Last updated: June 10, 2024

This privacy notice for Blend Financial Inc. (doing business as Origin Financial), its subsidiaries and affiliates ("Origin Financial," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at useorigin.com or any website of ours that links to this privacy notice

• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hereforyou@useorigin.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Origin Financial and the Services, the choices you make, and the products and features you use. 

Do we process any sensitive personal information? We may process sensitive personal information; however, we require opt-in consent before processing any sensitive personal data.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. 

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. 

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. 

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here: hereforyou@useorigin.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names

• Phone numbers

• Email 

• Addresses

• Mailing addresses

• Job titles

• Usernames

• Passwords

• Contact preferences

• Contact or authentication data

• Billing addresses

• Historical data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Financial data

• Biometric data

• Credit worthiness data 

Social Media Login Data. We may provide you with the option to register with us using a Google SSO integration. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services

• Analyze how our Services are used so we can improve them to engage and retain users

• Support our marketing activities

• Diagnose problems and/or prevent fraudulent activities

• Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

If you are located in China, this section applies to you.

For purpose of this section, “China” refers to mainland China, excluding Hong Kong SAR, Macau SAR, and Taiwan, and “information” means any electronic or otherwise recorded information related to identified or identifiable natural persons, excluding anonymized data.

We may collect and process your information unless you delete your information or withdraw your consent.

Sharing information with third parties

We may share your information with third parties, including related entities, service providers (e.g., suppliers and vendors) and other business partners.

If it is necessary for us to transfer information in case of a merger, division, dissolution, declaration of bankruptcy, or other reasons, we will notify you of the name and contact information of the recipient. The recipient shall comply with this Privacy Policy when processing your information.

We may share your information relevant competent law enforcement body, regulatory, government agency, court or other third parties where we believe that such disclosure is to:

• comply with an applicable law or regulation; 

• exercise, establish or defend our legal rights, or

• protect your vital interests or those of any other person.

We will make every effort to protect your rights of accessing, correcting, copying, and deleting Personal Information, withdrawing consent as well as other statutory rights.

Cross-border transfer of your information

We may transfer your information outside of China. If applicable Chinese laws require us to provide you with further notice and obtain your separate consent for the cross-border transfer, we will further provide such notice and obtain your separate consent.

We will use lawful cross-border transfer mechanism to transfer your information outside of China and adopt necessary measures to ensure the overseas recipients can provide the same level of protection as required under applicable Chinese laws.

Data subject rights

Individuals located in China may have certain rights related to their information in our possession or for which we are otherwise responsible, as set forth below:

• You have the right to access and request a copy of your information that we collect and process.

• You have the right to know how your information is processed by us.

• If you find that your information is inaccurate or incomplete, you have the right to request us to correct or supplement.

• Unless otherwise provided by applicable Chinese laws, you have the right to restrict or object to us processing your information. If you exercise your above right, you may not be able to use certain services provided by us.

• You have the right to withdraw your consent.

• You have the right to request us to provide you with means to transfer your information to a specific entity designated by you, to the extent that your request is allowed under applicable Chinese laws.

• Under the following circumstances, if we have not deleted your information, you have the right to request us to delete your information:

  • The purpose of processing has been achieved, is impossible to be achieved, or it is no longer necessary to achieve the purpose of processing.

  • We cease the provision of services to you or the retention period for the information ends.

  • You have withdrawn your consent (if consent is the basis for processing).

  • We process your information in violation of applicable Chinese laws or the agreement with you.

• You have the right to request to know about any automated decision-making of your information, and if we conduct automated decision-making that results in a significant impact on your rights or interests, you have the right to request we explain such decision-making and to refuse that we make the decision solely through automated decision-making.

• You have the right to opt out of targeted advertising.

• Your rights above may be subject to certain limitations, and we may not be required to fulfill all requests in all circumstances. For example, we may not be able to delete or anonymize all data as we may be legally required to retain certain data or retain certain data in identifiable form under applicable laws.

Please note that some functionality may not be available, or we may not be able to fulfill your request, depending on our legal obligations. If functionality to exercise your rights is not available to you directly, or you have any questions or concerns about how we handle your data under PIPL, please contact hereforyou@useorigin.com.

Brazil's General Data Protection Law (LGPD)

We adhere to Brazil's General Data Protection Law (LGPD), which regulates the processing of personal data of individuals in Brazil. This includes respecting data subject rights such as access, correction, deletion, and data portability.

India's Digital Personal Data Protection Act (DPDP)

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Data Analytics Services

• Data Storage Service Providers

• Performance Monitoring Tools

• Product Engineering & Design Tools

• Testing Tools

• Website Hosting Service Providers

• Cloud Computing Services

• Communication & Collaboration Tools

• Finance & Accounting Tools

• Government Entities

• Payment Processors

• Retargeting Platforms

• Sales & Marketing Tools

• User Account Registration & Authentication Services

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Partner Access.  If you enable our Partner Access feature, you authorize us to share your data with a designated partner or collaborator (“Partner”).  You and your Partner agree to comply with applicable data protection laws and regulations in your use of any shared data.

You may remove a Partner from accessing the Partner Access feature at any time for any reason.  We reserve the right to terminate or restrict a Partner from accessing the Partner Access feature in case of violation of our Terms of Use or any applicable law, rule or regulation.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a Google SSO integration, we may have access to certain information about you.

Our Services offer you the ability to register and log in using a Google SSO integration. Where you choose to do this, we will receive certain information about you from your account. The information we receive may vary, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make available.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in  the United States, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Except as set forth herein, no purpose in this notice will require us keeping your personal information for longer than one (1) months past the termination of the user's account.

Please note that Origin Investment Advisory LLC (“Origin RIA”), a wholly-owned subsidiary of Blend Financial Inc., is a Registered Investment Adviser, registered with the U.S. Securities and Exchange Commission, and we are subject to Rule 204-2 (the “Books and Records Rule”) of the Investment Advisers Act of 1940.  As such, Origin RIA is required to maintain certain records under the Books and Records Rule, which may be retained for longer than one (1) month past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We practice data minimization and will only retain personal data for as long as necessary to fulfill the purposes outlined in this notice, or as required by law. 

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hereforyou@useorigin.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at hereforyou@useorigin.com.

12. UNIVERSAL OPT-OUT MECHANISMS

You have the right to opt out of the sale of your personal data, targeted advertising, and profiling. We recognize and honor universal opt-out mechanisms, which allow you to exercise these rights across multiple platforms and services seamlessly.

To opt out, you can:

1. Use Browser Settings: Enable the Do-Not-Track (DNT) feature in your web browser. While we currently do not respond to DNT signals, we will honor them starting January 1, 2025.

2. Global Privacy Control (GPC): Utilize the Global Privacy Control (GPC) signal, which is a browser setting or extension that communicates your privacy preferences to websites you visit.

3. Direct Requests: Contact us directly at hereforyou@useorigin.com to submit your opt-out request.

Once we receive your opt-out request, we will act upon it as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

For more information on how to exercise your privacy rights, please contact us at hereforyou@useorigin.com.

13. STATE-SPECIFIC PRIVACY RIGHTS?

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hereforyou@useorigin.com or by post to:

Blend Financial Inc.

68 Harrison Avenue

#605, PMB 50966

Boston, MA 02111

United States

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: hereforyou@useorigin.com.