This document also includes the current Origin Privacy Disclosure Form summarizing how we share information and your rights to opt-out. We may also distribute this same Disclosure as a separate Notice, from time to time.
The current version of this document does not include a California Consumer Privacy Act ("CCPA") Privacy Statement applying to residents of the State of California, since Origin is currently not subject to CCPA requirements. A CCPA statement will be added to this document when Origin becomes subject to the CCPA.
How Our Services Work
Our Services are designed to create the best place to manage your financial life through the combination of an intuitive digital platform and human financial planners. Our Services enable you to connect and view your various online or app-based financial and finance related accounts in one place. Our Services may also permit you to analyze these accounts, set up automated savings or debt payments, transfer funds between your accounts, and receive offers relating to various financial products and services, including loans, payments, money transmission, and passive investment and savings vehicles from third parties.What Information We Collect
We may collect your personal data and other information from you in the following circumstances:Information You Provide.
Other Information We Collect:
● Non-Identifiable Data.
When you interact with our Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store this information itself or it may be included in databases owned and maintained by our agents or service providers. Our Services may use this information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors' Internet service providers. It is important to note that your personal data is not is available or used in this process.
● Aggregated Personal Data.
In an ongoing effort to better understand and serve our users, we may conduct research on our customer demographics, interests, and behavior based on personal data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
● Third Party Analytics.
We may also use your personal data and other personally non-identifiable information collected through our Services to help us improve content and functionality, to better understand our users, and to improve our Services. We may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or wish to have your name deleted from our mailing lists, please contact us as indicated below.
We are committed to protecting your personal data. We consider this to be a vital part of our relationship with you. We commit that if we share your data, it will be only in the following circumstances.
● At Your Request.
We may share your data where you have consented or otherwise given us permission to share your data. For example:
○ if you want us to retrieve your credit report on your behalf, we will need to share your personal data with third party credit bureaus for the purpose of retrieving your credit report.
○ If you choose to open an Origin Deposit Account to handle your savings goals, we will need to share your personal information with our banking partner BBVA.
In general, we will not share your name, address, email address, phone number, or tax identification number (such as U.S. social security number) with third party product providers that we refer you to. When you decide to pursue an offer from a referred third-party product provider, you may be asked to provide information directly to that provider, including your personal data. Using our Services does not require you to provide any information directly to such providers, unless you wish to. If certain referred third party service providers want us to share your personal information with them, for example for simplifying their sign up process, we would seek your explicit prior consent before doing so.
● As Aggregated or De-Identified Information.
Although we will not share your name, address, email address, phone number, or tax identification number (such as U.S. social security number) without your consent or unless you opt in to such sharing, we may share information that is aggregated or de-identified, so that it cannot reasonably be used to identify you. For example, we may include certain financial information about you (e.g., your rate of return for a security, token or currency) in a leaderboard that is accessible publicly, but your personal data will not be associated with such information unless you consent or opt-in to having your personal data associated or otherwise claim the profile associated with such information. In addition, we may share aggregated or de-identified information with third party providers to permit them to make offers that are more relevant to you.
● With Third Parties Needed to Provide Our Services.
We may share your information with vendors and partner service providers whom we use in delivering our Service. Examples include:
○ vendors who provide us with technology services such as hosting, identity verification, support, payment, bank account verification or email service. We provide these vendors with only the information they need to perform their specific function.
○ Our bank partner BBVA which supports the Origin Deposit Accounts
● For Legal Reasons.
We may share your information if required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process. This can include protecting the rights, property, and safety of Origin and its users, and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims.
● As Part of a Corporate Change.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, your personal data may be part of the transferred assetsHow to Update or Delete Your Account Information
You agree to promptly update your account information in the event of any change. If you need to update your personal data, please contact us at email@example.com. We will take reasonable steps to update or correct your personal data in our possession that you have previously submitted through our Services. You can also update your own data in our mobile app using the edit feature.
You may also choose not to provide us with your personal information, but you may as a result not be able to use some of our Services. You may terminate your account with us at any time by submitting a request to firstname.lastname@example.org, although additional steps may be required to close your Origin Deposit Account. Please note that we may retain your personal data and other information beyond the end of your relationship with us in accordance with our internal record-keeping policies and with applicable law, including to comply with legal reporting obligations.When You Provide To Us Unsolicited Information
We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not submit personal data to us. If you have reason to believe that a child under the age of 13 has provided personal data to us, please contact us and we will endeavor to delete that information from our databases, subject to applicable law.When You Link to Other Websites or Services
We take reasonable steps to protect your personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These include policies designed to protect the confidentiality and security of your personal data such as industry-standard encryption and authentication measures. We also limit access to your personal data to employees and service providers that have a business reason to know such information. However, no Internet or email transmission is ever fully secure or error free.Our Terms of Service
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
● Social Security number and income
● Date of Birth and address
● Account balances and payment history
● Credit history and credit scores
When you are no longer our customer, we continue to share your information as described in this notice.How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Origin chooses to share; and whether you can limit this sharing.Reasons we can share your personal information For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus:
Do we share? Yes
Can you limit this sharing? NoFor our marketing purposes to offer our products and services to you
Do we share? Yes
Can you limit this sharing? No
For joint marketing with other financial companies
Do we share? With your consent only
Can you limit this sharing? Yes, by not giving consent
For our affiliates’ everyday business purposes information about your transactions and experiences
Do we share? Not applicable
Can you limit this sharing? Not applicable
For our affiliates’ everyday business purposes information about your creditworthiness
Do we share? Not applicable
Can you limit this sharing? Not applicable
For our affiliates to market to you
Do we share? Not applicable
Can you limit this sharing? Not applicableFor nonaffiliates to market to you
Do we share? No
Can you limit this sharing? We don't shareQuestions
Email us at email@example.com or go to www.useorigin.comWho we are
Who is providing this notice?
Blend Financial Inc. doing business as Origin (“Origin”)What we do
How does Origin protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.How does Origin collect my personal information?
We collect your personal information, for example, when you:
● Link an external bank account
● Open an Origin Deposit Account
● Complete your financial diagnostics
We also collect your personal information from others, such as your employer, you existing bank if you link to your bank account.Why can't I limit all sharing?
Federal law gives you the right to limit only:
● Sharing for affiliates’ everyday business purposes – information about your creditworthiness
● Affiliates from using your information to market to you
● Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply only to you unless you tell us otherwise.DefinitionsAffiliates:
Companies related by common ownership or control with Origin. Origin does not have any affiliates.Nonaffiliates
: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Origin does not share with nonaffiliates so they can market to you.Joint marketing
: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial service companies.Other important information
We may offer financial services through joint marketing with other unaffiliated companies; if such joint marketing requires, or benefits from, sharing personal information, we will ask for your explicit consent to share such information.
We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you.