Last Revised: March 18, 2024

Privacy Policy

Figure Technology Solutions, Inc., together with its affiliates and subsidiaries (including Figure Lending LLC dba Figure) (collectively, “Figure,” “we,” “our,” or “us”) provides products and services that enable you to use your home equity to consolidate debt, pay for home improvements, fund your life, and achieve your financial goals.

Capitalized terms used in the Privacy Policy and not otherwise defined have the meanings given to them in the General Terms of Service.

This Privacy Policy explains what personal data we collect through the Site, our mobile applications (“Apps”), 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 for limited business purposes, and your choices concerning our data practices. We want to be clear that we do not sell your Personal Data to any other entities. Beyond the Privacy Policy, your use of our Services is also subject to our General Terms of Service, which are available at www.figure.com/terms.

By using our 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.

Please also review the Gramm-Leach-Bliley Act Privacy Notice for Figure Technology Solutions, Inc., and its subsidiaries (including Figure Lending LLC). This notice 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, if you are using one of our products or services that collect biometric information or identifiers.

Information We Collect

Personal Data You Voluntarily Provide Us

For purposes of this Policy, “Personal Data” refers to 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.

Upon interacting with our Services, applying for a financial product, contacting us with inquiries or creating an account to access the Services, we collect information you voluntarily provide 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).

Provided voluntarily, we may also utilize your financial institution login information (such as the username and password you use to access your bank’s website) to evaluate your transaction history for identifying financial products and services that might interest you, and to evaluate your eligibility for our products and services.

With your consent, we may access the contacts on your device, collecting and storing names and contact information from your address book to facilitate invitations and transactions that you initiate through our Services, and for other purposes described in this Privacy Policy or at the time of consent or collection. Please refer to the “Your Choices” section below for information on how you can disable the sharing of your contacts with us.

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. Please review our California Employee and Prospective Employee Privacy Notice.

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 document certain information about your visit, use or interactions with the Site or Apps. For instance, 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, Internet Explorer, etc.), broad geographical information, and Site-navigation patterns.

With your consent, we may also collect your precise location information when you use our Services. Please refer to 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

To assist in determining your qualification 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 for limited business purposes, such as financial institutions, product sponsors, business partners, service providers, background check companies, recruiters or referral sources, subscription information or analytic services, public sources, government records and sources, and others. However, we do not sell your Personal Data to any entity. This data helps us evaluate eligibility for products and services, enhance user experience, and fulfill legal and compliance obligations.

Types of Personal Data We Collect

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

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
Biometric Information	Face Geometry
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

The table includes examples in each category but these examples are not exclusive and may not be applicable to all job applicants or employees. Additionally, 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

In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer hosting our Services sends to your browser when you access the Services. Our cookies help enhance the functionality of the Services, and aid in our analysis of Services usage. For instance, our Site may place a cookie on your browser to enable access to the Services without repeatedly entering a password during your visit to the Site.

We are committed to respecting your privacy choices and handling your data responsibly. As part of this commitment, we provide a Cookie Consent Management tool, to ensure your control over your personal data, ensuring that your cookie preferences are respected and managed efficiently.

Upon your first visit to our Site, you will encounter a clear and user-friendly consent interface. This interface allows you to:

View Detailed Information: Understand the types of cookies used, their purpose, and the data they collect.
Customize Your Preferences: Freely choose which cookies you wish to accept or reject, including options to opt-in or opt-out of different cookie categories such as functional, analytical, and advertising cookies.
Consent Logging: Your consent decisions are logged and stored securely, ensuring compliance with data protection regulations and providing a record of your preferences.
Easy Access to Modify Choices: You can revisit and alter your cookie preferences at any time by clicking “Your Privacy Options” at the footer of our website.

Most web browsers have a “help” section on the toolbar detailing how to manage new cookies and disable them if desired. However, we recommend keeping cookies enabled to utilize the full range of features offered by our Service. Note that disabling cookies may limit your experience and the functionality available on our Site.

In addition to cookies, we employ pixel tags or “clear” gifs in our emails and on our Site. These are used to track links and similar technologies to monitor the pages you visit on our Site and personalize your experience. Pixel tags are similar to cookies but are used in online content or email bodies to track website activity or when specific content or emails are viewed.

We assure you that the information collected through cookies or pixel tags is not sold. It may be shared for limited business purposes as detailed in our Privacy Policy. Our Cookie Consent Management tool underscores our commitment to your data privacy, offering transparency and control over how your data is handled.

Analytics and Tracking Technologies

We and our third-party service providers, such as our advertising and analytics partners (e.g., Google Analytics), may use cookies or other tracking technologies, to understand your use of our Services and to collect information about your browsing activities over time and across different websites, apps, and online services for advertising purposes. 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.) We also 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”). All information collected through analytics and tracking technologies is used for limited business purposes and not sold to any third parties.

How We Use Personal Data

We may use the Personal Data we collect for the following purposes, while ensuring that we do not sell your Personal Data to any entity but share it only for limited and specified business 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, solely to enhance our services and better cater to your needs;
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, ensuring a seamless integration while safeguarding your data;
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, ensuring your privacy preferences are honored;.
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 line with our commitment to safeguarding your privacy, in the past 12 months, we have not sold any personal information to any other entity. Our practices are designed to ensure the prudent and legitimate sharing of Personal Data for business purposes as outlined above.

Aggregated Data

We may aggregate the information that we collect, and utilize such aggregated data for commercial, statistical, and market research purposes, including sharing it with affiliates, third parties and business partners for limited business purposes. This data may include location information derived from your IP address or mobile device. It’s important to clarify that we do not sell any of your personal information, but rather, share aggregated data to enhance our services and your experience.

We may share your Personal Data outside of Figure in the following circumstances for limited business purposes:

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. We do not sell your Personal Data in these instances.

Third Party Partners. We may also share your Personal Data with third party partners for business-related purposes. 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 vendors to show you Figure ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). 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.

Your Choices

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. Opting out of promotional messages will not affect sharing of your information for other limited business purposes as outlined in this policy.

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

California residents may have rights under the California Consumer Privacy Act (“CCPA”) as described in our California Consumer Privacy Act Disclosure. Figure’s privacy policy, terms of service, and Gramm-Leach-Bliley Act Privacy Notice should be read in conjunction with the California Consumer Privacy Act Disclosure.

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 and we encourage you to read their privacy policies before providing any information to them.

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

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.

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, and the revised version will be effective when it is posted. For material retroactive changes, we will notify you consistent with the law. Further use of the Services 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 or privacy@figure.com.