If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see below and visit www.oag.ca.gov/privacy/ccpa.

Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: info@pagaya.com.

Online Tracking

Our Site does not support “Do Not Track” browser settings and does not currently employ any “Do Not Track” mechanisms or frameworks that would allow us to respond to requests from you regarding the collection of your personal information.

CCPA Disclosure for California Residents

The following disclosure is for California residents on the behalf of Pagaya Technologies, Ltd., Pagaya US Holding Company LLC, and its subsidiaries (“Pagaya”, “we”, “our” or “us”).

Overview

Pagaya is providing this disclosure in order to comply with the California Consumer Privacy Act (CCPA),which went into effect January 1, 2020. The CCPA is a law that provides additional data privacy rights to California residents with regards to the collection, use, and deletion of their personal information. “Personal Information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

This disclosure supplements the information contained in our online privacy notices and provides California residents more information about Personal Information we may collect and disclose for a business or commercial purpose and explains how consumers can exercise those rights. Because Pagaya does not sell personal information, we have not included a description of the right to opt out of the sale of personal information. If you have any questions regarding our sharing practices, please e-mail us at info@pagaya.com.

The Policy covers Personal Information, that is collected, used, or disclosed outside of or separate from already exempted activities covered under federal law, such as when we collect Personal Information to offer you a financial product or service for personal, family, or household purposes.

Collection, Use, and Disclosure of Personal Information:
In the past 12 months, we have collected the following categories of personal information:

• Identifiers. This may include your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include your name, address, and phone number.
• Commercial information. This may include your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity. This may include your browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation data. This may include your physical location or movements.
• Sensory data. This may include your audio, electronic, visual, or similar information.
• Professional or employment-related information. This may include your current or past job history or performance evaluations.
• Inferences drawn from other personal information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

In the past 12 months, we have collected personal information from the following categories of sources:

• Directly from you when you provide us information or when you use our website (for example, browser cookies and web beacons).
• From third parties (e.g., credit bureaus and consumer data resellers) that interact with us in connection with services and activities we perform.
• Marketing list providers.

We also collect certain information from lending partners and when we purchase loans from lenders. However, with a limited exception, the CCPA does not apply to the collection, use, sharing, and disclosure of such information because this information is subject to federal privacy laws including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, and/or the California Financial Information Privacy Act.

We may collect your personal information for the following business or commercial purposes:

• Account Services: We use personal information to offer our account services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider’s behalf
• Internal Research: We use personal information for our internal research related to technological development and demonstration.
• Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
• Legal Obligations: We use personal information to comply with legal obligations.
• Commercial/Economic Interests: We use personal information to advance our commercial or economic interest.
• Maintenance of Technology (e.g., debugging): To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets
• Security and Fraud Detection: We use personal information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
• Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
• Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
• Merger/Acquisition/Bankruptcy, etc.: We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.

Sharing or Disclosing Your Personal Information for a Business or Commercial Purpose

We may disclose the above categories of your Personal Information to third parties for business purposes or as required or permitted by law including with:

• Our affiliates and subsidiaries;
• Service providers;
• Third parties to whom you authorize us, directly or indirectly, to disclose your personal; information in connection with products or services we provide to you; and
• Government or regulatory authorities, as required by law

We do not “sell” personal information as defined by the CCPA and its implementing regulations, and, in the preceding twelve (12) months, we have not sold any personal information. Also, it is our business practice not to collect or sell personal information of minors under 16 years of age and we have no actual knowledge of doing so.

Your Rights Under CCPA

The CCPA provides you with certain rights regarding the collection, use, sale, sharing, and disclosure of your personal information. As we noted above, because Pagaya does not sell personal information, we have not included a description of the right to opt out of the sale of personal information. If you have any questions regarding our sharing practices, please e-mail us at info@pagaya.com. In addition, as noted below, certain CCPA rights do NOT apply to business consumers.

As a California resident, you have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months including:

• The categories of Personal Information we have collected about you;
• The categories of sources from which we have collected Personal Information about you;
• The business or commercial purpose for collecting that Personal Information;
• The business purpose for disclosing that Personal Information to third parties;
• The categories of third parties with whom we have shared or share that Personal Information;
• The categories of Personal Information we have disclosed or shared with a third party for a business purpose; and
• The specific pieces of Personal Information we have collected about you.

This right does apply to business consumers.

Right to Request Deletion of Personal Information

California law gives you the right to request deletion of your Personal Information. We limit the Personal Information that we collect from you and only collect Personal Information from you for business or commercial purposes. Pagaya is providing the following methods to request deletion to comply with the CCPA. However, please keep in mind that Pagaya is not required to honor your request for deletion if the Personal Information is needed for a business purpose. In addition, this right does apply to business consumers.

Non-Discrimination Rights

You have the right to not receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA.

Exercising Your Rights

If you are a California resident, you can submit a request to us by:

E-mail
info@pagaya.com

Calling us
646-560-5095

Only you, or a person registered with the California Secretary of State whom you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request twice within a 12-month period.

For a verifiable consumer request, you must be able to:

• Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond; and
• Provide sufficient information to allow us to reasonably verify you are the California resident about whom we collected Personal Information or an authorized representative of such resident. The information you provide must include:
  • Confirmation of California residency;
  • Full name;
  • Address;
  • Email address; and
  • Other information that authenticates you (if a customer) or verifies you (if non-customer or authorized party).

We cannot respond to your request or provide you with personal information if we cannot verify your identity or confirm that the personal information relates to you. Submitting a verifiable consumer request does not require you to create an account with us.

