LAST REVISED: MAY 21, 2021
Please also review the Figure Lending Gramm-Leach-Bliley Act Privacy Notice here Opens a new window., and, if you are a user of Figure Pay, the Figure Pay Gramm-Leach-Bliley Act Privacy Notice here Opens a new window., which is available in your Figure Pay Application which applies to individuals who obtain financial products or services from us, including those who apply for one of our products or services.
Please also review our Biometric Privacy Notice here, if you are using one of our products or services that collect biometric information or identifiers, such as Figure Pay.
Information We Collect
Personal Data You Voluntarily Provide Us
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.
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, address, email address, phone number, social security number, taxpayer identification number, date of birth, copies of your government-issued identification documents, biometric information or identifiers, income information, bank account and routing numbers, or transaction information).
When you voluntarily provide it to us, we may also use your financial institution login information (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.
In connection with an application to work at Figure, a Figure company or as part of your employment at Figure or other recruitment and personnel 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 Apps
When you visit, use, and interact with the Site or Apps, we automatically collect certain technical information about the device and software you use to access the Site or Apps, such as your IP address, operating system version, phone carrier and manufacturer, device identifiers, and push notification tokens. We may also receive certain information about your visit, use or interactions with the Site or Apps. For example, we may monitor the number of people that visit our Site or Apps, peak hours of visits, which page(s) are visited on our Site or Apps, 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.
With your permission, we may also collect your precise location information when you use our Services. Please see the “Your Choices” section below for information about how you can prevent your device from sharing precise location information with us.
Information We Receive from Third Parties
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.
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 the past 12 months, we may have 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.
Cookies and Other Tracking Technologies
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 may allow you to take advantage of some of the Service features. 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.
How We Use Personal Data
We may use the Personal Data we collect 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 facilitate transactions and payments;
- To verify and authenticate your identity and account information;
- To determine whether you qualify for financial products and services;
- For advertising and marketing purposes;
- To personalize your experience on our Services, such as by providing tailored content and recommendations;
- 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 detect, prevent, and address 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 facilitate the connection of third- party services or applications to the Services;
- To send you text messages and push notifications;
- To facilitate invitations that you initiate through our Services;
- To publish user-generated content for use on our Site, social media, or other marketing platforms.
- To conduct recruitment and other personnel management functions and
- For other purposes for which we provide specific notice at the time the information is collected.
In the past 12 months, we may have used the Personal Data we’ve collected for these purposes, depending on the Figure product or service you use.
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.
How We Share Personal Data
We may share your Personal Data outside of Figure 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 service providers, advisors, potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of such transactions.
Third Party Partners. We may also share your Personal Data with third party partners. For example, we may share Personal Data and financial information with our bank partners to process ACH transactions and for other purposes, such as fraud prevention and compliance. We may also share information with our merchant customers to facilitate transactions and payments, and we may share aggregated information with prospective customers and merchant customers for purposes such as customer outreach and relationship management. We may also share Personal Data and financial information with third party partners in connection with Figure Pay to process rewards for qualifying transactions or enable access to automated teller machines (“ATMs”).
Agents, Consultants, Vendors, and Service Providers. We may share any information we collect with agents, consultants, vendors, and service providers to perform services for us. Examples of such services include mailing information, maintaining databases, processing payments, verifying your identity, and detecting and preventing fraud on our Services.
Credit Reporting Agencies. If you apply for financial products or services through the Services, we may share your Personal Data (such as your name, address, date of birth, and social security number) with credit reporting agencies so we can determine whether you qualify for such products or services. If you open an account with us, we may also report your account balances and payment history to credit reporting agencies.
Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) Opens a new window. or the Digital Advertising Alliance (https://optout.aboutads.info) Opens a new window.. If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
Legal Requirements. We may also access, preserve, and disclose your Personal Data if we believe doing so is necessary, required, or appropriate to (i) comply with a legal obligation or law enforcement request, (ii) protect and defend your, our, or others’ rights, property, or safety, (iii) prevent fraud, (iv) protect against legal liability, or (v) respond to your requests.
Consent. We may also disclose your Personal Data with your permission.
If you use Figure products, such as Figure Pay, Adnales and Marketplace, some information is publicly available information and may be seen by other users of the Provenance blockchain. Publicly available information includes your blockchain address(es), the time and date your transactions finalized on the Provenance blockchain, the amounts of the transactions, and the other blockchain address(es) that are parties to any transactions you have made on the blockchain.
Marketing Communications. 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. Please note that, even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Your Contacts. You may enable or disable the sharing of contacts information by updating your app settings or your device’s operating system settings.
Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings. Please note that if you prevent your device from sharing this information with us, some features of our Services may not work as intended or otherwise be available to you.
California Privacy Rights
Do Not Track Signals
Links to Other Websites
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
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from outside the United States, please note that your information will be transferred to the United States for storage and processing. We may also transfer your information from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By using our Services, you consent to the collection, international transfer, storage and processing of your information.
Update Your Information
You may be able to update some of your account information through your App settings.