Ladder Capital Corp and its affiliates (“Ladder Capital”) understand that confidentiality and the protection of your privacy are important elements of your business relationship with us. Ladder Capital has a policy of protecting the confidentiality and security of personal information we collect about individuals that we interact with in operating our business (“Privacy Policy”). Please take the time to read and understand this Privacy Policy that we have implemented to safeguard your personal information.

We generally do not offer products or services directly to the general public or to individuals. However, we obtain information that you provide when contacting us, including via email or by phone, and when you visit our websites. We also obtain information from and about individuals in their capacity as an owner, shareholder, guarantor, manager, or other control party of an entity applying for a loan (“Principals”), and individuals who have other business relationships with us, such as agents, brokers, consultants, or suppliers (“B2B Contacts”). If you provide personal information about another individual to us, you are responsible for ensuring that the individual is aware of this Privacy Policy.

Personal Information

We collect the information listed below:

• Identifiers, which include name, postal address, email address, social security number, driver’s license number, passport number or other similar identifiers. We collect these identifiers from Principals and we collect business contact identifiers from B2B Contacts. We may also collect your IP address and unique device identifiers when you visit our websites;
• Certain categories of personal information described in California Civil Code § 1798.80(e): the Identifiers listed above; signature (if you correspond with us), and telephone number;
• Certain categories of sensitive information from and about Principals: social security number, financial account data plus credential, and citizenship status;
• Characteristics of protected classifications, such as sex, gender and marital status. We obtain this information about Principals to the extent it is included in financial statements, tax returns or credit reports;
• Commercial information, including records of personal property, asset holding, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies. We collect this information about Principals;
• Internet or other electronic network activity information, including but not limited to, browsing history, search history, and information regarding your interaction with our websites;
• Geolocation data when you interact with our websites;
• Audio information from calls made to us, such as voicemails;
• Professional or employment-related information of Principals and B2B Contacts;
• Education information of Principals; and
• Inferences drawn from the information we collect when you visit our websites or seek to obtain financing from us in your capacity as a Principal.

We do not use sensitive information in a way that requires us to offer a right to limit such use.

We may collect the above personal information directly from you and from your interactions with our websites. We also obtain information about Principals from third party sources, including credit reporting agencies, financial institutions, creditors, and public records. We may use personal information in the above categories for business purposes that include but are not limited to:

• Providing information and responding to your requests;
• Operating, evaluating and improving our business, including analyzing and enhancing our products, services and websites;
• Performing data analyses;
• Protecting against, identifying and preventing fraud and other prohibited or illegal activity, claims and other liabilities;
• Complying with applicable legal and regulatory requirements and our policies;
• Establishing, exercising and defending legal claims;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Undertaking internal research for technological development;
• Administering, evaluating, and managing your application to be a broker or contractor and to contact you regarding such application;
• Evaluating and processing mortgage loan applications and other investment opportunities;
• Confirming licensing status; and
• Contacting you or your emergency contact.

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

• Managing and operating Information Technology and communications systems, and business continuity, disaster recovery, data archive and back-up;
• Maintaining records relating to business activities;
• Budgeting and financial management and reporting;
• Obtaining and maintaining licenses, permits and authorizations applicable to our business operations;
• Properly verifying your identity, preventing fraud and/or enhancing security; and/or
• Auditing, analyzing and providing reporting relating to our relationships.

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

We may disclose the above categories of personal information for these business purposes to our affiliates and to service providers in connection with their provision of services to us. We may also disclose the information we collect, as described above, to certain non-affiliated third parties such as, but not limited to, attorneys, accountants, auditors and persons or entities that are assessing our compliance with industry standards. These non-affiliated third parties are subject to contractual or professional obligations that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.  In addition, we may, however, disclose relevant personal information: (1) when required by law, regulation or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) when necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and (4) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). We disclose the above categories of personal information of Principals as noted above, as well as with: (1) investors and potential investors, and their affiliates and representatives; (2) nationally recognized statistical rating organizations; and (3) lenders on loans we may pledge as collateral for borrowings. 

Mobile phone information will not be disclosed to third parties or our affiliates for marketing or promotional purposes. We will not share text messaging originator opt-in data and consent with any third parties (except in the limited circumstances noted above).

Website Visitors

We may collect online data derived from your access to, and use of, our various internal and external websites through cookies, web beacons, local shared objects and similar technologies. Our websites may use the following categories of cookies:

(a) necessary cookies that are required to enable basic site functionality and do not store personally identifiable data;

(b) functional cookies that support features such as content sharing and feedback collection;

(c) analytics cookies that help us understand how visitors interact with our websites, including metrics such as visitor count, bounce rate and traffic source; and

(d) performance cookies that help us analyze key performance indicators to improve user experience.

You may manage your cookie preferences through the cookie consent tool on our websites.

We also use Google Analytics, a web analysis service provided by Google, to help us understand how visitors use our websites. Google Analytics collects information such as how often users visit our websites and what pages they visit. You can learn more about how Google uses data at www.google.com/policies/privacy/partners/ and opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout. You can also set your browser security settings to reject cookies; however, in doing so you may not be able to take full advantage of our websites’ functionality.

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. We do not respond to browser “do not track” signals. However, if you use Global Privacy Control or another universal opt-out mechanism recognized under applicable state law, our website will treat the browser and device you use to access our website as opted-out from the sharing of personal information to the extent we engage in such processing.

Safeguards

We restrict access to personal information about you to those employees and vendors who need to know that information to provide financial products or services to you or to otherwise do their job. We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect your personal information.

How Long We Keep Personal Information

We retain your personal information for as long as necessary to fulfill the purpose for which it was collected, consistent with our data retention policies, applicable statute of limitation periods, and legal requirements.  In determining the appropriate retention period, we also consider the potential risk of harm from unauthorized use or disclosure of your personal information.

Additional State Specific Rights

If you are a resident of California or another state in which a state-level privacy law applicable to Ladder Capital has been enacted, additional rights described in this Section may apply to you.

You may have the following rights, in each case to the extent set out in applicable law:

(1) the right to know what personal information we collect, use, disclose, sell or share (provided, if applicable, in a portable and readily usable format);

(2) the right to request that we delete your personal information (subject to our legal rights or obligations to retain such personal information);

(3) the right to request that we correct or update inaccurate personal information; and

(4) the right to opt out of the processing of your personal information for purposes of targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We will honor your request to the extent required by applicable law.

We do not sell, and have not sold in the 12-month period preceding the last revised date of this Privacy Policy, your personal information or share your personal information with third parties for cross-context behavioral advertising or targeted advertising.  If we decide to do so in the future, we will provide you with the right to opt out of such activities.

We will not discriminate against you for exercising any of your rights under the applicable state privacy laws

How to Exercise These Rights

You may request to exercise the foregoing rights by:

• Submitting a request via email to legalandcompliance@laddercapital.com.
• Calling us toll-free at 1-833-506-0481.

You may designate an authorized agent to make a request on your behalf. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.  If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how to exercise them.

Children’s Privacy

Our websites are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information.

Links to Third-Party Websites

Our websites may contain links to websites operated by third parties. These linked websites are not under our control, and we are not responsible for the privacy practices or the content of any linked websites. If you visit a linked website, you should review that website’s privacy policy to understand how your personal information may be collected and used.

Changes

We reserve the right to change this Privacy Policy at any time. Changes to this Privacy Policy will be posted on this website, or other method as required by law.

You may contact us at 212-715-3170 regarding any questions about this Privacy Policy.