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LAST REVISED: APRIL 15, 2026

Biometric Privacy Notice

Why are you receiving this notice?

This biometric privacy notice explains how Figure Technology Solutions, Inc, together with our affiliates and subsidiaries (including Figure Lending LLC d/b/a Figure, Figure Markets Holding, LLC, Figure Markets, Inc., Figure Markets Credit LLC, Figure Payments Corporation d/b/a Figure Pay, Figure Equity Solutions, Inc., Figure Markets Cayman Islands Ltd., and Figure Securities, Inc.) (collectively, “Figure,” “we,” “our,” or “us”) collects, uses, shares, retains, and destroys your Biometric Data when you use www.figure.com website or any related website or mobile application (the “Site”). “Biometric Data” includes: (i) “Biometric Identifiers,” which are data generated by measurements of your biological characteristics, such as your retina or iris scan, fingerprint, voiceprint, or a scan of your hand or face geometry; and (ii) “Biometric Information,” which is information based on a Biometric Identifier that can be used to identify you.

Please review this notice carefully. By agreeing to our collection of your Biometric Data, you consent to the collection, use, sharing, and retention of your Biometric Data as described in this notice.

What type of Biometric Data do we collect?

  • Face geometry

How do we collect it?

  • We extract your face geometry from the government-issued identification documents and selfies that you provide to us when you create certain accounts.

How do we use and share it?

  • We may use Biometric Information for purposes that include verifying or authenticating your identity, detecting and preventing fraud and safety or other security purposes.

How long do we retain your Biometric Data?

  • We will only retain Biometric Information until the initial purpose for collecting it has been satisfied or within three years of the individual's last interaction with Figure, whichever occurs first, unless legally required to keep it for a different period.

What happens to your Biometric Data at the end of the retention period?

  • Biometric information will be deleted from all systems unless prohibited by law such as court order.

Additional Privacy Disclosures and Your Rights

For Illinois and Texas residents, pursuant to the Illinois Biometric Information Privacy Act and Texas Capture or Use of Biometric Identifier Act respectively, Figure obtains affirmative consent before capturing or storing biometric information. Biometric information is not sold or shared with third-parties for commercial purposes. Biometric information is used for verifying your identity, detecting and preventing fraud, and security purposes.

For more information about how we collect, use, and share your personal information, as well as your rights and choices concerning our data practices, please review our Privacy Policy available at https://www.figure.com/privacy/.