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Privacy Policy and SMS Disclosure

Effective Date: Aug 19, 2026
Last Updated: Sep 11, 2026

1. Introduction And Corporate Identity

This Privacy Policy and SMS Disclosures document (“Policy”) governs the privacy practices of Path to Keyes, LLC (“the Company,” “we,” “us,” or “our”), a registered Credit Services Organization and mortgage-readiness counseling firm. We are committed to protecting the privacy and security of our clients, prospective clients, and website visitors.

This Policy outlines how we collect, use, disclose, and safeguard your personal information when you visit our website, interact with our landing pages, use our secure portal, or enroll in our digital mortgage-readiness program.

To maintain absolute transparency and ensure strict regulatory compliance with the Employer Identification Number (EIN) brand registration requirements of mobile carriers and federal authorities, our official corporate identity is as follows:

  • Legal Business Name: Path to Keyes, LLC
  • Corporate Physical Headquarters Address: 211 E 43rd St, Ste 6th Fl. NY, 10017
  • Official Support Email Address: info@pathtokeyes.com
  • Official Support Phone: (518) 268-0589

By accessing our website, submitting information through our webforms, or opting into our communications, you acknowledge and agree to the terms described in this Policy.

2. Compliance Scope, Scope Of Services, And CROA Alignment

The Company operates in strict alignment with the Credit Repair Organizations Act (CROA) (15 U.S.C. §§ 1679–1679j) and applicable state Credit Services Organization (CSO) statutes.

A. No Outcomes or Credit Score Guarantees

In compliance with CROA Section 1679b, the Company does not guarantee any specific credit score increase, credit report modification, or home loan approval outcomes. Credit profile optimization depends entirely on individual consumer profiles, historical data, and external financial behavior; therefore, results will vary by client.

B. Claim and Marketing Restrictions

The Company does not make, and will not make, any claims of “fast results” or promises regarding the removal of accurate, timely, or non-obsolete historical credit marks from your consumer files. We do not engage in any activities designed to assist consumers in misrepresenting their credit history or creditworthiness.

C. Framing of Services

The program and educational resources provided by the Company are strictly structured as:

  1. Financial Literacy Education: Providing digital courses, instructional curricula, and structured materials on credit scoring mechanisms.
  2. Mortgage Readiness Counseling: Educating consumers on standard underwriting boundaries, debt-to-income (DTI) calculations, and mortgage underwriting prerequisites.
  3. Credit File Audit and Optimization: Analyzing historical credit data, simulating potential credit actions (e.g., balance paydowns), and identifying point-loss factors to prepare a client for a future mortgage application.

3. Information We Collect

To deliver our mortgage-readiness program and facilitate technical integrations, we collect several categories of information.

A. Voluntarily Provided Information

We collect personal information that you choose to submit to us through our automated, self-service intake forms on our website and landing pages. This includes:

  • Contact information such as your full name, physical mailing address, email address, and mobile phone number.
  • Referral details submitted through our B2B Mortgage Loan Officer (LO) or Real Estate Partner portals (such as referring officer name, company, email, phone, and client name).
  • Transactional financial details and payment credentials when establishing your secure, self-service account through our payment forms.

B. Soft Credit Inquiry Data

To assess your starting credit profile and prevent the activation of aggressive, third-party competitor “trigger leads” generated by hard credit inquiries.

  • When you complete our self-directed intake form, our platform facilitates a secure soft credit inquiry to retrieve your data.
  • To ensure absolute bank-grade security and proper bureau identity verification, this process requires your standard identifying information, including your Social Security Number (SSN) and Date of Birth.
  • This soft inquiry safely retrieves your tri-bureau mortgage FICO scores, income estimates, and debt-to-income metrics.
  • Because this is a soft inquiry, it does not impact your credit score, does not register on public consumer files, and legally blocks the bureaus from selling your information to marketing trigger lists.

C. Automatically Collected Technical Data

Like most digital platforms, our servers automatically log certain technical information, including your IP address, browser type, operating system, pages viewed, time spent on our site, and referring URLs.

4. How We Use Your Information

The Company processes and shares your personal data strictly for functional program delivery, compliance enforcement, and direct technical integrations.

