Privacy
Welcome to Ladder. When you use our Site, you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important, and we hope you will take time to read it carefully. If you are a California resident, please click here to see our Privacy Information for California Residents.
Table of Contents
Definitions
“Ladder” or “us” or “our” or “we” refers to Ladder Financial Inc. and each of its subsidiaries and affiliates. “Site” means www.ladderlife.com and any other Internet sites operated by us, our online services, mobile services, and software. “You” and “your” means the user of this Site or individual who otherwise engages in business with us. “Personal information” refers to information that can be used on its own or with other information to identify, contact or locate you. For example, personal information includes your name, email address, phone number, date of birth, address, social security number, driver’s license number, credit card number, or other data which can be reasonably linked to you. Personal information does not include "de-identified" or other non-personally identifiable information. “De-identified” information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. “Carrier” means any insurance company that issues life insurance policies offered by Ladder.
Information We Collect
This privacy policy describes our collection of personal information from and about you. By using our Site or otherwise engaging in business with us, you consent to the collection and use of personal information in accordance with this policy. We collect information to provide better services to you, and we collect that information in the following ways:
Information You Give Us
We collect personal information from you when you register for a Ladder account, apply for insurance products and services through our Site, or apply to be an insurance agent appointed with our Carriers. For example, when you register for a Ladder account, we’ll ask you for your name and e-mail address, and when you apply for insurance products and services, we’ll ask you for your date of birth, Social Security number, address, phone number, driver’s license number, employment, financial, family, beneficiary and housing information, existing life and health insurance coverage information, activity information, health information, bank account and/or credit card information, and other information. We may also collect information from you during your use of our Site, or when we communicate with you via telephone, e-mail, text or other means. In addition, we have pages on social media sites like Instagram, Facebook, Twitter and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. If you are a partner, agent or vendor of ours and/or our Carriers, we will also collect information in connection with our business relationship, which may include your business contact information (e.g., business email, address, and phone number along with your title/role), and information collected from our ongoing business relationship (e.g., terms of our agreements with you, support calls, etc.).
Information We Collect from Third Parties
When you register for a Ladder account and/or apply for the insurance products and services offered through our Site, we will collect information from third parties to, among other things, verify your identity; assist in the underwriting of your application; make eligibility, risk rating, policy issuance and enrollment determinations; obtain reinsurance; administer coverage; administer claims; protect against fraud; and conduct other legally permissible activities. We generally collect your identifying information (for example, your name, address, e-mail, telephone number, date of birth, Social Security number, and employment information), bank account information, financial and credit information, existing and past life insurance coverage information, health information, driving record, criminal history, activity information, and other personal information from these third parties.
In addition, if another company refers you to us, we may collect your information from that company in order to process your application for the insurance products and services offered through our Site.
We use Plaid Technologies, Inc. ("Plaid") to gather data about you from your financial institutions and to process ACH payments. You agree that by using our Site, services and products, you are granting us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your financial institution. You also agree that your personal and financial information will be transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.
Information We Collect Based on Your Activity on Our Site
In order to provide our services to you, improve our products and services, and maintain records required by law, we collect information about your transactions and activity. For example, we collect information about your computer and your visits to the Site, such as your IP address, geographical location, browser type, referral source, length of visit, button clicks, mouse movement and page views, along with your responses to the questions that we need to receive from you to evaluate and process your insurance application or your request for an estimate, and your communications to us using third party tools, including those related to chat-related activities. In addition, we collect device-specific information such as hardware model, operating system version, unique device identifiers, and mobile network information including phone number. If you are a LadderLife™ policyholder, we collect information about your payment history.
We and our marketing partners and service providers use technologies such as cookies, beacons, tags, and scripts, and application programming interfaces (APIs) to analyze trends, administer our Site, track users’ movements around our Site, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis. We use cookies when you sign in to your Ladder account to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our Site. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of our Site may be limited. To learn more about cookies, beacons and similar technologies, and how you may opt-out of some of this tracking, you may wish to visit http://www.allaboutcookies.org/ or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/.
We also partner with third parties to manage our advertising on other websites and evaluate the overall performance of our Site. Our third party partners may use technologies such as cookies and APIs to gather information about your activities on our Site and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our marketing efforts or overall Site performance. We may also use and send information to certain third party partners, including session-replay technology service providers and chat-related service providers, to help us gather information about your activities on our Site so that we can help improve Site performance, assist you if there are any issues, or to combat fraud.
