Figure Logo

Last Revised: March 18, 2024

California Employee and Prospective Employee Privacy Notice

The California Consumer Privacy Act of 2018 (“CCPA”) imposes specific obligations on businesses processing personal information of California residents. Pursuant to the CCPA, Figure Technology Solutions, Inc., together with its affiliates or subsidiaries (collectively, “Figure”, “we” or “us”) are required to provide its employees who are California residents (“California Persons”) a notice, used at or before the point of collection of such personal information, that identifies the categories of personal information that may be collected and why Figure collects such information.

This California Employee and Prospective Employee Privacy Notice (“Notice”) is intended to provide HR Covered Individuals with the information required by the CCPA. “HR Covered Individuals” (also referred to as “you”) are California residents who are any of the following: (1) prospective, current, or former employees, applicants for employment, owners, directors, officers, or contractors, service providers, or similar personnel of Figure; (2) emergency contacts of Figure personnel; and (3) individuals related to Figure personnel for whom Figure administers benefits. This Notice only applies to HR Covered Individuals.


This Notice will be updated at least once every twelve (12) months to reflect changes in our business and legal or regulatory obligations, so please check this Notice periodically for changes by visiting Figure will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify you by email before such changes are effective at the email address you have provided to us.


“Personal Information” has the meaning as defined in the CCPA, and includes information that is collected by Figure about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

“Process”, “processed”, “processing” means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

“Employees”, “employee” or “you” means an identified or identifiable natural person who is a California resident and who is acting as a Figure job applicant, employee, or contractor. In this context “job applicant” refers to any person who has submitted his or her candidacy for employment with Figure; “employee” refers to any person who is employed at Figure as a full-or part-time employee or temporary worker, and “contractor” means a natural person who provides and service to a business pursuant to a written contract.

Personal Information We Collect About You

Listed below are the categories of personal information that Figure may process about employees:

  1. Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technologies; unique pseudonym, or user alias, telephone numbers, or other forms of persistent or probabilistic identifiers.

  2. Characteristics of Protected Classifications under California or Federal Law, including the following: race, skin color, national origin, religion (including religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition(s) (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and age.

  3. Personal Information Described in Cal. Civ. Code § 11798.80(e): Personal information, as defined in the California safeguards law, such as signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information.

  4. Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an employee’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, application or physical access to a Figure office location or workspace.

  5. Professional or Employment-related information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; and employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint(s), face, and voice recording; information form employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured form video, audio, systems or other forms of monitoring or surveillance.

  6. Education Information, including information about an employee’s educational background, such as education records, report cards, and transcripts that are not publicly available.

  7. Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  8. Sensitive Personal Information: Personal information that reveals a HR Covered Individual’s: Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in connection with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic group, religious or philosophical beliefs, or union membership; contents of mail, email and text messages unless we are the intended recipient of the communication; and genetic data. Sensitive Personal Information also includes biometric information processed for the purpose of uniquely identifying a HR Covered Individual, as well as personal information collected and analyzed concerning a HR Covered Individual’s health, sex life, or sexual orientation. Figure only collects and processes personal information that is considered to be sensitive personal information under the CCPA for the purposes set forth in Section 5.

Categories of Sources from Which Personal Information is Collected

During the 12-month period prior to the “Last Revised” date of this Notice, Figure may have obtained personal information about HR Covered Individuals from the following categories of sources:

  • Directly from HR Covered Individuals;
  • HR Covered Individuals’ work devices;
  • Family or friends who provide information about HR Covered Individuals, for example, in connection with our provision of benefits or services;
  • Our affiliates and subsidiaries;
  • Service providers, contractors and other vendors who provide services on our behalf;
  • Survey research or business partners who provide information about HR Covered Individuals, such as when they provide feedback;
  • Internet service providers (“ISPs”);
  • Operating systems and platforms;
  • Government entities; and
  • Data brokers, such as credit bureaus, credit reporting service providers, and background check services.

Purposes for Collecting Your Personal Information

Figure collects the personal information identified in the “Personal Information We Collect About You” section above for the reasons listed below.

  1. To Recruit Employees, including to conduct employment-related background screening and checks.

  2. To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

  3. To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related to payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.

  4. To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff restructuring

  5. To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of any employee’s work related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

  6. To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

  7. To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements.

  8. To Maintain Your Contact Information, including altering your details across relevant entities within Figure its affiliates and subsidiaries (for example personal, other employment and transferring roles).

  9. To Assist You In Case of Emergency, including maintenance of contact details for you, and your dependents in case of personal or business emergency.

  10. To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S.

  11. To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.

  12. To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.

  13. To Ensure a Safe and Efficient Working Environment, which includes Figure actions relating to disciplinary actions and code of conduct processes and investigations.

  14. To Maintain Security on Figure Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Figure’s software and hardware computer assets; systems testing such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

  15. To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal reporting obligations, including headcount, management information, demographic and Health, Safety, Security, and Environmental (HSSE) reporting.

  16. Employee Data Request vs. Consumer Data Request, if a Figure Employee chooses to use a Figure product, for example, a HELOC, and submits a data request, that request will be treated as a consumer data request. For example, if Sarah Smith submits an Employee Data request, Figure will only provide employee data that is collected under the purpose of employment. If, as an employee of Figure, Sarah Smith also has a HELOC with Figure, she would have to submit a consumer data privacy request and not an employee data privacy request.

Retention of Personal Information

We retain personal information about HR Covered Individuals for the time period reasonably necessary to achieve the purposes described in this Notice, or any other notice provided at the time of collection, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.

HR Covered Individual Privacy Rights

You have certain rights regarding your personal information, as described below. We may decline to grant access to, delete, or correct your personal information as permitted by applicable law, for example, if we are required to retain the information we have collected from you or retaining the information is necessary for us to, for example, detect or investigate security incidents.

  • Know and Access: You have the right to request that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you. We do not have to provide this information to you more than twice in any 12-month period.
  • Correct: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
  • Delete: You have the right to request that we delete certain personal information we have collected from you.
  • Non-Discrimination: You are entitled to protection against illegal discrimination when asserting your rights under the CCPA.

How to Submit a Request

You may exercise your rights by submitting a request to know and access, correct, or delete your Personal Information by contacting your HR Business Partner or emailing

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to sign into your Figure HR Management account. If you do not have a profile within Figure HR Management account and you request access to, or correction or deletion of, your personal information, we may require you to provide your email address and information about your employment dates with Figure, communication with Figure, or other details about your work for, or relationship to Figure. In addition, if you do not have a profile within a Figure HR Management account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the HR Covered Individual whose personal information is the subject of the request.

Contacting Us

If you have any questions, you can contact us at 888-819-6388 or