A. Operational and Integration Purposes

We use your information to:

  1. Automate Account Creation & Sequencing: Process your intake data securely upon submission of your onboarding request to establish your private portal profile and initiate automated account sequencing.
  2. Execute Legal Agreements & Verify Identity: Process electronic signatures on your Credit Services Organization (CSO) Service Agreement and Limited Power of Attorney (LPOA), and securely handle your identity verification documentation—including Photo ID, proof of address, and Social Security Number—for credit bureau file matching and real-time document tracking.
  3. Integrate Tri-Bureau Credit Monitoring: Receive and securely process your IdentityIQ® data feed to link your 3-bureau credit reports. IdentityIQ® is an independent third-party monitoring service billed at $29.86 per month following a $1.00 7-day trial. Path to Keyes, LLC participates in an affiliate program with IdentityIQ® and receives a $5.82 monthly recurring commission per active subscription. This continuous API integration allows our system to retrieve score updates and debt profiles without requiring or storing your external portal passwords.
  4. Enforce Programmatic Onboarding Gates: Programmatically verify completion of mandatory onboarding steps—including signed legal agreements, identity verification, active IdentityIQ® monitoring, and $0 setup registration—before unlocking access to your gated digital portal, 15-volume financial literacy eBook library, and 24/7 site-wide AI Companion.
  5. Process $0 Setup & Billing in Arrears: Collect card details to complete your $0 setup verification and maintain regulatory compliance with the Credit Repair Organizations Act (CROA) and FTC Telemarketing Sales Rule (TSR) by delaying your recurring $99 monthly service fee strictly only after your initial credit file audit report is prepared and delivered to your inbox.

B. Prohibition of Telemarketing Under the TSR

In compliance with the TSR (16 C.F.R. Part 310), the Company operates an entirely automated, self-directed, digital-only onboarding funnel. We strictly prohibit pre-sale outbound follow-up calls, pre-sale inbound discovery calls, or live pre-sale video consultations with prospective clients. All clients must execute their written service agreements and input billing methods in this self-service environment prior to any verbal or consultative contact with our team.

C. IdentityIQ® Data Sharing Boundaries

  • Native API Transmission: Nonpublic Personal Information (NPI) shared with IdentityIQ® is transmitted strictly through encrypted server-to-server API calls to facilitate credit report import and ongoing score tracking.
  • No Credential Brokering: The Company does not store, rent, or sell your IdentityIQ® login credentials or credit report files to unauthorized third parties.
  • Independent Service Privacy: Account management and billing details for IdentityIQ® are managed independently by the provider under its own Privacy Policy.

D. Rent Reporting & Rental Kharma Operational Data Handling

  • Consumer-Directed Service Enrollment: When you choose to enroll in Rental Kharma via our landing pages or portal links, you are directed to an independent third-party platform. Any personal information, lease history, or landlord details you submit during registration are collected directly by Rental Kharma and governed by its independent Privacy Policy.
  • Aggregated Commission Accounting: Rental Kharma provides Path to Keyes, LLC with de-identified, aggregated operational data (e.g., total monthly enrollments and completion milestones) solely for affiliate commission accounting. Rental Kharma does not transmit your specific lease agreements, tradeline records, or credit score outputs back to Path to Keyes, LLC without your explicit written authorization.

5. SMS Consent And Mobile Data Privacy Protection Policy

(This section is maintained in strict compliance with Mobile Carrier A2P 10DLC Guidelines and TCR Brand Vetting Code 30932).

SMS Consent and Mobile Data Privacy Protection Policy

Consumer mobile opt-in data, phone numbers, and consent details will never be shared, sold, rented, leased, or transferred to any third parties, commercial partners, lead generators, or corporate affiliates for marketing or promotional purposes under any circumstances.

Absolute Data Carve-Out

The Company maintains an absolute separation between your mobile carrier data and all other general business operations. For the avoidance of doubt:

  • No third-party marketing agreements, affiliate programs, or promotional joint ventures will ever include your mobile number or opt-in consent.
  • No consumer mobile information collected on our website, landing pages, or portals will be shared with external service providers for their independent marketing or promotional purposes.
  • Any general information-sharing provisions contained elsewhere in this Privacy Policy do not apply to mobile phone numbers, SMS opt-in data, or consent details, which are strictly protected under this carve-out.

6. SMS Messaging Terms, Frequency, And Opt-Out/Help Protocols

(This section is maintained in strict compliance with A2P 10DLC Vetting Codes 30909, 30913, 30923, 30924, and 30925).

A. Voluntary Opt-In and Independence of Consent

  • Optional Enrollment: Submitting your mobile phone number and opting into our text notifications is entirely voluntary and optional.
  • Unbundled Checkboxes: Consent for SMS notifications is collected through a separate, unbundled, and unchecked-by-default checkbox next to our webform submit buttons.
  • No Pre-Requisite: Opting in to receive text messages is never a condition of purchase, enrollment in our program, or access to our digital services, portals, and eBooks. You may submit any form on our website without opting in to text messages.

B. SMS Use Case and Content Restrictions

To prevent carrier rejections, network penalties, and to maintain our registered campaign classification as a transactional channel:

  • Transactional Alerts Only: Our SMS channel is strictly restricted to automated, non-promotional, transactional, and customer support alerts (e.g., multi-factor authentication codes, client portal registration links, document upload confirmations, and critical progress milestones).
  • Email Redirection: All marketing, promotional outreach, and dispute-specific communications are strictly offloaded to secure email channels .

