Last Revised: January 10, 2020
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.
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.
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.
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 Information||Examples|
|Address and other identifiers||Name, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers|
|Characteristics of protected classifications||Age, gender, and marital status|
|Unique and online identifiers||IP address, device IDs, browsing history, search history, and information on consumer’s interaction with a website|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Internet or other electronic network activity information||Browsing 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 information||Service calls, video recording of notary session, voicemails and other audio recordings, photographs|
|Professional or Employment Information||Employer, years of employment|
|Educational Information||School 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.
In the past 12 months, we may have collected and used Personal Data for the following purposes:
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.
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.
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.
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.
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