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 and managers or other individuals exercising control of an entity applying for a loan (“Principals”), and other individuals who have a business relationship with us, such as agents, brokers, consultants, or supplier contacts (“B2B Contacts”).

Personal Information

In the previous twelve months, we have collected 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, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute 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 of 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) placement agents. 

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 software information collecting tools like a cookie, web beacon or local shared objects. We may also collect and use certain online data to analyze the use and performance of our websites. You can set your browser security settings to reject cookies, etc., however, in doing so you may not be able to take full advantage of various 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,  our website will treat the browser and device you use to access our website as opted-out from sales or sharing to the extent we engage in such processing.

Safeguards

We restrict access to personal information about you to those employees 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

The amount of time we retain a particular category of personal information will vary depending on the purpose for which it was collected, our business need for it, and our legal obligations to retain it.  We retain your personal information for the time needed to fulfill the purpose for which that information was collected and as required pursuant to our data retention policies, which reflect applicable statute of limitation periods and legal requirements.  In determining the appropriate retention period for personal information, we consider the purposes for which we collect, use and maintain your personal information and our legal requirements to retain such information, as well as 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 (including, 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); and

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

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 Effective Date of this Privacy Notice, your personal information or share your personal information with third parties for cross-context behavioral advertising.  If we decide to do so in the future, we will provide you with the right to opt out of such activities.

Additionally, we do not sell personal information of individuals we know to be under the age of 16, or share such personal information with third parties for cross-context behavioral advertising.

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.

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.

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.

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 policy statement.