C. Expected Message Frequency

Message frequency is highly variable and depends entirely on your active transactional milestones during your onboarding and program participation. On average, active clients can expect between 2 to 6 transactional alerts per month.

D. Standard Carrier Rates

Message and data rates may apply to any text messages sent by us or received by you. Please check with your mobile service provider for details on your plan’s standard rates.

E. Help and Opt-Out Commands

We provide automated, immediate systems to manage your messaging preferences:

  • To Stop Messaging: You may opt out of our text communications at any time. Text “STOP” to our sending number to immediately terminate SMS messaging. You will receive a single confirmation text verifying that you have been unsubscribed.
  • To Get Assistance: Text “HELP” to our sending number at any time to receive direct contact instructions and customer support information. Alternatively, you can email us at info@pathtokeyes.com or via telephone at (518) 268-0589.

F. Engagement of Technical Infrastructure Vendors

Mobile telephone numbers and transactional message payloads are processed by trusted telecommunications gateway providers and Campaign Service Providers solely as technically necessary to transmit communications across cellular carrier networks. All such infrastructure providers are subject to binding contractual confidentiality obligations prohibiting the retention, transfer, aggregation, or secondary utilization of mobile data for any outside commercial purpose.

7. Data Security, Storage, And Credential Integrity

We implement industry-standard administrative, physical, and technical security measures to protect your personal data from unauthorized access, loss, or misuse.

  • Access Control: Access to our backend platforms is restricted to authorized administrative personnel and verified virtual assistants under strict security protocols.
  • No Brokering or Storage of SSNs: We do not collect, process, or store your Social Security Number or Date of Birth on our web servers, significantly reducing your identity theft risk profile.

8. Third-Party Links And Manual Compliance Partners

Our website, portals, and materials may contain links to external third-party service providers. To protect your consumer rights and maintain strict compliance with CROA and federal advertising standards:

  • Manual, Client-Initiated Links Only: All outbound links to our third-party compliance and legal partners are manual, client-initiated links.
  • No Automated Brokering: There is no background API integration, database sharing, real-time data brokering, or reselling of customer files between the Company and these partners.
  • No Outcome Guarantees: Any co-marketing copy describing these third-party services outlines only what the service does, without guaranteeing specific credit or legal outcomes.
  • Consumer Freedom of Choice: You are under no obligation to utilize these third-party services, and you are free to select any alternative service provider.

8.A Rental Kharma Affiliate Tracking, Cookies, and Privacy Controls

  • Affiliate Links & Cookie Utilization: Our platform utilizes outbound affiliate hyperlinks and tracking cookies to confirm client referrals to Rental Kharma. Clicking an affiliate link appends anonymous campaign tokens (e.g., ?partner=pathtokeyes) to track referral origin.
  • Strict URL Parameter Hygiene: Path to Keyes, LLC strictly adheres to GLBA privacy standards. We never pass Nonpublic Personal Information (NPI)—including Social Security numbers, bank details, phone numbers, or email addresses—through URL query strings, tracking pixels, or unencrypted web tags.
  • Commercial Affiliate Compensation: Path to Keyes, LLC receives financial compensation or referral fees from Rental Kharma for user sign-ups generated through our affiliate links. Enrolling in Rental Kharma is entirely optional, and choosing not to enroll does not restrict your access to Path to Keyes, LLC’s core educational coaching.
  • Vendor Security Oversight (FTC Safeguards Rule): In accordance with the FTC Safeguards Rule (16 C.F.R. Part 314), Path to Keyes, LLC conducts periodic vendor due diligence to verify that commercial partners, including Rental Kharma, maintain TLS encryption in transit, administrative access controls, and secure data storage standards.

C. Cross-Reference Section 5 (SMS Mobile Data Carve-Out)

Note: In accordance with Mobile Carrier A2P 10DLC Guidelines (Vetting Code 30932), consumer mobile opt-in data and phone numbers are strictly carved out and will never be shared with, sold to, or rented to Rental Kharma, IdentityIQ®, or any affiliate partner for marketing or promotional purposes.

9. Your Legal Rights, and Opt-Out Choices

Depending on your state of residence, you may have specific legal rights regarding your personal data and your relationship with a Credit Services Organization (CSO).

A. Your General Rights

You have the right to:

  • Access, correct, or request the deletion of the voluntarily provided personal information..
  • Opt out of any marketing emails by clicking the “Unsubscribe” link at the bottom of our emails.
  • Request copies of all documents and correspondence sent on your behalf as part of your file audit and counseling history.

10. Corporate Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy and SMS Disclosures document, or if you wish to exercise your legal rights, please contact our administrative team directly:

Path to Keyes, LLC
Attn: Legal Compliance Department
Corporate Headquarters: 211 E 43rd St, Ste 6th Fl. NY, 10017
Official Support Email: info@pathtokeyes.com
Official Support Phone: (518) 268-0589
Website URL: https://www.pathtokeyes.com/