Effective/Updated date: July 1, 2020
If you are California resident, please see our Notice at Collection for California Residents.
(1) What Information Does Blend Collect?
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device that you use to access our Website.
(A) Categories of Information
As described further below and depending on how you use the Website and interact with us, we may collect the following categories of information about you or your use of the Website:
- Identifiers (such as name and email address);
- Commercial information (such as transaction data);
- Internet or other network or device activity (such as browsing history and log data);
- Professional or employment-related information (such as employment history when you apply for a job with us);
- Education information (such as when you apply for a job with us);
- Location information (such as general location information inferred from an IP address); and
- Other information that identifies or can be reasonably associated with you.
(B) Categories of Sources of Information
(i) Information You Provide to Us
We may collect information from you during your use of or access to the Website, such as when you:
- Request a demo of or inquire for information about a Blend product or service;
- Enter information on the Website (e.g., providing your email address to subscribe to our blog);
- Communicate with us (including through our customer support services or on third-party social media sites); or
- Apply for employment at Blend.
We will collect any information that you choose to provide to us. The information we collect 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 Website. As described further below, we may collect and analyze information such as (a) IP addresses (including city and state information), unique device identifiers, browser types, browser language, operating system, and mobile device carrier information; and (b) information related to the ways in which you interact with the Website, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, pages and content viewed and the order of those pages, statistical information about the use of the Website, 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 Website through the use of internet server logs, cookies, and/or tracking pixels. A web 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; (ii) store your preferences and settings; (iii) understand the web pages of the Website you have visited; (iv) enhance your user experience by delivering content specific to your interests; (v) perform 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 Website 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.
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., Internet Explorer; 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 Website.
(iii) Information from Third Parties
Our Website may include social media features, such as the Facebook or Twitter button or interactive mini-programs that run on our Website. These features may collect your IP address and which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy statement of the company providing it.
We may also collect additional information about you, such as demographic and statistical information, from third parties, such as business partners, marketers, researchers, analysts, and other parties, that we may combine with information collected directly from you or attribute to you based on your assignment to certain statistical groups.
(2) How Will Blend Use My Information?
We and our service providers may use the information we collect from and about you for the following business purposes (as defined by applicable law) and commercial purposes:
- To process and respond to your inquiries or to request your feedback, including through our customer support services;
- For marketing and advertising purposes, including to contact you with information or surveys that we believe may be of interest to you regarding our Website, our products and service offerings and the product and service offerings of third parties;
- To conduct internal research, analytics, and reporting, including without limitation to synthesize and derive insights from your use of the Website;
- To improve the content and features of the Website and our other products or services;
- To develop or deliver new products or services;
- To personalize the content that you see on the Website;
- To administer and troubleshoot the Website;
- To review and process your employment applications;
- To comply with laws, regulations, and other legal process and procedure;
- To establish, exercise, or defend our legal rights; and
- To take steps that we reasonably believe to be necessary to protect the safety, security, and rights of Blend, its employees, service providers, and others.
We may also aggregate, de-identify, and/or anonymize any information collected through the Website in such a way that we cannot reasonably link the information to you or your device. We may use such aggregated, de-identified, or anonymized information for any purpose, including without limitation for research and marketing purposes.
(3) How Does Blend Personalize Content to My Interests?
Online and Email Analytics
We may use third-party web analytics services on the Website, such as 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 Website, including by noting the third-party website from which you arrive, provide certain features to you, improve and develop the Website, monitor and analyze use of the Website, aid our technical administration, assist in our troubleshooting and customer support efforts, and verify 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 opt-out cookies, and you will need to re-visit the relevant opt-out page.
If you receive email from us, we may use certain tools, such as clear GIFs, to collect data such as when you open our message or click on any links or banners our email contains. This information helps us make our communications with you more interesting and improve our Website.
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 Website for third-party purposes, and that is why we provide choices provided by Google Analytics. However, we do not currently recognize or respond to browser-initiated DNT signals. You can learn more about DNT at All About Do Not Track.
(4) How Will Blend Share My Information?
We and our service providers may share the categories of information identified above with the following categories of third parties as described in this section.
Affiliates and Subsidiaries. We may share information we collect from you to current and future affiliates and subsidiaries within the Blend family of companies.
Service Providers and Other Third-Parties. We may provide access to or share your information with select third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, analysis and processing, and legal services.
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), your information may be among the transferred assets. If a portion or all of Blend’s assets are sold or transferred to a third party pursuant to a corporate purchase, sale, or merger, your information may be one of the transferred business assets.
Consent. With your consent, we may also share your information with other third parties.
