Blend Agent Privacy Notice
Effective/update date: February 27, 2024
If you are a California resident, please see our Notice at Collection for California Residents.
This Privacy Policy (“Privacy Policy”) describes and governs the information collection, use, and sharing practices of Blend Labs, Inc. and its subsidiaries, affiliates, and divisions as may change from time to time (collectively, “Blend”, “we”, “us”, and “our”) with respect to use of the Blend workspace platform, Blend agent mobile application, Blend lender desktop application, Blend lender mobile application, and Blend banker workspace application (collectively, the “Blend Apps”) and the services we provide through our website and the Blend Apps (collectively, the Blend Apps and the services available through them are the “Services”).
Before you use or submit any information through or in connection with the Services, please carefully review this Privacy Policy. By using any part of the Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Policy does not apply to consumer information collected, used, and disclosed through the Blend Platform. Blend’s use of data provided through the Blend Platform is governed by the Blend Consumer Privacy Policy.
1. What Information Does Blend Collect?
We collect information in multiple ways, including when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties.
a. Categories of Information
As described further below and depending on how you use the Services and interact with us, we may collect the following categories of personal information about you or your use of the Services:
- Common identifiers (such as name, postal address, IP address, email address, phone number, and other similar identifiers);
- Commercial information (such as transaction data);
- Internet or other network or device activity (such as browsing history and log data);
- Sensory or identity verification information (such as photos you may upload when using the Services and recordings of your voice during customer service calls);
- Geolocation information (such as general location information inferred from an IP address);
- Professional or employment related data (such as your place of employment);
- Inference data about you (such as the additional services we think would be of most interest to you based on your interactions with us); and
- Other information that identifies or can be reasonably associated with you.
We will not collect sensitive personal information about you through the Services. However, we will collect information you provide or transmit through the Services from and about your clients and prospective clients, which may include their sensitive personal information. You should never provide or transmit information about your clients and prospective clients through the Services without their explicit consent, and you should handle their information in accordance with their instructions and applicable privacy laws. The Blend Consumer Privacy Policy governs the consumer information collected through the Blend Platform. We may also access your contact list information to assist with creating or saving new leads, if applicable.
b. Categories of Sources of Information
(i) Information You Provide to Us
We may collect any information that you provide to us during your use of or access to the Services, such as when you, create an account with us;; input information about yourself, your clients or your prospective clients in or through the Services; request a demo of the Services or inquire for information about a Blend product or service; or communicate with us (including through our customer support services or on third-party social media sites)
We will collect any information that you choose to provide to us. The information we collect about you generally includes your name, email address, phone number, and information about your interactions with us.
(ii) Information Collected Automatically
Device/usage information: We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. We may collect and analyze information such as (a) IP addresses, , unique device identifiers, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information and the location from which you accessed the Platform; and (b) information related to the ways in which you interact with the Services, such as mouse movements and scrolling, referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, amount of time spent on particular pages, date and time you used the Services, frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Tracking Technologies: We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. An internet server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer or device; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enable your experience in the Services; (v) perform searches and analytics; and (vi) assist with security and other administrative functions. Some cookies are placed in your browser cache. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier that are embedded in websites, online ads, and/or email and are designed to provide usage information like page clicks, measure popularity of the Services and associated content, and access user cookies. We may update this Policy from time to time as we adopt additional technologies, we may also gather additional information through other methods.
Blocking cookies through your browser settings: Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
(iii) Information from Third Parties
We may also collect information about you or others through non-affiliated third parties, including partners, marketers, and researchers, and combine such information with other information collected about you.
(iii) Information From Your Employer
We may also collect information about you from your employer or the party that retained you and combine such information with other information collected about you.
2. How Will Blend Use My Information?
We may use the information we collect from and about you for the following business purposes:
- For the purposes for which it is provided, such as to facilitate connections between you and other parties to a transaction;
- To provide and improve the Services, including to develop new features or services;
- For technical and customer support;
- To send you information about your relationship or transactions with us, account alerts, or other similar communications;
- For marketing and advertising purposes, including to contact you with information or surveys that we believe may be of interest to you both regarding our products and Services and those of third parties;
- To process and respond to your inquiries or to request your feedback;
- For analytics, research, and reporting, including to synthesize and derive insights from your use of our Services;
- For internal administrative purposes, such as taking steps to secure the Services;
- To comply with the law and protect the safety, rights, property, or security of Blend, the Services, our customers, and the general public; and
- To establish, exercise, or defend or enforce our legal rights.
