Last Revised: January 10, 2020

Privacy Policy

Welcome to the website (“Site”) of Figure Technologies, Inc. and its affiliates and subsidiaries (“Figure,” “we,” “our,” or “us”). Figure offers a simple and transparent process that enables you to use your home equity to consolidate debt, pay for home improvements, or fund your life. It also provides products that help you refinance your student debt and other tools to help achieve your financial goals. This Privacy Policy explains what personal and other data we collect through the Site, our mobile application (“App”), email, e-notary service, call center, other interactions with us, and through third-party data providers (collectively the “Services”), how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms of Service, which are available at: https://figure.com/terms/.. By providing us with your personal data when using the Services you agree to the data practices described in this Privacy Policy. If you do not agree to these practices, please do not access or use the Services. Before you submit any Personal Data (as defined below) to Figure through the Services, please review this Privacy Policy carefully, and contact us if you have any questions. For details on sharing your Personal Data, see “Sharing and Disclosure” section below. Please also review the Gramm-Leach-Bliley Act Privacy Notice here, which applies to individuals who obtain financial products or services from us, including those who apply for one of our products or services.

Information We Collect

Personal Data You Voluntarily Provide Us

Personal Data. When you interact with our Services, apply for a financial product, contact us with inquiries or create an account to access the Services, we collect information you voluntarily give us that alone or in combination with other information could be used to identify you (e.g., your name, email address, social security number, date of birth, bank account and routing numbers, credit report data). For purposes of this Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records. Other Information. In order to help us determine if you qualify for financial products or services, we may obtain credit reports from consumer credit reporting agencies. If required by law, we will provide notice and/or obtain your consent to do so. When you voluntarily provide it to us, we may also use the information you use to login to your accounts with your financial institutions (such as the username and password you use to access your bank’s website) so we can evaluate your transaction history to identify financial products and services that might interest you and evaluate your eligibility for our products and services. Job Applicants and Employees. In connection with an application to work at Figure, a Figure company or as part of your employment at Figure or other recruitment and personal management functions, we may collect your personal information permissible for collection under applicable law.

Information We Receive Automatically from Your Use of the Site and App

When you visit, use, and interact with the Site or App, we may receive certain information about your visit, use or interactions with the Site or App. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation patterns.

Information We Receive from Third Parties

We may also collect personal data from third parties, such as parties that interact with us, including other financial institutions, product sponsors, business partners and contacts, service providers, background check companies, recruiters or referral sources, subscription information or analytic services, public sources, government records and sources, and other parties that interact with us or store information on our systems.

Types of Personal Data We Collect

In particular, in the past 12 months, we may collected and disclosed the following categories of personal data for business purposes to our third-party service providers, our affiliates and business partners, and regulators/government agencies. We may also continue to collect these categories of Personal Data.

Categories of InformationExamples
Address and other identifiersName, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Characteristics of protected classificationsAge, gender, and marital status
Unique and online identifiersIP address, device IDs, browsing history, search history, and information on consumer’s interaction with a website
Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric InformationFingerprints
Internet or other electronic network activity informationBrowsing history, search history, settings, and information regarding an individual’s interaction with an internet website, application, or advertisement, device information, including name of device and operating system, cookies and pixel tags, city of login, and other data that your browser automatically sends
Audio or video footage or other visual informationService calls, video recording of notary session, voicemails and other audio recordings, photographs
Professional or Employment InformationEmployer, years of employment
Educational InformationSchool attended, level of educational attainment, schools attended

The table includes examples in each category but these examples are not exclusive and may not be applicable to job applicants or employees. In addition, we may draw inferences about you based on the information you provide, such as individual preferences or characteristics, and we may collect and use information as described to you when collecting the information. We may also receive Personal Data that individuals provide to us or store on our systems.

Cookies and Marketing

Cookies. In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. In order to personalize your use of the Site, we use local shared objects, also known as Flash cookies, to display content based upon what you view. Flash cookies are different from browser cookies (discussed above) because of the amount and type of information they generate, and how they store that information. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here. When you visit the Site or view one of our emails, we will use pixel tags or “clear” gifs to track links and/or similar technology to note some of the pages you visit on our Site and to personalize your experience. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message. Analytics and Tracking Technologies. We may, and we may allow third party service providers, to use cookies (as noted above) or other tracking technologies (e.g., Google Analytics), to help us understand your use of our Site and collect information about your browsing activities over time and across different websites. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners. Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies. Marketing. We may use Personal Data to contact you (e.g., by phone or email) in the future to tell you about products or services we believe may be of interest to you. Our email and text marketing communications will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications, or you wish to have your name deleted from our mailing lists, please contact us as indicated below. We use web beacons to tell when a user is redirected to the Site because of an advertisement that we ran was clicked on or otherwise interacted with and to better target our advertisements (known as “retargeting”). Our service providers may track Site visitors across multiple websites and social media services to retarget Site visitors. Users logged in to social media programs may be tracked by service providers who track such users across multiple websites and who may disregard the privacy settings in your web browsers.

How We Use Personal Data

In the past 12 months, we may have collected and used Personal Data for the following purposes:

  • To provide you with the Services and related customer service, including communicating with you as necessary in connection with your application for and servicing of financial products and services and sending you administrative and other information, for example, information regarding our terms, conditions, and policies and information that may be of interest to you;
  • To market our products and services to you;
  • To respond to your inquiries, comments, feedback, or questions;
  • To provide, maintain and improve the content and functionality of the Services, including by analyzing how users interact with our Services;
  • To prevent fraud, criminal activity, or misuses of our Services and to ensure the security of our IT systems, architecture and networks;
  • To conduct business operations, including processing payments, auditing consumer transactions, and research, analytics and development;
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties;
  • To conduct and publish market research, e.g., consumer surveys, polls, statistics, etc;
  • To publish user-generated content for use on our Site, social media, or other marketing platforms.
  • To conduct recruitment and other personnel management functions.

