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Effective Date: April 22, 2024

General Workforce Privacy Notice

Welcome to the General Workforce Privacy Notice of Figure Technology Solutions, Inc. and its affiliates or subsidiaries (“Figure”, “we” or “us”). This notice informs all our employees, prospective employees, and contractors across the United States about our practices concerning the collection, use, and protection of personal information. If you are a resident of California, please refer to the supplemental California Workforce Privacy Notice for specific provisions applicable to you.

  1. Applicability

This Notice applies to “HR Covered Individuals” (also referred to as “you”), which includes 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 whom Figure administers benefits.

  1. Updates

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.

  1. Definitions

       3.1 "Personal Information" 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.

       3.2 “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.

       3.3 “Employees”, “employee” or “you” means an identified or identifiable natural person 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.

  1. Personal Information We Collect About You

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

       4.1 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 (IP) address; cookies, beacons, pixel tags, or similar technologies; unique pseudonym, or user alias, telephone numbers, or other forms of persistent or probabilistic identifiers.

       4.2 Characteristics of Protected Classifications 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.

       4.3 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.

       4.4 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.

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

       4.6 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.

       4.7 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.

  1. Categories of Sources from Which Personal Information is Collected

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

  • Directly from you, via job applications and during the course of your employment.
  • Indirectly from you, through monitoring your activities as part of standard IT security and network management practices.
  • From third parties, such as background check providers, benefits providers, and other services related to employment.
  1. Purposes for Collecting Your Personal Information

We collect personal information for purposes such as recruiting employees, administering benefits, managing payroll and expenses, conducting performance reviews, monitoring work-related licenses and credentials, providing human resources management services, administering international travel or assignments, maintaining contact information, assisting in emergencies, ensuring eligibility to working in the United States, conducting healthcare-related services, facilitating a better working environment, and maintaining security on our systems and internet-connected assets.

  1. Retention of Personal Information

We retain personal information for the time period reasonably necessary to achieve the purposes described in this Notice, unless a longer retention period is required or permitted by applicable law.

  1. HR Covered Individual Privacy Rights

At Figure, we prioritize transparency and ethical handling of personal information for all our employees, prospective employees, and contractors across the United States. We extend these privacy rights voluntarily:

  • Right to Know and Access: You may request details on the personal information we collect, use, disclose, and if applicable, sell or share about you, up to twice per year.
  • Right to Correct: You can request corrections to any inaccurate personal information we hold about you.
  • Right to Delete: You may ask us to delete your personal information, except where we need to retain it for legal compliance or business necessities.
  • Right to Non-Discrimination: Exercising these rights will not affect your employment conditions, benefits, or other services provided by us.

How to Submit a Request: Please submit your request via our online Data Privacy Portal  Opens in a new window.. Include your name, contact information, and details of your request. We aim to respond within 14 days of verifying your identity.

Verifying Requests: To protect your privacy and maintain security, we will verify your identity before processing any requests. If you are an active employee, this may involve singing into your Figure HR Management account. Former employees, contractors, or those without an account may need to provide additional documentation such as email address, employment dates, or other relevant information. In certain cases, a declaration under penalty of perjury may be required.

  1. Additional Information for California Residents

California residents are encouraged to consult our California Workforce Privacy Notice for additional rights under state law.

  1. Additional Information

If you have any questions about this statement please contact,  Opens in a new window..