Biometric Policy

LAST REVISED: MARCH 12, 2024

Why are you receiving this notice?

This biometric privacy notice explains how Figure Markets Holding, Inc. and its subsidiaries (“Figure Markets,” “we,” and/or “us”) collect, use, share, retain, and destroy your Biometric Data when you use www.figuremarkets.com website or any related website or mobile application (the “Site”). “Biometric Data” includes: (i) “Biometric Identifiers,” which are data generated by measurements of your biological characteristics, such as your retina or iris scan, fingerprint, voiceprint, or a scan of your hand or face geometry; and (ii) “Biometric Information,” which is information based on a Biometric Identifier that can be used to identify you.

Please review this notice carefully. By agreeing to our collection of your Biometric Data, you consent to the collection, use, sharing, and retention of your Biometric Data as described in this notice.

What type of Biometric Data do we collect?

• Face geometry.

How do we collect it?

• We extract your face geometry from the government-issued identification documents and selfies that you provide to us when you create certain accounts, including the “Figure Wallet.”

How do we use and share it?

• We may use Biometric Information for purposes that include verifying or authenticating your identity, detecting and preventing fraud and safety or other security purposes.

How long do we retain your Biometric Data?

• We will only retain Biometric Information until the initial purpose for collecting it has been satisfied or within three years of the individual’s last interaction with Figure Markets, whichever occurs first, unless legally required to keep it for a different period.

What happens to your Biometric Data at the end of the retention period?

• Biometric information will be deleted from all systems unless prohibited by law such as court order.

Additional Privacy Disclosures and Your Rights

For more information about how we collect, use, and share your personal information, as well as your rights and choices concerning our data practices, please review our Privacy Policy. If you have additional questions, please feel free to contact us at privacy@figuremarkets.com.

Figure Markets Subsidiaries

Figure Markets Holdings, Inc. and its affiliates or subsidiaries includes Figure Technologies, LLC, Figure Markets, Inc., Figure Securities, Inc., Figure Payments Corporation dba Figure Pay (“Figure Markets”, “we” or “us”) and Figure Equity Solutions, Inc.