Lamina Privacy Policy

PRIVACY POLICY

INTRODUCTION

This Privacy Policy describes how Lamina, LLC ("Lamina" or "we" or "our" or "us") handles the information we collect about you ("personal information") during your interactions with us as a visitor to the Lamina website with its homepage located at www.laminafs.com (the “Lamina Site”) or use the Lamina Platform (collectively, “Lamina Services”). This Privacy Policy does not apply to the personal information practices of Lamina’s affiliate companies, including West Monroe Partners, LLC (“West Monroe”). If you apply for a job posting with Lamina or visit Lamina’s offices, West Monroe’s privacy policy describes how it handles the personal information collected about you during such interactions.

The Lamina Platform is designed to help Lamina’s clients share loan documents with prospective investors. The Lamina Site is primarily intended to support users of the Lamina Platform. As a result, the personal information that Lamina controls through the Lamina Site and the Lamina Platform collects is largely limited to business users. This policy does not apply to the extent that Lamina acts as a processor or service provider on behalf of its customers.

Lamina Platform users may include personal information in the documents that they process on the Lamina Platform. Lamina does not control this personal information, and it is not subject to this Privacy Policy.

From time to time, we may supplement this Privacy Policy with additional information relating to a particular interaction we have with you.

This Privacy Policy was last updated and is effective as of November 21, 2024.

Notice at Collection

We collect the categories of personal information identified below. We “sell” or “share” (as those terms are defined in applicable law) some types of personal information collected from Lamina Website visitors for marketing and targeted advertising purposes to business partners and third parties, such as data analytics providers, advertising technology vendors, third-party advertising networks, and social media platforms. We do not sell or share personal information about Lamina Platform users or personal information that we process on their behalf.

Categories of Personal Information We Collect

Category Collected?	Sell or Share?	Category of Third Party Sold To/Shared With?
Identifiers/biographical information, including Name, postal and email address, phone number. Online identifiers, Internet Protocol (“IP”) address, and other similar identifiers.	Yes Yes	Advertising Partners
Personal information categories listed in the California Customer Records statute, such as your credit or debit card number.	No	N/A
Characteristics of protected classifications under California or Federal law, including age, gender/sex, language preferences, etc.	No	N/A
Commercial information, including items purchased, obtained, or considered and other purchasing or consuming histories or tendencies.	No	Advertising Partners
Internet or other electronic network activity information	Yes	Advertising Partners
General location information (imprecise)	Yes	Advertising Partners
Professional or employment-related information	No	N/A
Inferences drawn from the above-listed categories of personal information	No	N/A
Sensitive Personal Information, such as user names and passwords from Lamina Platform account holders We do not use or disclose such information for the purpose of inferring characteristics about you or for any purpose other than the limited permissible purposes set forth in the regulations implementing applicable law.	No	N/A

We do not knowingly sell or share personal information about persons under the age of 18. Please click here to opt out of the sale or sharing of your personal information, including targeted advertising.

The Business and Commercial Purposes for Which We Collect and Use Your Personal Information:

To provide, maintain, and improve the Lamina Services
To create, maintain, customize, and secure your account with us
To communicate with you, such as through bots, including to respond to your inquiries/requests and request feedback from you
To conduct analysis and develop and/or improve the Lamina Services
To protect the security and integrity of the Lamina Services, and protect against fraud and other illegal activities
To comply with applicable regulations and respond to lawful requests for information
To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction
To protect our rights, privacy, safety, property and/or those of others
To fulfill any other purpose for which you provide your personal information or as explained to you at the point of information collection
To display advertisement or send you information that is likely to be of interest to you

Retention

We will retain your personal information for as long as reasonably necessary to provide you with the Lamina Services; for marketing purposes unless you opt out as described in our Privacy Policy; or otherwise where permitted or required in accordance with applicable law. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

1. INFORMATION WE COLLECT

Active Data Collection
We actively collect information from our visitors both by asking specific questions on this Site and by permitting you to communicate directly with us via e-mail and other electronic means. When you communicate directly with us, through the Lamina Services or otherwise, we may collect your name, contact information, and any communications you provide to us through contact or feedback forms.

Passive Data Collection
We automatically collect certain personal information concerning your use of the Lamina Services, such as information regarding which of our pages are most often visited. We may share or transfer information about your use of the Lamina Site to third parties to maintain the Site, respond to direct inquiries, measure usage trends, and provide advertisements that are more relevant to you and your interests.

The following provides examples of the type of information that we collect from you, actively or passively, as applicable, and how we use that information.

