Privacy Policy

This Privacy Policy explains how Footfallz ("Company," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use the askKeys AI chatbot ("askKeys"). This policy applies to home buyers who access askKeys through an open house, a property listing, or a direct invitation from a real estate agent.

By using askKeys, you consent to the practices described in this Privacy Policy. This policy should be read alongside our Terms of Use.

1. Information We Collect

2. How We Use Your Information

3. AI and Third-Party Processing

We take the following steps to limit your data exposure during AI processing:

• Sending only the content of your chat messages to AI providers — not your name, email, or phone number (unless you type them into the chat yourself)
• Storing all chat logs on our own secure servers, not on AI provider systems
• We may change or add AI providers at any time to improve service quality

Important: When your messages are transmitted to third-party AI providers, those providers' own privacy policies and terms of service govern how they handle that data. Footfallz does not have special agreements with AI providers that restrict their use of your data beyond their standard commercial terms. We encourage you to review the privacy policies of OpenAI, Anthropic, and OpenRouter for details on how each provider handles data submitted via their APIs.

4. How Your Information Is Shared

Depending on how you accessed askKeys, your information is shared with:

• Open house or listing agent: If you signed in at an open house or accessed askKeys through a property listing, the agent hosting that open house or managing that listing receives your information.
• Your inviting agent: If a real estate agent invited you to use askKeys directly, that agent receives your information — typically an agent you are working with or building a professional relationship with.

We also share information with:

We do not sell or share your personal information for cross-context behavioral advertising. If you have questions about this or wish to submit a request, email privacy@footfallz.com.

5. Automated Profiling

When you interact with askKeys, our platform may perform automated processing of the information you provide to generate inferences that help personalize your experience and support the real estate agent assisting you. This processing may include:

• Extracting housing preferences, location priorities, and property characteristics of interest from your conversations
• Inferring housing price-range signals and purchase readiness indicators based on your messages
• Inferring household-related preferences (such as family size or lifestyle needs) where reflected in your conversation
• Classifying buyer intent (for example, actively searching, casually browsing, or exploring a future move)

These automated inferences are used solely to personalize property recommendations and help the real estate agent who receives your chat transcript better understand your needs. They are not used to make legally significant decisions about you, such as determining eligibility for housing, credit, insurance, or financial services.

Under applicable state privacy laws, you may have the right to opt out of automated profiling or request human review. To exercise these rights, contact privacy@footfallz.com.

6. Your Privacy Rights

Depending on your state of residence, you may have the following rights:

• Right to Know: Request what personal data we hold about you
• Right to Delete: Request deletion of your personal data
• Right to Correct: Request correction of inaccurate information
• Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. We do not sell or share your personal information as defined by CCPA/CPRA. To submit a request or ask any questions, email privacy@footfallz.com.
• Right to Data Portability: Request a copy of your personal information in a portable, structured, commonly used, machine-readable format that you can transmit to another organization
• Right to Non-Discrimination: We will not treat you differently for exercising your rights

These rights are available under CCPA/CPRA (California), VCDPA (Virginia), CPA (Colorado), CTDPA (Connecticut), UCPA (Utah), and other state privacy laws.

To exercise your rights: Email privacy@footfallz.com. We will acknowledge receipt of your request within 10 business days and provide a substantive response within 45 calendar days. If we need additional time (up to 45 more days), we will notify you of the extension and the reason before the initial 45-day period expires.

Important limitation: Once your chat transcript and contact information have been shared with a real estate agent, we cannot guarantee deletion of the agent's copy. The agent's handling of your data is governed by their own privacy practices and professional obligations.

7. Cookies and Tracking

You can manage cookies through your browser settings. Disabling some cookies may affect the functionality of askKeys. Our service does not currently respond to "Do Not Track" browser signals. However, we recognize and honor Global Privacy Control (GPC) signals as required by applicable state law. When we detect a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of personal information associated with that browser.

8. Data Security

We protect your personal information with encryption in transit (TLS/SSL) and at rest, access controls on a need-to-know basis, regular security assessments, and secure cloud infrastructure. No method of transmission or storage is 100% secure, but we use commercially reasonable safeguards to protect your data.

9. Data Retention

You can request deletion at any time by emailing privacy@footfallz.com.

10. Data Breach Notification

If we discover a breach of security that results in the unauthorized access, acquisition, or disclosure of your personal information, we will:

• Notify affected individuals in the most expedient manner possible and without unreasonable delay, consistent with the legitimate needs of law enforcement
• Notify the California Attorney General if the breach affects more than 500 California residents
• Notify other applicable state regulators within the timeframes required by their respective state laws (typically within 30–90 days of discovery, depending on the state)
• Provide you with information about what happened, what data was involved, what steps we are taking, and what steps you can take to protect yourself

If you believe your information has been compromised, please contact us immediately at privacy@footfallz.com.

11. Children's Privacy

askKeys is not intended for anyone under the age of 18. We do not knowingly collect personal information from minors. If you believe a child has used askKeys, please contact privacy@footfallz.com and we will delete the data promptly.

12. California-Specific Disclosures

If you are a California resident, the following additional disclosures apply under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Categories of personal information collected in the past 12 months: identifiers (name, email, phone number, IP address), internet or other electronic network activity (device data, usage data, chat logs), geolocation data (inferred from property preferences and IP address), inferences drawn from personal information (housing preferences, purchase readiness, buyer intent), and commercial information (property and budget preferences).

Purposes for collection: to provide the askKeys chatbot service, share information with your real estate agent, improve service quality, communicate with you, and comply with applicable laws.

Categories disclosed to third parties: identifiers and chat content are disclosed to AI providers (OpenAI, Anthropic, OpenRouter) and to real estate agents as described in Section 4. Identifiers and usage data are disclosed to service providers (hosting, analytics, email).

We do not sell or share your personal information for cross-context behavioral advertising as defined by CCPA/CPRA. Because we do not engage in these activities, a formal opt-out page is not required. If you have questions or wish to submit a request, email privacy@footfallz.com.

Sensitive personal information: We may process inferences about household composition and financial readiness from your chat conversations. We do not use this information for purposes other than personalizing property recommendations and supporting your agent. You have the right to limit our use of sensitive personal information to these purposes by emailing privacy@footfallz.com.

Shine the Light: California Civil Code Section 1798.83 permits California residents to request information about the disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the service or by email. Continued use of askKeys after changes are posted constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

14. Contact Us

Questions about this Privacy Policy or your data?