Privacy Policy

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Effective Date: December 19, 2025
Company: Key 2 Recovery, Inc. (“Key 2,” “we,” “us,” or “our”)

1) Scope

This Privacy Policy describes how Key 2collects, uses, discloses, and protects information when you:

  • Visit our websites and related pages (the “Site”);
  • Use our online portals and payment tools (the “Portal”);
  • Contact us by phone, email, SMS/text message, webform, mail, or     other methods; or
  • Interact with us in connection with account recovery services     performed on behalf of our clients (such as schools, institutions, or     other creditors).

2) Information We Collect

We may collect the following categories ofinformation:

A. Identifiers & contact information
Name, mailing address, email address, phone number, and similar contactdetails.

B. Account related information
Information related to an account placed with Key 2 for recovery, which mayinclude account identifiers, balances, payment history, and related recordsprovided by our clients during servicing.

C. Verification information
To help verify identity and protect accounts, we may obtain information such asdate of birth, partial Social Security number (e.g., last 4 digits), and otherauthentication data.

D. Payment information
If you make a payment, we (and our payment processors) may collect paymentdetails such as bank account information for ACH, debit/credit card details,billing information, and transaction history.

E. Communications
Call recordings where permitted by law, voicemails, emails, SMS/text messages,chat interactions, and other communications with Key 2.

F. Website/Portal usage & devicedata
IP address, device identifiers, browser type, operating system, pages viewed,referring/exit pages, approximate location derived from IP, and similaranalytics/usage data.

G. Client-provided placement files
If you are an institutional client, you may upload files (e.g., spreadsheets,PDFs, word processing documents) containing account data for placement orservicing.

3) How We Collect Information

We collect information:

  • Directly from you (e.g., when you     submit a form, make a payment, contact us, or use the Portal);
  • From our clients/creditors (e.g.,     institutions that place accounts with Key 2);
  • Automatically (e.g., through     cookies or similar technologies on the Site/Portal); and
  • From service providers supporting     our operations (e.g., hosting, analytics, payment processing).

4) How We Use Information

We may use information to:

  • Provide and operate the Site, Portal, and our services;
  • Verify identity and prevent fraud or unauthorized access;
  • Communicate with you about an account, payment options,     notices, and support;
  • Process payments and maintain transaction records;
  • Comply with applicable laws and regulatory requirements;
  • Maintain security, audit, and internal controls;
  • Improve our services, training, quality assurance, and customer     experience; and
  • Protect our rights, property, and the safety of users and     others.

5) How We Disclose Information

We may disclose information:

  • To our clients/creditors in     connection with servicing activities;
  • To service providers that perform     functions on our behalf (e.g., website hosting, payment processing,     communications, data security, analytics) under appropriate contractual     restrictions;
  • For legal and compliance reasons     (e.g., to comply with law, court orders, subpoenas, regulatory requests,     or to protect rights and safety);
  • In business transfers (e.g.,     merger, acquisition, financing, or sale of assets), subject to customary     confidentiality protections; and
  • With your direction/consent where     applicable.

6) Cookies, Analytics, and Tracking

We may use cookies and similar technologiesto operate the Site/Portal, remember preferences, enhance security, andunderstand usage. You can control cookies through browser settings, butdisabling cookies may affect functionality.

7) Communications, Calls, and TextMessages

If you provide a phone number or othercontact details, you may receive communications from Key 2 Recovery related toyour account. Where required, we will obtain appropriate consent. You can optout of communications by using the unsubscribe method provided.

For account-related SMS/text messages(if you opt in or otherwise consent), message frequency may vary andmessage/data rates may apply. You can opt out by replying STOP

8) Information Security

We use reasonable administrative,technical, and physical safeguards to protect information. However, no methodof transmission or storage is completely secure, and we cannot guaranteeabsolute security.

9) Data Retention

We retain information for as long as reasonablynecessary to:

  • Provide services and manage accounts;
  • Maintain business records;
  • Comply with legal/regulatory requirements; and
  • Resolve disputes and enforce agreements.
        Retention periods vary depending on the type of information and the     purpose for which it is maintained.

10) Children’s Privacy

Our Site/Portal is not directed to childrenunder 18, and we do not knowingly collect personal information from childrenunder 18 without appropriate authorization.

11) External Links

Our Site may include links to third-partywebsites. We are not responsible for the privacy practices of those thirdparties.

12) Changes to This Privacy Policy

We may update this Privacy Policy from timeto time. The “Effective Date” above indicates when the latest version took effect.

13) Contact Us

Key 2 Recovery, Inc.
8584 Washington St.  Suite 104 ChagrinFalls Ohio 44023
Email: info@key2recovery.com
Phone: 877.322.KEY2

California Privacy Notice

This section applies to Californiaresidents to the extent the California Consumer Privacy Act as amendedby the California Privacy Rights Act (“CCPA/CPRA”) applies.

A) Notice

We collect the categories of personalinformation listed in Section 2 above for the business purposesdescribed in Section 4, and we retain information as described in Section9.

B) Your California Privacy Rights

Subject to certain exceptions, Californiaresidents may have the right to:

  • Request to know/access the personal information a     business collects about you;
  • Request deletion of personal information;
  • Request correction of inaccurate personal information;
  • Opt out of the sale or sharing     of personal information (if applicable);
  • Limit the use/disclosure of sensitive     personal information (if applicable); and
  • Not be discriminated against for exercising privacy rights.

C) Submitting Requests

You may submit a request by:

  • Emailing: info@key2recovery.com
  • Mailing: 8584 Washington St.      Suite 104 Chagrin Falls Ohio 44023

We may need to verify your identity beforecompleting certain requests (for example, by confirming data points related toyour account). If you use an authorized agent, we may require proof ofauthorization and may still need to verify your identity directly, as permittedby law.

D) Response Timing

We will respond within the timeframerequired by California law. If we need additional time, we will notify you asrequired.

E) Sale/Sharing, Targeted Advertising,and Opt-Out Preference Signals

If our online activities are considered a“sale” or “sharing” of personal information under the CCPA/CPRA, you may optout. Where applicable, we will also process valid opt-out preference signals(such as the Global Privacy Control) as required.

F) “Shine the Light”

California Civil Code section 1798.83 maypermit California residents to request information regarding certaindisclosures of personal information for direct marketing purposes. You maysubmit such a request using the contact methods above.