If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see below and visit www.oag.ca.gov/privacy/ccpa.
Your California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: firstname.lastname@example.org.
Our Site does not support “Do Not Track” browser settings and does not currently employ any “Do Not Track” mechanisms or frameworks that would allow us to respond to requests from you regarding the collection of your personal information.
CCPA Disclosure for California Residents
The following disclosure is for California residents on the behalf of Pagaya Technologies, Ltd., Pagaya US Holding Company LLC, and its subsidiaries (“Pagaya”, “we”, “our” or “us”).
Pagaya is providing this disclosure in order to comply with the California Consumer Privacy Act (CCPA),which went into effect January 1, 2020. The CCPA is a law that provides additional data privacy rights to California residents with regards to the collection, use, and deletion of their personal information. “Personal Information” is 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.
This disclosure supplements the information contained in our online privacy notices and provides California residents more information about Personal Information we may collect and disclose for a business or commercial purpose and explains how consumers can exercise those rights. Because Pagaya does not sell personal information, we have not included a description of the right to opt out of the sale of personal information. If you have any questions regarding our sharing practices, please e-mail us at email@example.com.
The Policy covers Personal Information, that is collected, used, or disclosed outside of or separate from already exempted activities covered under federal law, such as when we collect Personal Information to offer you a financial product or service for personal, family, or household purposes.
Collection, Use, and Disclosure of Personal Information:
In the past 12 months, we have collected the following categories of personal information:
- Identifiers. This may include your 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.
- Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include your name, address, and phone number.
- Commercial information. This may include your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity. This may include your browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. This may include your physical location or movements.
- Sensory data. This may include your audio, electronic, visual, or similar information.
- Professional or employment-related information. This may include your current or past job history or performance evaluations.
- Inferences drawn from other personal information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
In the past 12 months, we have collected personal information from the following categories of sources:
- Directly from you when you provide us information or when you use our website (for example, browser cookies and web beacons).
- From third parties (e.g., credit bureaus and consumer data resellers) that interact with us in connection with services and activities we perform.
- Marketing list providers.
We also collect certain information from lending partners and when we purchase loans from lenders. However, with a limited exception, the CCPA does not apply to the collection, use, sharing, and disclosure of such information because this information is subject to federal privacy laws including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, and/or the California Financial Information Privacy Act.
We may collect your personal information for the following business or commercial purposes:
- Account Services: We use personal information to offer our 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 the service provider’s behalf
- Internal Research: We use personal information for our internal research related to technological development and demonstration.
- Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
- Legal Obligations: We use personal information to comply with legal obligations.
- Commercial/Economic Interests: We use personal information to advance our commercial or economic interest.
- Maintenance of Technology (e.g., debugging): To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets
- Security and Fraud Detection: We use personal information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
- Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
- Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
- Merger/Acquisition/Bankruptcy, etc.: We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.
Sharing or Disclosing Your Personal Information for a Business or Commercial Purpose
We may disclose the above categories of your Personal Information to third parties for business purposes or as required or permitted by law including with:
- Our affiliates and subsidiaries;
- Service providers;
- Third parties to whom you authorize us, directly or indirectly, to disclose your personal; information in connection with products or services we provide to you; and
- Government or regulatory authorities, as required by law
We do not “sell” personal information as defined by the CCPA and its implementing regulations, and, in the preceding twelve (12) months, we have not sold any personal information. Also, it is our business practice not to collect or sell personal information of minors under 16 years of age and we have no actual knowledge of doing so.
Your Rights Under CCPA
The CCPA provides you with certain rights regarding the collection, use, sale, sharing, and disclosure of your personal information. As we noted above, because Pagaya does not sell personal information, we have not included a description of the right to opt out of the sale of personal information. If you have any questions regarding our sharing practices, please e-mail us at firstname.lastname@example.org. In addition, as noted below, certain CCPA rights do NOT apply to business consumers.
As a California resident, you have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months including:
- The categories of Personal Information we have collected about you;
- The categories of sources from which we have collected Personal Information about you;
- The business or commercial purpose for collecting that Personal Information;
- The business purpose for disclosing that Personal Information to third parties;
- The categories of third parties with whom we have shared or share that Personal Information;
- The categories of Personal Information we have disclosed or shared with a third party for a business purpose; and
- The specific pieces of Personal Information we have collected about you.
This right does apply to business consumers.
Right to Request Deletion of Personal Information
California law gives you the right to request deletion of your Personal Information. We limit the Personal Information that we collect from you and only collect Personal Information from you for business or commercial purposes. Pagaya is providing the following methods to request deletion to comply with the CCPA. However, please keep in mind that Pagaya is not required to honor your request for deletion if the Personal Information is needed for a business purpose. In addition, this right does apply to business consumers.
You have the right to not receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA.
Exercising Your Rights
If you are a California resident, you can submit a request to us by: