Figure Markets Cookie Policy

LAST REVISED: November 27, 2024

Figure Markets Cookie Policy

1. Introduction

Figure Markets Ireland Limited (a registered Virtual Asset Service Provider (VASP)), together with its group entities, affiliates and subsidiaries including Figure Markets Holdings, Inc., Figure Securities, Inc., Figure Payments Corporation, Figure Investment Advisors, LLC, Figure Markets Credit, LLC, Figure Equity Solutions, Inc., and Figure Payments Corporation of California (collectively, “Figure,” “we,” “our,” or “us”) use cookies and similar technologies when you visit our websites such as www.figuremarkets.com and other Figure managed websites that link to this policy (each a “Site” and collectively the “Sites”). This policy also covers the use of cookies when you use the Figure mobile app or Figure application programming interface.

At Figure, security and compliance are integral to our operations, we use cookies and similar technologies to enhance your experience, provide secure access to our services, and deliver tailored content.. This Cookie Policy explains what cookies are, why we use them, and your rights to manage their use. For a broader understanding of how we handle your personal data, please refer to our Privacy Policy.

2. What Are Cookies?

"Cookies” are small data files stored on your device when you visit a website or use an application. They enable websites and applications to remember your preferences, analyze performance, and deliver personalized content. This policy also includes similar technologies like web beacons, pixels, local storage, and identifiers associated with your device, collectively referred to as 'cookies.' These technologies may be used to support essential website functionality, security, and compliance."

3. Legal Basis for Processing Cookies

We process cookies based on the following legal bases:

• Strictly Necessary Cookies: These are processed under our legitimate interest (Article 6(1)(f), GDPR) to ensure the functionality, security, and compliance of our websites and applications. This legitimate interest is balanced with your fundamental privacy rights.
• Other Cookies: All other cookies, including functional, performance, targeting, and social media cookies, are processed based on your explicit consent (Article 6(1)(a), GDPR).

You can manage or withdraw your consent at any time via our Cookie Consent Manager which allows you to control your cookie preferences with ease.

4. Why We Use Cookies

We use cookies and similar technologies for the following purposes:

• Ensure Security and Compliance: Protect your account, prevent fraudulent activities, and meet regulatory obligations, particularly as a regulated Virtual Asset Service Provider (VASP).
• Enhance Functionality: Save your preferences, such as language or region settings, and enable a seamless browsing experience.
• Analyze Performance: Collect anonymized data to measure website performance, optimize functionality, and track technical issues. For example, tracking load times or popular pages.
• Deliver Personalized Content: Provide tailored advertisements and content relevant to your interests.
• Facilitate Third-Party Integration: Enable social media interactions and integrations with trusted service providers, such as Facebook, LinkedIn, and X.
• Support Navigation: Ensure smooth transitions between pages and improve usability.

These cookies enhance your overall experience and allow us to better serve your needs while maintaining privacy and transparency.

5. Types of Cookies We Use

We use the following categories of cookies on our websites and applications:

1. Strictly Necessary Cookies:
   • Purpose: Enable core functionality such as secure logins, fraud prevention, and compliance with legal obligations.
   • Example: Cookies that maintain session integrity when you navigate between pages.
   • Legal Basis: Legitimate interest (Article 6(1)(f), GDPR).
2. Functional Cookies:
   • Purpose: Remember user settings (e.g., language or region) and provide a personalized experience.
   • Example: Saving your login credentials for faster access during subsequent visits.
   • Legal Basis: Consent (Article 6(1)(a), GDPR).
3. Performance Cookies:
   • Purpose: Collect anonymized data about how users interact with the site, enabling us to improve performance and identify areas for enhancement.
   • Example: Google Analytics cookies tracking site visits and page load times.
   • Subcategory: First-Party Analytics Cookies – These cookies are treated as performance cookies and enable us to measure and enhance website functionality.
   • Legal Basis: Consent (Article 6(1)(a), GDPR).
4. Targeting Cookies:
   • Purpose: Deliver advertisements relevant to your interests and track ad performance. These cookies may share anonymized user data with third-party advertising providers.
   • Example: Cookies used by advertising networks to show ads based on your browsing history.
   • Legal Basis: Consent (Article 6(1)(a), GDPR).
5. Social Media Cookies:
   • Purpose: Enable you to interact with social media platforms directly from our site, such as sharing content or logging in via social accounts.
   • Example: Cookies from Facebook, LinkedIn and Xthat track interactions across platforms.
   • Legal Basis: Consent (Article 6(1)(a), GDPR).