Response Time and Method

Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request. Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with notice and an explanation of the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt. If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request and identifying any rights you may have to appeal the decision.

We will not charge you to verify your identity. In addition, we will not charge you or your authorized agent a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at info@pagaya.com , 646-560-5095, or at:

Pagaya Technologies, LTD
121 Menachem Begin Rd.
54th floor
Tel-Aviv, Israel
Attn: Legal / Privacy Matters

Pagaya Investments US LLC
90 Park Avenue
31st Floor
New York, NY 10016

This Job Candidate Privacy Notice (“Notice”) describes what personal data we, Pagaya, and our affiliates (“Pagaya”, “we”, “our” or “us”) – collect and process on our job candidates and applicants (“Candidates”, “you” or “you”) with respect to our application and recruitment process, why we collect it and how we use it. It also describes how candidates may exercise their rights to such data held with us.

We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please avoid providing us with your data.

You are not legally required to provide us with any personal data, but without it we may not be able to process your application.

1. What data do we collect, how do we collect it, and how do we use it?

Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, such as your identifying data, contact details, resume/CV, work-related data, social media activity, etc. We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as recruitment agencies, background check services (as applicable and subject to applicable law), or your references.

We will only use your personal data when the applicable law allows us to. Most commonly, we may use such data to assess our Candidates’ skills, qualifications and overall to verify, consider and process their application and candidacy for any of our positions, and to communicate with them regarding such processes. We may also use it to manage risk and enhance our security and anti-fraud measures, and to create aggregated statistical or inferred data regarding our Candidates, for further development and improvement of our recruitment processes.

In addition, we may use it to act as permitted by, and to comply with, any legal or regulatory requirements. Should we wish to conduct any additional activities that may require the use of your data, we will request your specific consent in advance.

2. Where do we store our Candidates’ data?

Your personal data will be maintained, processed and stored by Pagaya and our Service Providers (as defined in Section 5 below) in Pagaya’s different offices worldwide including Israel, and the United States, in the applied position’s location(s), and other jurisdictions, as necessary for the proper handling of your candidacy.

While privacy laws may vary between jurisdictions, Pagaya, its affiliates and Service Providers processing personal data on our behalf are each committed to protect personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

3. For how long may we keep your data?

We may retain Candidates’ data even after the applied position has been filled or closed. This is done so we could reconsider Candidates for other positions and opportunities at Pagaya; so we may use their personal data as reference for future applications submitted by them; in case the Candidate is hired, for additional employment and business purposes related to their work; and as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.

4. How will we secure your data?

Pagaya has implemented security measures designed to protect the personal data of our candidates, including physical, procedural and electronic measures. These measures provide sound industry standard security, confirmed also by Pagaya’s SOC 2 type II certification. We also regularly seek new ways and tools for further enhancing the security of our system and the integrity of the personal data that we hold. Please be aware that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal data stored with us.

5. Who will have access to your data?

Pagaya will share your personal data with several selected Service Providers, whose services and solutions complement, facilitate and enhance our own. These include any recruitment firms that have referred you to us (or vice versa), candidate evaluation centers, recruitment software providers, background checks providers, data and cybersecurity services, web analytics, and our business, legal, compliance and financial advisors (collectively, “Service Providers“). Such Service Providers may receive or otherwise have limited access to our Candidates’ personal data, depending on each of their particular roles and purposes in facilitating and enhancing our recruitment process, and may only use it for such purposes.

Additionally, we may disclose or otherwise allow access to any Candidates’ personal data pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing. We may also share your personal data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Pagaya, any of our customers or employees, or any member of the general public.

Finally, we may share personal data internally within our family of companies, for the purposes described above. In addition, should Pagaya undergo any change in control, including by means of merger, acquisition or purchase of all or part of its assets, your personal data may be shared with the parties involved in such event.

6. Which cookies and tracking technologies do we use?

Pagaya uses certain monitoring and tracking technologies, such as “cookies” and other downloaded data files, including ones offered by our Service Providers. These technologies are used to maintain, provide and improve our processes and operations on an ongoing basis, and in order to provide a better experience to our website visitors and Candidates.

For example, these technologies enable us to better secure our website and services and detect abnormal behaviors, to identify technical issues, and to monitor and improve the overall performance of our services and processes.

To learn more about our cookies practices, please visit our Cookie Policy.

7. How can you access your data or request to delete it?

If you wish to exercise your rights under applicable law to request access to your data, to rectify it, to erase it, or to port it, or to object to its processing, or to withdraw consent with respect to the data you shared with us, or to exercise any similar rights afforded to data subjects under the laws that apply to you – please send us an email to privacy@pagaya.com, and we will respond within a reasonable timeframe and in accordance with applicable laws.

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above. We may redact from the data which we will make available to you, any personal data related to others.

Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

8. Will this Notice be updated?

We may update this notice to reflect changes in our privacy practices. If we make any changes that we deem as “material”, we will update this page prior to the change becoming effective.

9. What if you have any questions?

if you have any comments or questions regarding our data practices or your privacy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Pagaya, you can contact our Data Protection Officer at privacy@pagaya.com.

Last updated: October, 2021

Contact

E-mail
@Investor Relations [link ir@pagaya.com]
@Partnerships [link info@pagaya.com]

Phone
1 (646) 710-7714

US Addresses
90 Park Avenue
New York, NY 10016

233 Wilshire Blvd Ste 720
Santa Monica, CA 90401

Tel Aviv Address
Azrieli Sarona Bldg,
54th floor
Derech Menachem Begin 121,
Tel-Aviv, Israel