Customer Data Certification

Last Updated: May 29, 2026

This Customer Data Certification ("Certification") supplements the Frontkey Terms of Service. By accepting this Certification on behalf of your account, you represent, warrant, and agree that:

1. Authority

You have authority to accept this Certification on behalf of the account, customer, business, owner, or property manager using the Services.

2. Customer-Controlled Data

Your account may choose to upload, store, transmit, or otherwise manage information about tenants, applicants, residents, guarantors, owners, contractors, vendors, or other third parties through the Services, including sensitive, confidential, or regulated information. This can include sending invitation emails, directing Frontkey to send tenants transactional property notices, sending tenant-facing reminder or coordination emails, publishing or sharing property Passport content through time-limited links, and making documents, events, or other records available to third parties. You—not Frontkey—decide what information to upload, why to upload it, with whom to share it, and how long to retain it.

3. Notices, Permissions, Consents, and Other Legal Bases

You are solely responsible for determining and maintaining the notices, permissions, consents, authorizations, certifications, permissible purposes, and other legal bases required for the collection, use, disclosure, retention, and processing of information handled through your account.

You are not representing that every tenant, applicant, resident, or other third party has entered into a contract directly with Frontkey. Instead, you are representing that, to the extent required by applicable law for the data or workflow at issue, you have provided or will provide required notices and obtained or will obtain required permissions, consents, authorizations, certifications, permissible purposes, and other legal bases necessary for your use of the Services.

This responsibility applies to all tenant-facing or third-party-facing workflows you trigger through the Services, including invitation emails, transactional property notices, reminder or coordination emails, weekly or periodic summaries that include third-party information, tenant-facing documents or events, and published or publicly shared Passport content or share links.

4. Screening and Consumer Reports

If your account obtains, uploads, stores, uses, or relies on any tenant screening report, credit report, background report, criminal history report, eviction history report, investigative consumer report, or other consumer report or related information, you are solely responsible for:

• ensuring you have any permissible purpose and any required permissions, certifications, or authorizations;
• using the information only for lawful housing-related purposes;
• providing any required notices, including adverse-action notices;
• complying with applicable retention, redaction, and secure disposal obligations; and
• complying with applicable fair housing, consumer protection, privacy, data security, and recordkeeping laws.

5. Data Minimization, Retention, and Deletion

You are solely responsible for deciding whether the Services are appropriate for the information you upload and for applying appropriate minimization, redaction, retention, deletion, disposal, and access practices. You are also solely responsible for deciding what information may be included in invitation emails, transactional property notices, reminder emails, shared or public pages, or time-limited share links, and for revoking, deleting, or retiring those workflows when no longer appropriate.

6. Security of Your Account and Authorized Users

You are solely responsible for controlling your Authorized Users, limiting access based on need, maintaining credential security, using multi-factor authentication where available or required, and promptly revoking access when no longer needed.

7. Frontkey's Role

Frontkey is a software provider. Frontkey is not your lawyer, compliance department, records custodian, property manager, landlord agent, consumer reporting agency, or screening provider, and Frontkey does not make leasing, screening, credit, underwriting, or other eligibility decisions for you. Frontkey does not determine whether a given invitation email, transactional property notice, tenant reminder, weekly digest, or shared or public Passport page is legally sufficient, permitted, or appropriate for your use case.

8. Supplemental Effect

This Certification is incorporated into and supplements the Frontkey Terms of Service for the applicable account. If there is a conflict between this Certification and the Terms of Service on a matter specifically addressed by this Certification, this Certification controls for that matter.

9. No Third-Party Beneficiary Rights

Except as required by law, this Certification does not create rights in favor of tenants, applicants, residents, guarantors, vendors, contractors, or other third parties.

10. Contact

FrontKey FrontKey LLC 2501 Chatham Rd #6541 Springfield, IL, 62704, USA Email: contact@frontkey.app