Last Revised: January 1, 2023
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 our clients (“Privacy Policy”). Please take the time to read and understand this Privacy Policy that we have implemented to safeguard your personal information.
In addition, if you are a resident of California, please see our Additional Notice for California Residents, which provides additional information about our privacy practices.
Personal Information Collected
Ladder Capital collects certain personal information in order to provide financial services and products. The personal information that we gather during the normal course of doing business with you may include:
We do not disclose personal information about our clients, or former clients to anyone, except as permitted or required by law, or as necessary to provide requested services. We may 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. Information that we collect from individuals in their capacity as an owner, shareholder or guarantor of an entity applying for a loan in connection with the loan application process may be subject to a separate privacy notice provided to those individuals, which governs such disclosures.
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. You may contact us at 212-715-3170 regarding any questions about this policy statement.
Personal Information of Website Visitors
We also collect the personal information that you provide to us when you visit our website or contact us by phone or email, including identifiers, such as name, phone number, address, and email address.
We may also collect your IP address and unique device identifiers when you visit our websites. We may also collect Internet or other electronic network activity information, including but not limited to, browsing history, search history, and information regarding your interaction with our websites.
We may use such information to respond to your requests; to operate, evaluate and improve our business, including analyzing and enhancing our products, services and websites; to perform data analyses; to protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; to comply with applicable legal and regulatory requirements and our policies; to establish, exercise and defend legal claims; to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity; and to undertake internal research for technological development.
We may disclose the above categories of personal information for such business purposes to our affiliates and to service providers in connection with their provision of services to us. We also may disclose 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).
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.
This Notice was last updated on January 1, 2023 (“Effective Date”).
This Privacy Notice applies only to residents of California. We generally do not offer products or services directly to the general public or to individuals. However, we obtain information that individuals provide when contacting us, including via email or by phone, and when you visit our websites. We also obtain information of individuals who have a business relationship with us, such as agents, brokers, consultants, or supplier contacts (“B2B Contacts”), and who are California residents. Information that we collect from individuals in their capacity as an owner, shareholder or guarantor of an entity applying for a loan in connection with the loan application process is subject to a separate privacy notice provided to those individuals
Personal Information about California Consumers
We may collect from California consumers, or have collected from California consumers in the previous twelve months, the information listed below.
We may collect the above personal information directly from consumers and from consumer interactions with our websites. We may use personal information in the above categories for business purposes that include but are not limited to:
We may also use personal information to facilitate administrative functions and information technology operations, including but not limited to:
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 California 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 also may disclose 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 have not sold personal information to third parties, or shared such personal information with third parties to conduct cross-context behavioral advertising, in the 12-month period preceding the Effective Date of this Privacy Notice.
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.
Sales or Sharing of Minors’ Personal Information
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.
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.
Your Rights Under the California Consumer Privacy Act, as amended (“CCPA”)
If you are a California resident, you have: (1) the right to know what personal information we collect, use, disclose, sell and share; (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 collect certain sensitive information (as discussed above in the “Personal Information of California Consumers” section). We do not use or disclose sensitive information in a manner that requires us to offer a right to limit such use under the CCPA. We do not sell or share (as such terms are defined under the CCPA) your personal information. If we decide to sell or share personal information in the future, we will provide you with the right to opt out of such sales and sharing.
We do not use automated decision-making tools to process your personal information in a manner that requires us to offer a right to limit such processing under the CCPA.
You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity registered with the California Secretary of State. 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 may not discriminate against you for exercising any of your rights under the CCPA. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.
How to Exercise These Rights
You may request to exercise the foregoing rights by:
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.