Employee Privacy

Ladder Capital Finance LLC

CA Employee and Applicant Privacy Notice

This Notice was last updated on January 1, 2020.

This Privacy Notice (the “Notice”) applies to Ladder Capital Finance LLC’s (the “Company”) collection and processing of personal information of the Company’s job applicants, employees, directors, officers, and contractors who are residents of California (“you”). This Notice describes our practices regarding the categories of personal information we collect, our use of such information, and our obligations with respect to that information. We may update this Notice from time to time in the event of changes in these personal information practices.

Types of Personal Information We Collect

The Company may collect the following categories of personal information about you, directly or indirectly through its service providers:

(A) Identifiers such as a real name, alias, postal address, unique identification numbers (including employee ID), online identifier, internet protocol address, email address, account name, social security number, driver’s license or state identification card number, passport number, and other similar identifiers;

(B) Personal information described in Cal. Civ. Code Section 1798.80(e) (the California Customer Records statute), which includes any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, the identifiers listed in (A) above, as well as an individual’s physical characteristics or description telephone number, insurance policy number, education, employment, employment history, credit history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

(C) Characteristics of protected classifications under California or federal law, such as race, color, sex, sexual orientation, age (40 and older), national origin, religion, marital status, medical conditions, disability status, genetic information, military or veteran status, political affiliation and citizenship status;

(D) Biometric information, such as fingerprints for employees of the Company’s broker-dealer affiliate;

(E) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interactions with internet websites, applications, or advertisements;

(F) Geolocation data;

(G) Audio, electronic, visual, or similar information, such as photographs and information captured on security systems, including CCTV;

(H) Professional or employment-related information. This may include:

• Details necessary to perform human resource functions including, but not limited to: name, address, date of birth, employee medical information, social security numbers, employee driver’s license numbers, state identification card numbers and bank account information for auto-depositing of paychecks and expense reimbursements, nationality, photo, employee ID number and immigration status;
• Details applicable to your employment with the Company, such as date of hire, title/position, work-related contact details, work history, technical skills and training courses attended, salary, bonuses and incentives;
• Application-related information, such as your curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, references, desired salary, interview notes and background screening information;
• Information from other employees relating to job performance, and other personal information relevant for the purposes of employee disciplinary matters;
• Sick pay, records of work absences, vacation entitlement and requests, performance appraisals, disciplinary and grievance procedures;
• Investment accounts (for you and your Immediate Family Members¹ living in your household), insurance and other related benefits information (which may include information about your spouse, children and other eligible dependents and beneficiaries);
• For compliance purposes, records regarding employee’s outside business activities, political contributions history, and provision or receipt of gifts and entertainment to or from business contacts;
• Date of resignation or termination, reason for resignation or termination, other information relating to termination of employment;
• Information about your use of our systems, for example, your use of our IT systems and electronic devices used by, or allocated to, you; and
• Any information needed to comply with local legislation, court requests or law enforcement authorities;

(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99), such as institutions attended and performance; and

(K) Inferences drawn from any of the information identified above to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How We Use Your Personal Information

We may use your information to fulfill the usual human resources functions and obligations, including but not limited to:

• personnel administration;
• compensation, payroll, tax, insurance, benefit planning and administration;
• termination and recruitment;
• management of health and safety concerns;
• to manage disciplinary actions and terminations;
• talent and performance management, and advancement and succession planning;
• conducting employee surveys and other similar HR initiatives; and
• to administer programs and/or benefits offered to employees.

We may also use personal information to facilitate administrative functions and information technology operations, including but not limited to:

• management and operation of Information Technology and communications systems, and business continuity, disaster recovery, data archive and back-up;
• monitoring and protecting the security and use of our networks, communications and systems, offices and facilities, reports, property and infrastructure;
• protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• maintenance of records relating to business activities;
• budgeting and financial management and reporting; and
• obtaining and maintaining licenses, permits and authorizations applicable to the Company’s business operations.

We may use personal information to comply with legal requirements, and to exercise our legal rights, including but not limited to:

• to respond to requests in connection with litigation and from law enforcement and government authorities pursuant to valid legal process;
• dispute and complaint resolution, internal investigations and reviews, auditing, compliance, and risk management;
• compliance with record-keeping and reporting obligations; and
• establishing, exercising or defending against legal claims.

To the extent we anticipate using your information for purposes other than those set forth above, we will communicate that to you as required by law.

How We Share Your Personal Information

Your personal information may be disclosed to the following categories of recipients:

• our agents and service providers (e.g., the Company’s affiliates and third parties providing services, including IT maintenance and support, and personal data storage);
• courts, litigants and advisors;
• law enforcement, government authorities, or self-regulatory agencies;
• in the event that the Company is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and may be passed to the new owners of the business; and
• as may otherwise be required in the course of the Company’s business or to facilitate the provision of services and benefits for or to its employees.

You may contact Human Resources at 212-715-3154 with any questions regarding this Notice, or to update your information.

¹ As defined the Company’s Employment Manual and the Ladder Capital Asset Management LLC Compliance Manual.