Your California Privacy Rights
This section applies to any California residents about whom we have collected personal information from any source, including through your use of our Website(s),
by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person.
As a company regulated under the Gramm-Leach-Bliley Act (“GLBA”), Ladder Loans applies privacy and security protections to your personal information as required
by US federal law. As such, certain of the personal information that we may process about you is exempted from the California Consumer Privacy Act (“CCPA”) and
certain other personal information may be subject to the CCPA.
For purposes of this section, “personal information” 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 California consumer/resident or household. Personal information does not include publicly
available information or information that has been de-identified. In our descriptions, we have included all data collected without regard to exempt data under GLBA.
However, by doing so, we do not intend to waive claims of preemption under the GLBA and other similar regulations.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer or device (“personal information”). In particular, the chart below depicts the categories of
personal information relating to consumers we have collected within the last twelve (12) months:
Category | Examples | Collected | ||
---|---|---|---|---|
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES | ||
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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. Some personal information included in this category may overlap with other categories. | YES | ||
C. Protected classification characteristics under California or federal law. | Age (40 years or older | YES | ||
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | ||
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | ||
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES | ||
G. Geolocation data. | Physical location or movements. |
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H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | ||
I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES | ||
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | ||
K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose,
we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for
any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information
Category E: Biometric data
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information
We disclose your personal information for a business purpose to the following categories of third parties:
We may also disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a
commercial purpose, which may include providing your information to a provider which can assist you, we have a compensatory relationship which
requires the recipient to abide by data privacy regulations and not use it for any purpose except as described.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information
We disclose your personal information for a commercial purpose to the following categories of third parties:
Your Privacy Rights
If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information,
to the extent your personal information is not already subject to federal law and the required privacy and security measures applied under federal law:
You may also authorize someone to exercise the above rights on your behalf. In order to have a third party exercise rights on your behalf as an agent,
the third party would need to fill out the same forms as the consumer and have a notarized letter authorizing them to act on your behalf The agent would
also need to be able to have sufficient data to verify the identity of the consumer in question.
The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to
various exclusions and exceptions under applicable laws.
In order to verify your identity for prospective consumers, you must provide first and last name,
state of residence, phone, physical address and email. If you are a current customer, you must also provide the social security number or other identifying
account number in addition to the items required for prospective consumers.
If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:
For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:
Notice of Right to Opt-Out
You have the right to direct Ladder Loans not to sell your personal information and to refrain from doing so in the future.
If you wish to opt-out of such sales, please do so in one of the following ways:
Please consult the other sections of our Privacy Policy for further information on our practices regarding your personal information.
Contact Us
If you have any questions or concerns about this privacy statement, please send them to us by emailing Support@LadderLoans.com.