If you do not wish to have this information used for the purpose of serving you interest-based ads, you may opt-out of certain advertising networks by clicking here, or by using the opt out mechanism contained in the "Your Rights and Choices" section below. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Although we do our best to honor the privacy preferences of our users, because we believe that there is a consistent industry standard for how to respond to Do Not Track browser settings, we are not able to process or respond to such signals from your browser at this time. However, as explained further below in the "Your Rights and Choices" section, we do honor legally-required browser-based global privacy controls.
Purposes for Which We Use Information We Collect
We use the information we collect for our business purposes to provide, maintain, protect and improve our Site, products and services; to develop new products and services; to better our marketing efforts; and to protect us and our users. This may include processing your application for life insurance; servicing your LadderLife™ policy; enabling automatic payments and funds transfers with financial institutions; communicating with you concerning your Ladder account and transactions; processing your appointment with our Carriers; facilitating our ongoing business relationship with you; and addressing any disputes you may raise concerning your Ladder account or the products and services offered through our Site.
We may also use your personal information to select you for certain marketing offers, including from our partners, newsletters, surveys and/or requests for feedback regarding your experience. We may use your personal information both to select you for an offer and to communicate that offer to you. Receipt of these communications is voluntary. If you do not wish to receive these communications please click on the “unsubscribe" link provided in such communications.
How We Disclose and Categories of Third Parties to Which We Disclose Information
We disclose your personal information to others in the following circumstances:
With Your Consent
We may disclose your personal information to companies, organizations or individuals outside of Ladder when we have your consent to do so.
As Necessary to Provide You the Products and Services You Request
We will disclose your personal information to life insurance companies, reinsurance companies, business partners, and their respective administrators, vendors, agents, and third party service providers, including but not limited to insurance support organizations, that are engaged in services related to underwriting, selling, and issuing life insurance policies as needed to provide you the insurance products and services you request.
We will also disclose your personal information to third-party vendors, agents and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include billing, payments, background check services, service fulfillment, web hosting or providing analytic services. We provide only as much information as is needed for these third-party vendors, agents and other service providers to perform services on our behalf. In addition, if you were referred to us by another company, we will share your information with that company as necessary to honor the terms of our agreement with that company and to provide you the insurance products and services you request.
For Legal Reasons
We may disclose your personal information to companies, organizations or individuals as required by law or subpoena or if we reasonably believe that such action is necessary to (i) comply with, any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, detect, prevent or address fraud, or to protect the security or integrity of our Site and the products and services offered through our Site; and/or (iii) exercise or protect the rights, property, or personal safety of us, our users or others.
In Connection with Our Sale or Other Significant Transaction
We may disclose your personal information to companies, organizations or individuals in connection with a significant transaction, such as a merger, sale of our assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings.
With Our Affiliates
We may disclose your personal information to other companies owned by or under common ownership as Ladder. These companies will use your personal information in the same way as we can under this policy.
We Have De-Identified the Data
We may also aggregate, de-identify, or otherwise strip data of all personally identifying characteristics and may disclose that aggregated and/or de-identified data with other companies, organizations or individuals in our discretion.
Advertising and Analytics Partners
As discussed above in the "Information We Collect Based on Your Activity on Our Site" section, we may disclose to or allow access to certain information about you by our online advertising and analytics partners.
Your Rights and Choices
Marketing Opt Out Rights
If you do not want to receive promotional emails from us, you may stop receiving such emails by clicking on the “unsubscribe” link provided in such emails. We make every effort to promptly process all unsubscribe requests. You may not, however, opt out of service-related emails and communications (for example, you may not opt out of emails related to account verification, changes/updates to features of our Site or products or services, technical and security notices or that provide other transactional information).
Personal Information Rights
Depending on your jurisdiction of residence (e.g., California, Colorado, Virginia, Utah, and Connecticut), you (or an authorized agent acting on your behalf) may be able to make certain requests related to your personal information in accordance with applicable laws. Specifically, you may be able to request us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information. Such information is also set forth in this privacy policy.
- Provide access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
- Correct your personal information.
We will not discriminate against you for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you.
We also will take reasonable steps to verify your identity before responding to a request. In doing so, we will need to, at a minimum, match two or more pieces of information provided by you with the information maintained by us. If we are unable to verify your identity, we shall have the right, but not the obligation, to request additional information from you.
