Personal Data Collected
    - Other Identifying Information that You Voluntarily Choose to Provide
    - We may also de-identify or anonymize Personal Data to further our legitimate interests. 

    Examples of these legitimate interests include (as described in more detail above):
    - Providing, customizing and improving the Services.
    - Marketing the Services.
    - Corresponding with you.
    - Meeting legal requirements and enforcing legal terms.
    - Completing corporate transactions. 
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems. 
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. 
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. 
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes. 
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Services' practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
     
  • (857) 598-4354
  • https://keys.casa
  • [email protected]
  • 1624 Market St, Ste 226, PMB 78958, Denver CO 80202, United States