Blend may also share aggregated, de-identified and/or anonymized information for any purpose to third parties, including without limitation advertisers and promotional partners.
(5) 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 Website, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Website and that any such transmission is at your own risk. If you have any questions about the security of your information, you can contact us at firstname.lastname@example.org.
(6) What Rights Do I Have?
(A) Accessing, Updating, and Deleting Your Information. You may be able to access, update, or delete certain information we hold about you in accordance with applicable legal requirements. If you wish to request access or deletion of your information, please contact us at email@example.com. We will respond to your request within a reasonable timeframe.
(B) Marketing Communications and Sharing. You may instruct us not to use your contact information to contact you with marketing communications regarding products, services, promotions and special events that might appeal to your interests by contacting us at firstname.lastname@example.org. In commercial email messages, you can also opt-out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt-out of certain operational emails, such as those reflecting our relationship or transactions with you.
(C) Nevada Residents. Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing email@example.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
(D) 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”) and other applicable California privacy laws. Any terms used in this Notice that are not defined in the Notice itself have the same definition as used in the CCPA 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 “What Information Does Blend Collect” section of the Policy. The exact information we collect 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 Your Information: We use your information for the business or commercial purposes described above in the “How Will Blend Use My Information” section of the Policy. 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 practices over the previous 12 months until present time.
(c) Blend does not “sell” your personal information as defined by the California Consumer Privacy Act and its implementing regulations
(ii) Right to Know: California law provides California consumers with the right to request that certain covered businesses provide you (i) the categories of personal information we collect, use, disclose or sell about you; (ii) the categories of sources of such information; (iii) the business or commercial purpose for collecting or selling your personal information (as applicable); (iv) the categories of personal information we sell or have sold or disclosed for a business purpose about the consumer and the categories of third parties to whom we’ve disclosed your personal information and, (v) specific pieces of personal information that a business has collected about the consumer. This “Right to Know” is subject to certain exceptions. Furthermore, Blend is not required to respond to requests for the Right to Know from users acting as an employee, owner, director, officer, or contractor of another entity or within the context of another entity in conducting due diligence regarding, or providing or receiving a product or service to or from such company.
(iii) Right to Delete: California law provides California consumers with the right to request that certain covered businesses delete personal information that they have collected from you. This “Right to Delete” is subject to certain exceptions. Furthermore, Blend is not required to respond to requests for the Right to Know from users acting as an employee, owner, director, officer, or contractor of another entity or within the context of another entity in conducting due diligence regarding, or providing or receiving a product or service to or from such company. Please note, we need certain types of information so that we can provide the services to you. 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 we provide.
(iv) 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 we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations. In addition, Blend does not have actual knowledge that it sells the personal information of minors under 16 years of age.
(v) Authorized Agent: 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):
i. Provide the authorized agent signed permission to do so.
ii. Verify their own identity directly with the business.
iii. 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 visit https://blend.com/policies/personal-data-requests/.
(vii) Financial Incentives: We do not offer financial incentives for the collection of your data. If this changes, we will notify you prior to doing so, and we will obtain your consent to opt-in to this program before enrolling you.
(viii) Non-discrimination Rights: 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:
i. Deny you goods or services.
ii. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
iii. Provide you a different level or quality of goods or services.
iv. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
(ix) 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 requests to access or delete data.
(x) Contact us: If would like to exercise any of these rights, please submit a request at firstname.lastname@example.org or visit https://blend.com/policies/personal-data-requests/. 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. If you have any questions regarding your rights under California law, you may reach out to us at email@example.com.
(7) What Is Blend’s Responsibility for Third-Party Links on the Website?
The Website may contain links to or “from” third-party websites, applications, and other services available to support Website 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 Website and to read the privacy statements of each and every site they visit that collects their information.
(8) 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 firstname.lastname@example.org.
(9) Retention of Your 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 collected and use it.
(10) Employment Applications
You also have the option to connect to LinkedIn to apply for employment at Blend. Any information that Blend collects from LinkedIn in connection with your application for employment at Blend is handled consistent with this Policy. Blend will use and share your information only for employment purposes, such as evaluating you for a job opportunity or communicating with you about your interests, and where sharing is required by law.
If you are a California job applicant, please see our Notice at Collection for California Applicants.
(11) 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 and use practices, the features of the Website, or advances in technology. Please check this page periodically for changes. Your continued use of the Website following the posting of changes to this Policy will mean you accept those changes. If we make any material changes to our data privacy practices, we will notify you in accordance with applicable legal requirements.
If you have any questions or concerns regarding our Policy, please send us a detailed message to email@example.com, and we will try to resolve your concerns.
Blend Labs, Inc.
415 Kearny Street
San Francisco, CA 94108