We may also continue to collect and use Personal Data for these purposes. We do not sell personal information and, in the preceding 12 months, we have not sold any personal information to any other entity.

Aggregated Data

We may aggregate the information that we collect and use such aggregated data for commercial, statistical, and market research purposes, including sharing it with affiliates, third parties and business partners. This data may include location information derived from your IP address or mobile device.

How We Share Personal Data

We do not share your Personal Data outside of Figure except in the following circumstances: Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy, or similar event, Personal Data may be part of the transferred assets and may otherwise be shared with business partners and non-affiliates for the purposes of carrying out transactions. Affiliates, Non-Affiliates and Business Partners. We may also share your Personal Data with our affiliates, non-affiliates and our business partners for business purposes, including the processing of consumer transactions. Agents, Consultants, Vendors, and Service Providers. Like many businesses, we sometime hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. Legal Requirements. We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability.

Information Access and Choice

You can contact us at 888-819-6388.  Opens a new window. or privacy@figure.com.  Opens a new window. to do the following at any time:

  • See what data you provided through the Services, if any.
  • Change/correct any data you provided through the Services.
  • Express any concern you have about our use of your data.
  • Request we delete your data.

California Privacy Rights and Disclosures

California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. As noted above, we do not provide Personal Data to third parties for their direct marketing purposes. Residents of California may have rights under the California Consumer Privacy Act (“CCPA”) as described in this section of our Privacy Policy. We note, however, that much of the Personal Data that we collect is exempt from the following provisions of the CCPA, which do not apply to Personal Data collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act. The CCPA also includes certain exceptions related to certain information in a business-to-business context and information collected about employees, job applicants, and contractors. You can review our Gramm- Leach-Bliley Act Privacy Notice for more information on how we share information here. Access Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request access to certain information about the Personal Data we collect about you. In particular, these individuals have a right to request that we provide the following information:

  • The categories of Personal Data that Figure has collected about you.
  • The categories of sources from which Figure collected the Personal Data.
  • The business or commercial purposes for which Figure collected and/or sold the Personal Data.
  • The categories of any third parties with which Figure shared the Personal Data.
  • The specific pieces of Personal Data Figure collected over the past year.
  • The categories of Personal Data, if any, Figure has sold about you, categories of third parties to which Figure sold that Personal Data, and the categories of Personal Data sold to each type of third party.
  • The categories of Personal Data that we have disclosed for a business purpose.

Our responses to such requests will cover the 12-month period preceding our receipt of the request. To request access to this information, you may contact Figure at 888-819-6388 or email us your request via privacy@figure.com. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with Figure. You may also designate an agent to submit a request on your behalf. We will likewise need to verify the agent. Deletion Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request that we delete certain personal information from our records, subject to certain exceptions. We are not required to delete information that is necessary for us to: complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract Figure entered into with you; detect security incidents; maintain the functionality or security of Figure’s systems; comply with or exercise rights provided by the law; or use the information internally in ways that are comparable with the context in which you provided the information to Figure or that are reasonably aligned with expectations based on your relationship with Figure, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies. To submit a deletion request, you may contact Figure at 888-819-6388 email us your request via privacy@figure.com.  Opens a new window. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with Figure. We will respond to requests for access or deletion as soon as practicable and in any event generally not more than within 45 days after receipt of your request. We may extend this period to 90 days in some cases. Household Information: There may be some types of Personal Data that can be associated with a household (a group of people living together in a single home). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. Non-Discrimination: If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than other consumers. Accessibility: We are committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this policy in alternative formats by contacting us at the address, phone, or email address below. This website is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us by either:,

Do Not Track Signals

Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Children

The services are not directed to children under the age of 16 and we do not knowingly collect or sell the Personal Information of children under 16. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy. If you believe we have collected information from a child who is under 13 please contact us and we will endeavor to delete the information.

Links to Other Websites

This Privacy Policy only applies to information collected by Figure through our Services. Our Services may contain links to other web sites, apps or online services not operated or controlled by Figure (“Third Party Sites”). The policies and procedures described here do not apply to Third Party Sites. By providing links to Third Party Sites or services we do not imply that we endorse or have reviewed such websites or services. We suggest that you contact those sites directly for information about their data practices and policies.

Security

You use the Services at your own risk. We use reasonable precautions, including technical and administrative measures, to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us in connection with the Services may not be secure. Therefore, you should take special care in deciding what information you send to us.

International Transfers of Data

Because we are based in the United States, if you use our Site or Services from outside the United States your information will be transferred to the United States. By using our Site, products and services, you consent to the collection, international transfer, storage and processing of your information. If it is illegal to access our Site or transfer your data to the United States, please do not use our Sites

Changes to This Privacy Policy

We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we make material changes to this Privacy Policy, we will post notice that the Policy has been updated in the “Last Revised” section of the Policy. For material retroactive changes, we will notify you consistent with the law. Further use of the Website following any such changes constitutes your agreement to follow and to be bound by the amended Privacy Policy, so we encourage you to check for updates.

Contacting Us

If you have any questions, you can contact us at 888-819-6388.  Opens a new window. or privacy@figure.com  Opens a new window..