Updated/Effective date: November 30, 2021

The financial institution you’re using (your “Financial Services Provider”) has engaged Blend Labs, Inc. (“Blend” or “us” or “our” or “we”) to enhance your online experience.    

This Privacy Policy (“Policy”) applies to the online platform (“Platform”) owned and operated by Blend. The Platform allows you to provide information that your Financial Services Provider needs to check loan rates, process loan applications and offer other financial services to you. “You” and “your” refer to you and/or any person who accesses or uses the Platform on your behalf, including an authorized signer, authorized representative, delegate, co-applicant and/or other authorized Platform user. Except as provided herein, this Policy describes and governs the information collection, use, and sharing practices of Blend with respect to the Platform.

Before you use or submit any information on or through the Platform, please carefully review this Policy. Blend will continue to evaluate this Policy as we update and expand the Platform and our offerings, and we may make changes to the Policy accordingly. Any changes will be incorporated into this Policy and posted on the Platform. Your continued use of the Platform will signify acknowledgment of the terms of the Policy including any updates. The most current version of the Policy that applies to your use of the Platform will be available to you by clicking the link at the bottom left of the desktop version of the Platform or in the upper right of the mobile version of the Platform.

1. Privacy of Joint Applicants

If you are using the Platform to apply jointly with another person for a loan or other financial services product, you and your co-applicant may be required to provide information using a single application or you may have the option to use multiple individual Platform account(s). When using a single application, the joint applicants will have access to all information supplied by each other to complete that application. Such joint applicants will have the ability to view, print, transmit, save, and/or edit the information. Access may continue for as long as the joint applicants utilize the single Platform account in connection with the application process. While Blend takes reasonable efforts to keep personal information separate between joint applicants, all types of joint applicants should expect that certain personal information may be shared between both applicants. The type of personal information shared between joint applicants may depend on the practices of your Financial Services Provider.

2. What Information Does Blend Collect?

a. Categories of Information

We collect information directly from you, third parties you authorize, or publicly available information. The extent of information Blend collects depends on the data collection practices of your Financial Services Provider and the products and services sought. The information in this disclosure is based on our data collection practices over the previous 12 months until present time. The following is a list of categories of information we may collect:

  • Common identifiers (such as a real name, postal address, IP address, email address, social security number, or other similar identifiers);
  • Commercial information (such as transactional data or records of personal property, or other purchasing or consuming histories or tendencies);
  • Financial information (such as financial history);
  • Internet or other network or device activity (such as browsing history and log data);
  • Identity verification information (such as faceprints, scans of hand or face geometry, voiceprints, iris or retina scans, and/or pictures of your identification cards);
  • Geolocation information (such as general location information inferred from an IP address);
  • Professional or employment related data (such as information you provide about your work history);
  • Education data (such as information about your educational institutions and history);
  • Characteristics of protected classifications under state or federal law (such as gender or marital status);
  • Physical characteristics or description;
  • Inference data about you (such as profiles we develop based on how you use the Platform); and
  • Other information that identifies or can be reasonably associated with you.

b. Categories of Sources of Information

Blend collects information in multiple ways, including when you provide information directly to us, when we passively collect information from your browser or device, and when we obtain information from third parties as indicated in this Policy.

Information You Provide Directly to Us

Blend may collect information from you during your use of or access to the Platform, such as when you register for a Blend Platform account, enter information in the Platform or communicate with us, or when connecting your third-party accounts to retrieve your information.

Information Collected Indirectly

Device/usage information: Blend may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Platform. We may collect and analyze information such as (a) IP addresses, unique device identifiers, , unique personal 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 Platform, 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 Platform, amount of time spent on particular pages, date and time you used the Platform, frequency of your use of the Platform, 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 Electronic Technologies: We may also collect data about your use of the Platform through the use of internet server logs, 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 only to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Platform you have visited; (iv) enable your user experience in the Platform; (v) perform searches and analytics; and (vi) assist with security 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 Platform and associated content, and access user cookies. We may update this Policy from time to time as we adopt new technologies to 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 (e.g., Google Chrome; Mozilla Firefox; or Apple Safari) for more information. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Platform.

Information from Third Parties

Blend may also obtain information about you from third parties such as other financial institutions with which you have a relationship, third-party data provider partners (see below), and credit reporting agencies, among others. These third parties provide data, products, and services that enable us to provide the services you have requested through the Platform.

