Privacy Policy

1. Overview & Scope

Next Key Mortgage (“we,” “our,” or “the Company”) is a direct mortgage lender (NMLS #2721083) licensed to originate, underwrite, and fund mortgage loans. This Privacy Policy describes how we collect, use, share, and protect your personal information across all of our services.

This Policy applies to our website (nextkeymortgage.com), SMS communications (Twilio platform), email communications (Brevo platform), and all mortgage lending services we provide directly.

2. Information We Collect

Information You Provide Directly

• Identity: Full name, date of birth, Social Security number, government-issued ID
• Contact: Address, email, mobile phone number
• Financial: Income, employment, assets, liabilities, bank statements, tax returns, pay stubs
• Property: Property address, value, intended use
• Preferences: SMS opt-in status, loan type interest, contact preferences

Information Collected Automatically

• IP address, browser type, device identifiers, pages visited, referring URLs

Information from Third Parties

• Credit bureaus (Equifax, Experian, TransUnion) with your authorization
• Appraisers and title companies involved in your transaction
• Public records: property data, title information, recorded liens

3. How We Use Your Information

Purpose	Legal Basis
Originate, underwrite, and fund mortgage loans	Contractual necessity; regulatory compliance
Verify identity and prevent fraud	Legal obligation (BSA, PATRIOT Act)
Send application status updates via SMS	Express written consent (TCPA)
Send marketing emails and newsletters	Consent (CAN-SPAM / Brevo compliance)
HMDA reporting requirements	Legal obligation
Improve website and marketing	Legitimate interest; cookie consent
Respond to contact form inquiries	Legitimate interest; your consent
Service your loan through closing	Contractual necessity

4. Information Sharing & Disclosure

We do not sell, rent, or trade your personal information. As a direct lender, we share information only as necessary to complete your loan transaction:

• Settlement service providers: Appraisers, title companies, escrow agents, insurers involved in your closing
• Credit bureaus: With your authorization for credit evaluation
• Regulatory bodies: CFPB, HUD, state banking departments as required by law
• Service providers (sub-processors): Twilio (SMS delivery), Brevo (email delivery), Google Analytics (website analytics)
• Secondary market investors: If your loan is sold after closing, you will be notified as required by RESPA

5. SMS / Text Message Communications

Next Key Mortgage uses Twilio to send SMS and MMS messages. We are a direct mortgage lender — not a broker or third-party intermediary — and our SMS program complies with the TCPA, Twilio’s Messaging Policy, and CTIA standards.

Opt-In & Consent

• Marketing SMS messages are only sent after you provide express written consent through our website opt-in form
• Consent is timestamped with IP address and the specific disclosure language agreed to
• Consent is never a condition of obtaining a mortgage loan
• Pre-checked consent boxes are never used

Message Types

• Transactional: Application status, document requests, rate lock confirmations, closing reminders
• Marketing: Rate alerts, new loan programs, market updates (require explicit consent)

Opt-Out (STOP)

Reply STOP to any message to unsubscribe immediately. You will receive one confirmation and no further marketing messages. Transactional messages on active loans may continue as permitted by law.

Help (HELP)

Reply HELP to any message for support: Next Key Mortgage SMS Help • (470) 457-6149 • info@nextkeymortgage.com • Msg&Data rates may apply. Reply STOP to cancel.

Message Frequency & Rates

Message frequency varies, typically 2–8 messages per month. Standard message and data rates may apply.

Twilio Data Processing

Twilio processes phone numbers and message content solely to deliver SMS on our behalf. See twilio.com/legal/privacy.

6. Email Communications (Brevo)

We use Brevo for transactional and marketing emails, in full compliance with the CAN-SPAM Act and Brevo’s Anti-Spam Policy.

• All marketing emails clearly identify Next Key Mortgage as the direct lender sender
• Subject lines accurately reflect content
• Our physical address is included in every marketing email
• Every marketing email includes a functioning unsubscribe link
• Opt-out requests honored within 10 business days

To unsubscribe: click the link in any email or contact info@nextkeymortgage.com. See brevo.com privacy policy.

7. Cookies & Tracking Technologies

Type	Purpose	Duration
Essential	Website security and functionality	Session
Analytics	Google Analytics — page views, traffic	Up to 2 years
Marketing	Ad retargeting (Facebook Pixel)	Up to 90 days
Preferences	Remember your settings	1 year

You may disable cookies in your browser. We honor Do Not Track (DNT) signals where feasible.

8. Data Security

• 256-bit SSL/TLS encryption on all data transmissions
• Secure, access-controlled servers with multi-factor authentication
• Regular security assessments per FFIEC cybersecurity guidelines
• Incident response and breach notification procedures per applicable state laws
• Employee training on data handling and privacy requirements

9. Data Retention

Data Type	Retention Period	Reason
Loan application records	7 years	ECOA, HMDA, RESPA
Closed loan files	7–10 years	Regulatory and legal
Credit pull authorizations	25 months	ECOA compliance
SMS consent records	5 years	TCPA compliance
Email consent records	3 years after unsubscribe	CAN-SPAM compliance
Declined application records	25 months	ECOA adverse action

10. Your Privacy Rights

• Right to Know & Access: Request a copy of your personal data
• Right to Correct: Request correction of inaccurate information
• Right to Delete: Request deletion subject to legal retention requirements
• Right to Opt-Out of Sale: We do not sell data — automatically satisfied
• Right to Non-Discrimination: We will not penalize you for exercising rights
• Right to Opt-Out of SMS: Reply STOP to any message
• Right to Opt-Out of Email: Click Unsubscribe in any marketing email

To exercise rights, contact us at info@nextkeymortgage.com or (470) 457-6149. We respond within 45 days.

11. Children’s Privacy

Our services are not directed to persons under 18. We do not knowingly collect information from minors. Contact us at info@nextkeymortgage.com if you believe we have collected such information.

12. Fair Lending & Equal Credit Opportunity

Next Key Mortgage is an Equal Housing Lender. We comply fully with the Equal Credit Opportunity Act (ECOA), Fair Housing Act, Home Mortgage Disclosure Act (HMDA), and Community Reinvestment Act (CRA).

We do not discriminate based on race, color, religion, national origin, sex, marital status, age, disability, familial status, or receipt of public assistance.

13. GLBA Financial Privacy Notice

As a direct mortgage lender, Next Key Mortgage is subject to the Gramm-Leach-Bliley Act (GLBA) Privacy Rule (Regulation P). We provide initial and annual privacy notices as required and maintain a comprehensive information security program per the FTC Safeguards Rule (updated 2023).

Request a copy of our full GLBA notice by emailing info@nextkeymortgage.com.

Verify our license: NMLS #2721083 at nmlsconsumeraccess.org.

14. State-Specific Privacy Rights

California (CCPA/CPRA)

California residents have additional rights under CCPA/CPRA including access, correction, deletion, and restriction of sensitive personal information. Submit requests to info@nextkeymortgage.com.

Other States

Residents of Texas, Florida, Georgia, Colorado, Virginia, Connecticut, and other states with privacy laws may have similar rights. Contact us to learn about your state-specific rights.

15. Policy Changes

We update this Policy as needed. Material changes will be communicated by updating the effective date, emailing active customers, and posting a notice on our website. Continued use of our services constitutes acceptance.

16. Contact Us