CALIFORNIA PRIVACY POLICY

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:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”).
• Information that is publicly available online or elsewhere and
• Employees and job applicants.

Use of Personal Information

• We may use or disclose the personal information we collect for one or more of the following business purposes:
• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us assist you in debt settlement activities.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To assist you in identifying appropriate resources if we cannot serve you for any of a number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt
• To provide a third party with qualified leads for a program that they may administer
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• To conduct audit, compliance or other legal work associated with our business.
• To perform financial reporting and accounting and other general business administration
• To assess third party vendors and services providers
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties.

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:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

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:

• Our affiliates.
• Corporate credit facility lenders
• Service providers.
• Vendors
• Other third parties including marketers

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:

• Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
• Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by us. You may access our Notice of Right to Opt-Out by clicking here.
• Right to Data Portability. You have the right to request a portable version of your data.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

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:

• CCPA Request Form
• 866-552-3337
• Support@LadderLoans.com

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

• 866-552-3337
• Support@LadderLoans.com

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:

• CCPA Request Form
• 866-552-3337

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.