3. How Will Blend Use My Information?

Blend may use the information we collect from and about you for the following purposes:

  • To provide services through or in connection with the Platform to your Financial Services Provider, and to you on behalf of your Financial Services Provider, including:
    • Providing analytics and reporting services to your Financial Services Provider;
    • Processing applications and fulfilling your requests and transactions;
    • Verifying your identity;
    • Sending you communications on behalf of your Financial Services Provider related to your Platform activities;
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; and
    • Responding to legal requests and demands, as well as exercising and defending legal claims.
  • For internal purposes to improve our services, including:
    • Undertaking internal research and reporting; and
    • For development, such as to improve the content and features of the Platform.

    Blend may also collect, use, and share your information in an anonymized, aggregated, and de-identified form (that does not identify you personally) for our business purposes.

    Online and Email Analytics: Blend may use third-party web analytics services on the Platform, 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 Platform, including by noting the third-party website from which you arrive, improving and developing the Platform, monitoring and analyzing use of the Platform, 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 by clicking here. 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 on the Platform 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 by clicking here.

    4. How Will Blend Share My Information?

    We may share your information with the following categories of parties as described in this section. We base the information in this disclosure on our data sharing practices over the previous 12 months until present time.

              • Your Financial Services Provider. Blend collects information for your Financial Services Provider that are evaluating, processing, or funding loan applications or other financial services applications. We may share the information you provide with, and/or make that information available to your Financial Services Provider, its successors-in-interest, and other relevant third parties that your Financial Services Provider has authorized to access the information in order to facilitate the loan process or other financial services transaction, and provide related services and products to you. If you have questions about your Financial Services Provider’s privacy practices or you no longer want to be contacted by your Financial Services Provider, please contact your Financial Services Provider directly. Blend is not responsible for the privacy practices of your Financial Services Provider.
              • Affiliates and subsidiaries of Blend. With your authorization on behalf of your Financial Services Provider, we may share information we collect with other members of the Blend family of companies (e.g., Blend Insurance) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and the customer experience.
              • Service providers. Blend may provide access to or share your information with select third parties who perform services on our behalf to facilitate the operation and functionality of the Platform. For example, we may use companies that assist with billing, customer support, fulfillment, data storage, to mitigate fraud and verify your identity, analysis and processing, and legal services. We may also provide access to or share information with third parties as necessary to effect, administer, or enforce a transaction that you request or authorize. These service providers are only permitted to use your personal information in order to perform services on our behalf.
              • Protection of Blend and others. We may access, preserve, and disclose your information, including but not limited to any user content, if required to do so by law or in a good faith belief that such access, preservation, or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce any agreements, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property, or personal safety of Blend, its agents and affiliates, and/or its users and/or the public.
              • Business transfers. As we continue to develop our business, we may buy or merge with other companies. In such transactions (including in contemplation of such transactions, e.g., due diligence), user information may be transferred to continue providing services through or in connection with the Platform.

    5. Sharing of Account Information with Data Provider Partners and your Financial Services Provider
    We may use data provider partners, including Plaid Inc. and Finicity Corporation, to assist in obtaining information from one or more of your financial institutions. We then share this information with your Financial Services Provider for the purpose of verifying your financial information, completing your application, and underwriting your loan. You will be able to view and select which of your financial accounts to include in your application. If you choose to provide your third-party account credentials (e.g., your log-in credentials for accessing your bank account or tax return information) (“Third-Party Account Credentials”) to link with your third-party accounts, you grant Blend and our data provider partners the right to collect those credentials and retrieve information with those credentials from the relevant third party on your behalf and transmit such information to your Financial Services Provider. Information collected from your selected financial institution accounts may include account balance information, financial statements and summaries, transaction history, account ownership, and other similar information.

    The length of transaction history retrieved from each account may vary based on the underwriting requirements relevant to your application. The collection, use, transmission, and storage of this information by our data provider partners is governed by the privacy policies of the applicable data provider partners. None of the data provider partners in use by Blend sell your personal information to third parties.

    The data provider partners will be able to continue retrieving necessary information from your account as long as specified by your Financial Services Provider in connection with your application, unless you change your login credentials or ask to stop such access by emailing privacy@blend.com.