6. Third-Party Cookies

We partner with trusted third-party providers, such as Google Analytics, Facebook, LinkedIn, and X (formerly Twitter), to enhance our services. These technologies may collect information about your interactions with our websites, such as:

• Pages visited and links clicked.
• Behavior on figuremarkets.com.
• Unique device identifiers, including mobile device IP addresses.
• Information about your device’s operating system and mobile carrier.
• Location information, to the extent permitted by applicable law.

These technologies may include cookies, web beacons (such as conversion pixels), and similar tracking tools. For example, web beacons may be embedded in our Sites or marketing emails to track whether messages have been opened or links clicked. Web beacons do not store data on your device but work in conjunction with cookies to monitor activity.

Depending on your preferences in our Cookie Consent Manager, the collection and use of this data may vary. You can manage or withdraw consent for third-party cookies at any time via the Cookie Consent Manager.

Future Flexibility:
To improve our services, we reserve the right to add or replace third-party providers. Any changes to these providers or the data they process will be reflected in this policy and the Cookie Consent Manager.
For more details on how these third-party companies process data on our behalf, please refer to their respective privacy policies, accessible via our Cookie Information Page.

7. Retention Periods

The retention periods for cookies used on our websites and applications are outlined below. These durations reflect the purposes of the cookies and our commitment to protecting your data in compliance with GDPR.

Cookie Type	Retention Period	Details
Strictly Necessary	Session (until browser closes)	These cookies expire when you close your browser and are not stored on your device permanently.
Functional	Up to 12 months	Retained to save preferences (e.g., language, region) and improve usability for future visits.
Performance	Up to 24 months	Used to analyze site performance over time (e.g., page load times) and optimize functionality.
Targeting	Up to 24 months	Retained to deliver personalized advertisements and track their effectiveness over time.
Social Media	Up to 24 months	Enable sharing and interaction on platforms like Facebook and LinkedIn and may track user behavior across websites.

Key Points:

1. First-Party vs. Third-Party Cookies: Retention periods may vary for third-party cookies depending on the provider’s policies. Refer to our Cookie Information Page for details.
2. User-Controlled Retention: Cookie retention may change based on your preferences in the Cookie Consent Manager For example, disabling cookies may result in earlier deletion.
3. Automatic Renewal: Some cookies may be renewed automatically upon continued use of our website, in accordance with your consent preferences.

8. Your Rights and Choices

You have full control over your cookie preferences. Here’s how you can manage them:

1. Browser Settings:
   • Adjust your browser settings to block or delete cookies. For instructions, refer to your browser's help section (e.g., Google Chrome, Mozilla Firefox, Safari).
2. Cookie Consent Manager:
   • Use our Cookie Consent Manager to modify your preferences at any time. This tool allows you to enable or disable non-essential cookies and review details about each cookie type.
3. Device Settings:
   • Opt-out of interest-based advertising through your device’s operating system settings. For example, adjust your advertising preferences on iOS (Apple Support) or Android (Google Support).

Withdrawal of Consent:
You may withdraw your consent for non-essential cookies at any time using our Cookie Consent Manager. Withdrawing consent does not affect processing carried out before withdrawal. Note that disabling certain cookies may impact site functionality, such as the ability to log in or save preferences.