Context	Types of Data	Legal Basis and Purpose for Collection and Use of Data
Client Information	We collect the name, contact information and email address of our clients and their employees with whom we may interact.	We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.
Feedback/Support	If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	We have a legitimate interest in receiving and acting upon your feedback or issues.
Mailing List	When you sign up for one of our mailing lists, we collect your email address.	We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.	We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We have a legitimate interest in understanding how you interact with our communications to you.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms, including your name and contact information. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Essential Cookies, clear GIFs and first party tracking	We use cookies, clear GIFs and other tracking technology that are essential for the operation of our website and providing our services to you. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information.	We have a legitimate interest in making our website operate efficiently.
Non-essential First-party Cookies and First Party Tracking	We also use cookies, clear GIFs and tracking technology that are not essential to the operation of our website.	Where required by law, we base the use of these cookies and tracking upon consent.
Non-essential Third-party Cookies and Third Party Tracking	We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.	Where required by law, we base the use of third-party cookies and tracking upon consent.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.
Inferences	We develop inferences based on your use of the Lamina Services and third-party information.	We have a legitimate interest in providing our services, to communicate with you, and for research and development.

We share the information we collect from you as set forth under the “SHARING OF INFORMATION” header.

Information from Third Party Sources

Lamina may, from time to time, combine information we receive through your use of the Lamina Services with information obtained through third party sources, including, for example, third parties, business partners, our affiliates, or publicly available sources, in order to enhance our ability to market those products or services that may be of interest to you.

2. SHARING OF INFORMATION

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations:

Affiliates and Acquisitions. We may share personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we may also share personal information with that company, including at the negotiation stage.
Other Disclosures with Your Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this policy.
Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or the provision of services by a third party intermediary.
Public. The Lamina Site may provide the opportunity to post or share comments, or reviews, in a public forum. If you decide to submit information on these pages, it may be publicly available.
Service Providers. We may share your information with service providers, which process personal information at our direction. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

3. HOW LAMINA PROTECTS YOUR INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use technical, administrative, and physical controls to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

4. CHOICES YOU HAVE ABOUT HOW LAMINA USES YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. Under applicable data protection laws, you may have certain rights with respect to your personal information depending on where you live, including the right to:

Access Your Personal Information. You may request information regarding whether we process your personal information or access your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
Correct Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
Delete Your Personal Information. You may request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Opt-out of Targeted Advertising. You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the cookie settings link here. Please note that if you change browsers or devices, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt-out of other forms of targeted advertising by submitting a request as described below. The Lamina Site does not respond to browser-based "Do Not Track" signals.
Object to Certain Processing. You may object to certain uses or disclosures of your personal information by contacting us at the address described below.
Restrict Certain Processing. Under certain circumstances, you may request us to restrict the processing of your personal information.
Revoke Consent. If we rely on your consent to process your personal information, you may revoke your consent to such processing at any time. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us as described below.
Data Portability. If applicable, request your personal information be ported (transferred) to another company.

Please note, these rights are not absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your requests to access, modify, or delete your information, or to revoke consent or object to processing. This may occur because the law permits or requires us to do so.

We do not discriminate against individuals who exercise their rights under this Privacy Policy.

We have also implemented the following mechanisms for exercising control over your personal information:

Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.

You may also adjust the marketing messages you receive or opt out of receiving marketing messages from Lamina by visiting our Preferences Center.

5. HOW TO MAKE A REQUEST CONCERNING YOUR PERSONAL INFORMATION

You may submit a request regarding your rights to [email protected]. This e-mail address is being protected from spam bots, you need JavaScript enabled to view it to request access to, correct or delete personal information that you have provided to us. Alternatively, you may call 888-326-0510 or mail us at:

Lamina, LLC
311 W. Monroe St.
14th Floor
Chicago, IL 60606
Attn: Legal/Privacy

Following submission of a request, we will take steps to verify your identity before responding substantively, as is required by law. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the mailing address we have on file, or the date of your last communication with us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

Depending on your U.S. state of residence, you may use an authorized agent to make your request. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must provide either a copy of the signed permission given to you by the individual or a power of attorney executed in accordance with applicable law.

If you are unsatisfied with our response to a request, you may appeal our decision by contacting us at [email protected] or, if you are in certain localities such as the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority. Finally, in certain U.S. states, if your appeal is denied, you may have a right to lodge a complaint with the state attorney general.

6. OTHER IMPORTANT INFORMATION

The following additional information relates to our privacy practices:

Third Party Websites/Links

The Lamina Site may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This policy does not apply to information collected about you by any third party (i.e., anyone other than Lamina). Information you provide directly to third parties is not covered by this Privacy Policy (for example, if you provide information to third party organizations that may be linked from the Lamina Site or whose contact information you gather from the Lamina Site). We encourage you to read the privacy policies of other websites or services to which you provide personal information.

Transmission Of Information To Other Countries.

Your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised Policy here, and we will notify you of material changes as required by applicable law. Our Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

What Lamina Does About Children Visiting This Site

The Lamina Services are not intended for children under the age of eighteen, and we do not knowingly collect information from individuals in this age group.

7. CONTACT US

If you have any questions, comments or concerns about our privacy practices, please contact us by e-mail at [email protected] or call us at 888-326-0510. This e-mail address is being protected from spam bots, you need JavaScript enabled to view it.