    6. Sharing of Income and Employment Information with Data Provider Partners and your Financial Services Provider

    Blend may use data provider partners to assist in obtaining information from your previous and current employers. We then share this information with your Financial Services Providers for the purpose of verifying your information, completing your application, and underwriting your loan. If you choose to provide Third-Party Account Credentials to link your payroll or human resource information system (“HRIS”) accounts, you grant Blend and our data provider partners the right to retrieve information with those credentials from the relevant third party on your behalf and transmit such information to your Financial Services Provider. Information collected from your selected payroll or HRIS accounts may include employer name, salary or pay rate information, and other similar income and employment related information.

    The length of income and employment history retrieved may vary based on the underwriting requirements relevant to your application. None of the data provider partners used by Blend sell your personal information to third parties.

    The data provider partners will be able to continue retrieving necessary information from your account as long as specified by your Financial Services Provider in connection with your application, unless you change your login credentials or ask to stop such access by emailing privacy@blend.com.

    7. How Does Blend Secure My Data?
    We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, we store usernames, passwords, PINs, and other log-in information in encrypted form. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no internet and/or other electronic transmissions can be completely secure.

    8. What Choices Do I Have?
    You may be able to add, update, or edit certain information while using the Platform. 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. Any information that cannot be updated or edited through the Platform will require you to contact your Financial Services Provider for further assistance. Additionally, to the extent applicable law affords you rights regarding personal information held by your Financial Services Provider, such as access and deletion rights, please reach out to your Financial Services Provider to inquire about your data rights.

    9. 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 section in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) 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 and its implementing regulations.

    Blend is a technology Service Provider

    Blend is a Service Provider as defined by the CCPA and we process your information on behalf of your Financial Services Provider. To the extent California law allows you to make certain requests including access to personal information or requests to delete Personal Information, you must make these requests directly to your Financial Services Provider.

    Right to Know

    You have a right to know what personal information is being collected about you. This includes the following: categories of personal information; categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing personal information; and specific pieces of information collected. However, this “right to know” is subject to certain exceptions. To submit an access request, please reach out to your Financial Services Provider.

    Right to Delete

    You have a right to request deletion of personal information collected about you. However, this “right to delete” is subject to certain exceptions. To submit a deletion request, please reach out to your Financial Services Provider.

    Blend does not sell your data

    While the CCPA provides California residents with the right to opt out of the “sale” of their personal information, Blend has not “sold” consumer personal information in the preceding 12 months and does not “sell” your personal information, as that term is defined under the CCPA and its implementing regulations.

    Authorized Agents

    When a consumer uses an authorized agent to submit a request to know or a request to 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):

              • Provide the authorized agent signed permission to do so.
              • Verify their own identity directly with the business.
              • 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 reach out to your Financial Services Provider for instructions.

    Financial Incentives

    Blend does not offer financial incentives for the collection of your data.

    Non-discrimination Rights

    You also have the right to not be discriminated against for exercising certain of your rights under the CCPA.

    How other data privacy laws may affect your ability to request access to, 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 CCPA requests to access or delete data.

    Contact us

    If you have any questions regarding your rights under California law, you may reach out to us at privacy@blend.com or contact your Financial Services Provider.

    10. What Is Blend’s Responsibility for Third-Party Links on the Platform?

    The Platform may contain links to or “frame” third-party websites, applications, and other services available to support Platform operations and functionality. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they access third-party websites and/or leave the Platform and to read the privacy statements of each and every site they visit that collects their information.

    11. 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 you are under 13, please do not attempt to send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact privacy@blend.com.

    12. Retention of Your Information

    Blend keeps your information in identifiable form for no longer than necessary to provide services to your Financial Services Provider. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. We may, if necessary, retain some of the information for compliance with applicable banking and lending regulations, fraud prevention and identity verification, resolving disputes, and enforcing our agreements. Blend may also continue to use any aggregated or de-identified information but not in a manner that would identify you personally.

    13. What If I Have Questions About This Privacy Policy?

    If you have any questions or concerns regarding our Privacy Policy, please send us a detailed message to privacy@blend.com and we will try to resolve your concerns. If you have any questions about your Financial Service Provider’s privacy policy or practices, please contact them directly.

    Blend Labs, Inc.
    415 Kearny Street
    San Francisco, CA 94108