California Privacy Statement

Last Revision Date: June 28, 2023

Your privacy is important to us. This California Privacy Statement explains how Fig collects, uses, and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). This “Statement” constitutes our notice at collection and our privacy policy pursuant to the CCPA.

Applicability

The CCPA does not apply to certain personal information, such as:

Personal information covered under certain federal or state financial privacy laws, including but not limited to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and the California Financial Information Privacy Act.
Publicly available information from government records.

The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA varies based on the relationship between Fig and the individual. To learn more about how we collect, disclose and secure information for these customers, please see our GLBA Financial Privacy Notice and Privacy Policy.

Securing Personal Information

Fig is committed to keeping Personal Information secure. In addition to meeting our obligations under applicable laws and regulations, we have implemented physical, technical, electronic, procedural and organizational safeguards and security measures to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access.

Collection, Use and Disclosure of Personal Information

In the past 12 months, we have collected and disclosed for our business purposes each of the following categories of Personal Information relating to California residents covered by this Notice:

Identifiers.This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)).This category is similar to Identifiers and includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Internet or other similar network activity.This may include browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement, such as your clicks and how long you are using our website.

In the past 12 months, we have collected and disclosed for our business purposes each of the following categories of Sensitive Personal Information relating to California residents covered by this Notice:

Personal Information that reveals:
A California resident's Social Security, driver's license, state identification card, or passport number; and,
A California resident's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

In the past 12 months, we have collected Personal Information from the following categories of sources:

Directly from you or your authorized agents. For example, from forms you complete on your application or through information you provide us during the life of your loan.
Indirectly from you. For example, from observing your actions on our website (www.figloans.com)
From third-parties that interact with us in connection with the origination or servicing of your loan. For example, from credit bureaus, affiliates, or other companies.

We may disclose your Personal Information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed your personal information to the following third parties:

Vendors and service providers who provide services such as banking and communication infrastructure, operating systems and platforms, website hosting, storage, legal expertise, tax expertise, information technology, data analytics, customer service.
Partners and third-party service providers who provide services such as payments, advertisements, services and products.
Government agencies as required by law.

We collect, use and disclose for our business purposes Personal Information, including Sensitive Personal Information, relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business or commercial purposes, including the following:

Account Services including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on our service provider’s behalf.
Security and Fraud Detection including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Debugging including identifying and correcting errors to our system and services.
Improvement of Products and Services such as enhancing the quality of our products and services.
Internal Research including technological development and demonstration.
Advertising and Marketing Services including advertising or marketing services on our own behalf or on behalf of our affiliates.
To Comply with our Legal Obligations
Audits including reviewing current interactions with you and related transactions.
For Other Business or Commercial Purposes as permitted by law.

How Long We Retain Personal Information

The length of time that we intend to retain each category of Personal Information will depend on a number of criteria, such as the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements; the length of time we may need to accomplish the business purpose(s) for which such Personal Information is collected, used or disclosed (as indicated in this Notice), and whether you exercise your rights under the CCPA (subject to certain exceptions) to request that your Personal Information is deleted.

Sale or Sharing of Personal Information

For purposes of this Notice:

“sold” means the disclosure of Personal Information or Sensitive Personal Information to a third party for monetary or other valuable consideration; and
“shared” means the disclosure of Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising.

In the 12 months preceding the date of this Notice, we “shared” Personal Information for cross-context behavioral advertising, with respect to California residents covered by CCPA to deliver advertising and marketing. Fig “shared” Personal Information with our third party advertising and marketing vendors who were prohibited from using that Personal Information for any purpose other than to provide the specifically requested advertising and marketing services.

The categories of Personal Information that we “shared” for cross-context behavioral advertising in the 12 months preceding the date of this Notice are:

Identifiers.This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)).This category is similar to Identifiers and includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Internet or other similar network activity.This may include browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement, such as your clicks and how long you are using our website.

Fig does not sell personal information. Also, it is our business practice not to sell Personal Information of minors under 16 years of age and we have no actual knowledge of doing so.

You can opt-out of sharing your information by clicking here

How We Use Sensitive Personal Information

We only use or disclose Sensitive Personal Information for the following purposes consistent with CCPA Regulations:

Account Services including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on our service provider’s behalf.
Security and Fraud Detection including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Debugging including identifying and correcting errors to our system and services.
Improvement of Products and Services such as enhancing the quality of our products and services.
Internal Research including technological development and demonstration.
To Comply with our Legal Obligations
Audits including reviewing current interactions with you and related transactions.
For Other Business or Commercial Purposes as permitted by law.

Rights under the CCPA

If you are a California resident covered by the CCPA, you have the right to:

Receive this Notice at or before the point of collection of your Personal Information.
Request we disclose to you free of charge the following information covering the 12 months preceding your request:
the categories of Personal Information about you that we collected;
the categories of sources from which the Personal Information was collected
the purpose for collecting Personal Information about you;
the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that were disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
the specific pieces of Personal Information we collected about you;
Request we correct inaccurate Personal Information that we maintain about you.
Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception.
Be free from unlawful discrimination for exercising your rights under the CCPA.

Please see the section below entitled, “How to Exercise Your Rights,” for instructions explaining how you can exercise these rights described above.

For individuals submitting a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom the request is made.

For a company or organization submitting a request on behalf of another person, we may require proof of authorization from the individual such as a Power of Attorney and verification of identity directly from the person for whom the request is made.

In some instances, we may not be able to honor your request. This may occur if we cannot verify your identity or verify that you have permission to make the request on behalf of another individual; or the information is exempt from deletion under the Gramm-Leach-Bliley Act or the CCPA.

Global Privacy Controls

We will recognize global privacy controls as a valid privacy request.

How to Exercise Your Rights

You can opt-out of sharing your information by clicking here

If you are a California resident, you may submit a request to know, delete or correct by:

Completing this online form
Emailing privacy@figloans.com
Through your Fig account

Questions or Concerns

You may contact us with questions or concerns about this Notice and our practices by:

Fig Loans
9450 SW Gemini Dr
Suite 93137
Beaverton, Oregon 97008-7105
Email us at privacy@figloans.com

Where You Can Find This Notice Online

You may access this Notice online at https://www.figloans.com/ccpa-opt-out