We may aggregate, de-identify and/or anonymize any information collected through the Services in such a way that we cannot reasonably link the information to you or your device. We may use such aggregated, de-identified and/or anonymized data for any purpose, including without limitation for research and marketing purposes.
Online and Email Analytics: We may use third-party web analytics services within the Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and Other Electronic Technologies” section to collect information (including your IP address) to help us analyze how users use the Services, including by noting the third-party website from which you arrive, improving and developing the Services, monitoring and analyzing use of the Services, aiding our technical administration, assisting in our troubleshooting and customer support efforts, and verifying that users have the authorization needed for us to process their requests. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may clear the Google Analytics opt-out cookies, and you will need to re-visit the relevant opt-out page. If you receive email communication from us, we may use certain tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains.
Notice Concerning Do Not Track Signals: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected through the Services for third-party purposes, and that is why we provide choices provided by Google Analytics. However, we do not recognize or respond to browser initiated DNT signals, as the internet industry is currently still working toward defining exactly what “DNT” means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about DNT at All About Do Not Track.
3. How Will Blend Disclose My Information?
We may disclose your information under the following circumstances:
Service Providers and Other Third Parties. We may provide access or disclose your information to select service providers and third parties who perform services on our behalf, including, without limitation: marketing, market research, customer support, data storage, data analysis and processing, and legal services.
Protection of Blend and Others. We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce out Terms of Use this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) to respond to your requests for customer service; and/or (d) to protect the rights, property, or personal safety of Blend, our agents and affiliates, our customers, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of Blend’s assets are sold or transferred to a third party, our data (including your contact information) would likely be one of the transferred business assets.
Affiliates and Subsidiaries of Blend. We may disclose information we collect from you to current and future affiliates and subsidiaries within the Blend family of companies.
Consent. With your consent, we may also disclose your information to other third parties.
We may disclose aggregated, de-identified and/or anonymized information for any purpose to third parties, including without limitation advertisers, promotional partners, and/or others.
4. How Does Blend Secure My Data?
We take technical, administrative, and physical measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services and that any such transmission is at your own risk.
5. What Choices Do I Have?
(A) Accessing, Updating, and Deleting Your Information. You may be able to add, update, or edit certain information while using the Website. When you update information, however, we may maintain a copy of the unrevised information in our records to the extent necessary for legal compliance purposes and where permitted by applicable law.
(B) California Residents. This section of the Policy applies solely to those individuals who reside in the State of California (“consumers” or “you”). We are providing this policy in compliance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other applicable California privacy laws. Any terms used in this section that are not defined in the Policy itself have the same definition as used in the CCPA/CPRA, and its implementing regulations.
(i) Notice at Collection for California Residents
(a) What Information We Collect: We collect the categories of information disclosed above in the “Categories of Information” section of the Policy, and we collect that information from the categories of sources described above in “Categories of Sources of Information.” The exact information we collect, and the sources, about you depends on what products/services you use and how you use our Website and interact with us. We base the information in this disclosure on our data collection practices over the previous 12 months until present time.
(b) How We Use and Disclose Your Information: We collect and use your information for the business or commercial purposes described above in the “How Will Blend Use My Information” section of the Policy, and we disclose your information to the categories of third parties described above in “How Will Blend Disclose My Information.” Exactly how we use your information depends on what products/services you use and how you use our Website and interact with us. We base the information in this disclosure on our data collection and disclosure practices over the previous 12 months until present time.
(ii) Right to Know: California law provides California consumers with the right to request that covered businesses provide you with the following: (i) the categories of personal information the business has collected about you; (ii) the categories of sources of such information; (iii) the business or commercial purpose for collecting, selling or sharing your personal information (as applicable); (iv) the categories of third parties to whom the business discloses personal information and, (v) the specific pieces of personal information the business has collected about you. To the extent applicable, a covered business must also disclose (i) the categories of your personal information that the business sold or shared (and to which categories of third parties); and (ii) the categories of your personal information that the business disclosed for a business purpose (and to which categories of persons). This “Right to Know” is subject to certain exceptions. Please see below under “Contact us” for information on how to submit an access request.