If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, or if you are an authorized agent making a request on a user’s behalf, please use the form here or contact us at privacy-requests@ladderlife.com. Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.
Sale/Targeted Advertising Opt Out Rights
As explained in the “Information We Collect Based on Your Activity on our Site” section above, we sometimes disclose information (e.g., usage information, online identifiers, and/or hashed email addresses) to unaffiliated third parties we collaborate with or that provide online targeted advertising that we think may be of value to you, or to assist us with analytics. These disclosures may be considered a “sale” or the processing/sharing of personal information for targeted advertising purposes under applicable law.
If you would like to opt out of our disclosure of your personal information through cookies and pixel technologies for purposes that could be considered “sales” or “sharing” for purposes of targeted advertising, please click here. You can also submit a request to opt out of our disclosures of information for these activities that are not cookie and pixel based by emailing us at privacy-requests@ladderlife.com.
Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Retention of Your Information
We will retain your information for as long as your account is active or as needed for legitimate business or legal purposes. We may also reject requests related to updating or deleting information that are unreasonably repetitive, require disproportionate technical effort (for example, fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for example, requests concerning information residing on backup systems). If you have any questions about reviewing, modifying or deleting your information, you may contact us by email at privacy-requests@ladderlife.com.
Privacy Information for California Residents
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA and which is subject to the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We “share” information to provide more relevant and tailored advertising to you regarding our Services. While we do not disclose your personal information to third parties in exchange for money, our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA.
Please note that not all of the personal information we collect from and about you is subject to the CCPA; therefore, in this section, we address the personal information that is subject to the CCPA.
Category of personal information | Purposes of use | Categories of Third Parties to Which Ladder Discloses this Personal Information | Categories of Third Parties to Which Ladder “Shares” and “Sells” this Personal Information for Advertising/Analytics Purposes |
Identifiers (e.g., name, address, email address) | Provide the Services; Communicate with you; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising partners (note that only email is shared) |
Internet or other network or device activity (e.g., browsing history or usage information and associated device IDs and IP addresses) | Provide the Services; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising/analytics partners |
Categories of personal information we collect
Under the CCPA, we are required to provide you with the “categories” of personal information we collect as defined by California law. The categories of personal information we collect that are subject to the CCPA are:
- Identifiers (such as name, address, email address) that are collected from prospective users or non-registered users seeking additional information about Ladder; and
- Internet or other network or device activity (such as browsing history or usage information and associated device IDs and IP addresses).
Your Choices Regarding “Sharing” and “Selling”
If you would like to opt out of our disclosure of your personal information through cookies and pixel technologies for purposes that could be considered “sales” or “sharing” for purposes of targeted advertising, please click here. You can also submit a request to opt out of our disclosures of information for these activities that are not cookie and pixel based by emailing us at privacy-requests@ladderlife.com.
Other CCPA Rights
If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes.
Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Please see the “Your Rights and Choices” section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.
Retention of Your Personal Information
Please see the “Retention of Your Information” section above.
Shine the Light Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.
Information Security
We maintain commercially reasonable administrative, physical, and technical safeguards designed to prevent any unauthorized use, access, processing, destruction, loss, alteration, or disclosure of the data and information you provide us. In the event that any data or information under our control is compromised as a result of a breach of security, we will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.
Children’s Privacy
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for a Ladder account. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us by e-mail (privacy-requests@ladderlife.com).
Third-Party Practices
This Site contains links to, and uses services from, other Internet sites that are not maintained by us. Unless otherwise stated, we make no warranties or representations regarding these websites or the products or services offered on them. We do not control the privacy or security practices of third parties, or the locations where they process data. You should read the privacy and security policies of the other sites, as their practices may differ from ours. In particular, we use certain Google Maps APIs to streamline the application process. The Google Maps APIs are covered by Google’s Privacy Policy, and to the extent applicable, is incorporated by reference to this policy.
Contacting Us
If you have any questions regarding this privacy policy or our practices, please contact us by e-mail (privacy@ladderlife.com) or by U.S. Mail (P.O. Box 456, Menlo Park, CA 94026, Attn: Privacy).
Changes
Any changes to this policy become effective when posted to the Site. If you have registered for an account through the Site, we will notify you of any material changes to this policy by using any of the contact information you have provided to us or by posting a message on the Site’s home page.
In addition, we will update the “last modified” date at the bottom of this page. Your continued use of the Site or our products and services following the update means that you accept our updated policy.
This privacy policy was last modified on June 14, 2024.