Managing Cookies Automatically:
Cookies that are disabled or blocked may remain on your device until they expire. To remove these cookies, use your browser’s clear cookies function or reset device identifiers on mobile.

9. Managing Cookies

Our Cookie Consent Manager is a powerful tool that gives you control over your cookie preferences. Its features include:

• Customization: Adjust your cookie preferences in real time, enabling or disabling specific categories such as Functional, Performance, or Targeting Cookies.
• Granularity: Manage preferences for first-party and third-party cookies separately.
• Transparency: View detailed information about each cookie, including its purpose, provider, and retention period.
• Notifications for Changes: Receive alerts when new cookies are introduced, categories are updated, or significant changes are made to our cookie practices.
• Consent Logs: Track your consent history, including preferences set, changes made, and timestamps, for added transparency and accountability.

To access the Cookie Consent Manager, click here or use the “Manage My Preferences” link in the footer of our website.

10. Impact of Disabling Cookies

Disabling or blocking cookies may affect your experience in the following ways:

• Strictly Necessary Cookies:
  • Impact: Core website features, such as secure login or maintaining session data, may not function properly.
  • Example: You may be unable to log in to your account or complete transactions.
• Functional Cookies:
  • Impact: Preferences like language or region settings may not be retained, requiring you to re-enter these details during every visit.
• Performance Cookies:
  • Impact: We may lose insights into website performance metrics, such as page load times or error tracking, which could affect ongoing improvements to our site.
• Targeting Cookies:
  • Impact: Advertisements may become less relevant to your interests, and we may lose insights into ad performance, limiting the personalization of marketing content.
• Social Media Cookies:
  • Impact: Features that enable sharing content on social media platforms or logging in using social accounts may be disrupted.

Disabling cookies does not automatically delete previously stored cookies on your device. To manually remove cookies, refer to your browser’s “clear cookies” or “delete browsing data” settings. For additional guidance, consult your browser or device’s support resources (e.g., but not limited to: Google Chrome, Apple Safari, Mozilla Firefox etc).
You can manage or withdraw consent for non-essential cookies at any time through our Cookie Consent Manager. This will not affect the lawful processing carried out before withdrawal.

11. Security And Compliance

At Figure, we prioritize security and regulatory compliance in all aspects of our operations. Strictly necessary cookies are deployed to:

• Protect your account and session data from unauthorized access or fraud.
• Ensure secure transactions and compliance with our obligations of each relevant Figure entity, (including Figure Markets Ireland Limited as a registered Virtual Asset Service Provider (VASP)).
• Maintain the integrity of our websites and applications.

All cookies, including non-essential categories, are deployed in compliance with GDPR or other applicable laws. This includes adhering to principles such as:

• Data Minimization: Collecting only the data necessary to fulfill the purpose of each cookie.
• Accountability: Regularly auditing our cookie practices and updating our tools to align with the latest regulations.

Our commitment to compliance ensures that all cookies are managed responsibly, protecting your data while providing transparency and control.

12. Updates to This Policy

We review and update this Cookie Policy periodically to reflect:

• Changes in technology, such as new tracking methods or security enhancements.
• Updates to laws or regulatory guidance, including GDPR and the ePrivacy Directive.
• Adjustments to our business practices, such as the introduction of new features or tools.

Timeline for Reviews:
Our Cookie Policy is reviewed at least annually, or more frequently if significant changes occur.

Communication of Updates:
All updates will be clearly communicated via:

• A notification banner on our website for new or returning users.
• An email notification for registered users when material changes are made.
• The publication date at the top of the policy to reflect the latest version.

These updates will take effect immediately upon publication. For previous versions of this policy, or to provide feedback, please contact us at privacy@figuremarkets.com.

13. Contact Us

Inquiries about this policy or your cookie preferences, including those from EU-based users, are managed centrally through our dedicated email address. Our team is available to address your concerns promptly and you can reach us using the contact details below:

Email: privacy@figuremarkets.com

Our team is available to assist you during business hours in your respective time zone.