(iii) Right to Delete: California law provides California consumers with the right to request that covered businesses delete personal information that they have collected from you. This “Right to Delete” is subject to certain exceptions as provided by law. Please note, we need certain types of information so that we can provide the Services. If you request deletion of your information and we are required to delete your information, you may no longer be able to access or use the Services. Please see below under “Contact us” for information on how to submit a deletion request.
(iv) Right to Correct: California law provides California consumers with the right to request that covered businesses that maintain inaccurate personal information about you correct that information. This “Right to Correct” is subject to certain exceptions. Please see below under “Contact us” for information on how to submit a correction request.
(v) Right to Limit: While California law provides California consumers with the right to request that covered businesses limit the use and disclosure of sensitive personal information collected or processed with the purpose of inferring characteristics about them (subject to certain exceptions), we do not collect sensitive personal information about you through the Services, as we understand those terms to be defined by the CCPA/CPRA and its implementing regulations. Any sensitive personal information you provide or transmit through the Services from and about your clients and prospective clients is subject to the Blend Platform Consumer Privacy Policy.
(vi) Blend Does Not Sell or Share Your Data: While California law provides California consumers with the right to opt out of the “sale” or “sharing” of their personal information (subject to certain exceptions), Blend has not “sold” or “shared” consumer personal information in the preceding 12 months and does not “sell” or “share” your personal information as we understand those terms to be defined by the CCPA/CPRA and its implementing regulations.
(vii) Authorized Agents: When a consumer uses an authorized agent to submit a request to know, correct or delete, a business may require that the consumer do the following (this does not apply when a consumer has provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465):
(a) Provide the authorized agent signed permission to do so.
(b) Verify their own identity directly with the business.
(c) Directly confirm with the business that they provided the authorized agent permission to submit the request.
A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf. To make an authorized request on behalf of another pursuant to consumer rights provided by California law, please use the Data Request Form or call 866-602-9022.
(viii) Additional Rights: Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask certain covered businesses for a notice (a) identifying the categories of personal information (as defined by California law) that are disclosed to third parties for their own marketing purposes and (b) providing contact information for such third parties. However, as disclosed here in our Privacy Policy, Blend does not disclose such personal information for these purposes.
(ix) Financial Incentives: We do not offer financial incentives for the collection of your data.
(x) Right of No Retaliation You also have the right to not be discriminated against for exercising certain of your rights under the CCPA. If you exercise your rights under the CCPA, we will not:
(a) Deny you goods or services.
(b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
(c) Provide you a different level or quality of goods or services.
(d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
(e) Retaliate against an employee, applicant for employment, or independent contractor, as those terms are defined in California Civil Code Section 1798.145.
(xi) How other data privacy laws may affect your ability to request access to, correct, limit or delete, your data: Please note that your rights and choices regarding your personal information are often subject to other laws. Personal information collected pursuant to other laws, such as information governed by the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, and the California Financial Information Privacy Act, may be exempt from requests to access, correct, limit or delete data.
(xii) Contact us: If you would like to make a request to exercise any of these rights, please use the Data Request Form or call 866-602-9022. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
6. What is Blend’s Responsibility for Third-Party Links?
The Services may contain links to or “from” third-party websites, applications, and other services to support operations and functionality. Please be aware that we are not responsible for the privacy practices of such other sites and services. If you submit information to any of those websites, your information is governed by their privacy statements. We encourage our users to be aware when they access third-party websites and/or leave the Services and to read the privacy statements of each and every site they visit that collects their information.
7. What is Blend’s Policy on Children?
We do not knowingly collect or solicit personal information (as defined by the “Children’s Online Privacy Protection Act”) from anyone under the age of 13. If we learn that we have collected personal information from a child under age 13, we will take reasonable steps to delete it as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact privacy@blend.com.
8. What is Blend’s Policy on Retaining Information?
We keep your information for no longer than necessary for the purposes for which it is processed and/or as required to comply with applicable laws. The length of time for which we retain information depends on the purposes for which we collect and use it.
9. Will Blend Change This Policy?
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection use and practices, the features of the Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Service following the posting of changes to this Policy will mean you accept those changes.
10. What If I have Questions About this Privacy Policy?
If you have any questions about this Privacy Policy or our privacy practices, please send us a detailed message to privacy@blend.com, and we will try to resolve your concerns.
Blend Labs, Inc.
415 Kearny Street
San Francisco, CA 94108