Product Counsel - Data & Privacy

The role

The Product Counsel - Data & Privacy will act as the first-line legal owner for data, privacy, and information-security legal work. This individual contributor will advise on partner data sharing, privacy opt-outs, FCRA, GLBA/Reg P, and data retention.

What you will do

• Serve as the legal advisor on partner data sharing and document guidance for Data and business teams.
• Advise on privacy opt-outs and suppression obligations.
• Provide practical FCRA guidance regarding credit reports and sharing outcomes.
• Advise on GLBA / Regulation P and consumer privacy notices.
• Interpret state privacy laws and automated-decision-making / AI requirements.
• Own data retention and deletion guidance and support the record-retention policy.
• Partner with Security and GRC on information-security risk assessments and incident response.
• Provide product counseling to Product and Engineering on new features.
• Coordinate with Compliance on regulatory interpretation and exam preparation.
• Translate complex requirements into actionable guidance for cross-functional partners.

Required qualifications

• J.D. from an accredited law school
• Active membership in good standing with at least one U.S. state bar
• 4 to 8 years in data privacy law
• Demonstrated expertise in GLBA/Regulation P, FCRA, and state privacy laws including CCPA, and consumer financial regulation
• Experience in financial services, fintech, or a high-growth startup environment
• Working knowledge of FCRA and GLBA / Regulation P
• Familiarity with state privacy laws (CCPA/CPRA and newer state regimes) and their practical application to data sharing and product
• Experience advising on data-sharing arrangements, privacy notices and opt-outs, and data retention
• Strong contract review skills, including data sharing agreements, DPAs, and regulatory-facing documentation
• Comfort partnering with security and information-security teams on vendor risk assessments, data protection, and incident response
• Ability to work autonomously, own work end-to-end, manage competing priorities, and deliver clear legal guidance under tight timelines
• Strong communicator able to explain legal risk to engineers, analysts, and business leaders

Nice to have

• Privacy certification (e.g., CIPP/US)
• Experience with FCRA in a lending or credit context, ECOA/Reg B adverse action, and automated decision-making / AI governance (e.g., state ADMT laws)
• Familiarity with data-security frameworks (PCI DSS, SOC 2, NIST) and breach/incident-response processes
• Familiarity with additional consumer finance regulations (TILA/Reg Z, EFTA/Reg E, UDAAP, CAN-SPAM, TCPA)
• Experience in sponsor bank, banking-as-a-service, or fintech partnership environments
• Experience with GDPR applicability and ROPA obligations
• Experience working in a ticketing or project management system (e.g., Linear, Jira, Asana)
• Comfort with legal technology, AI-assisted workflows, and process automation
• Experience with consumer credit products, such as credit cards or buy-now-pay-later
• Experience building or standardizing privacy frameworks across multiple product lines or partner programs

Benefits

• Competitive compensation and equity packages
• Leading configured work computers of your choice
• Flexible paid time off
• Fully covered, high-quality healthcare, including fully covered dependent coverage
• Access to One Medical
• Option to enroll in an FSA
• 20 weeks of paid parental leave for the primary caregiver
• 8 weeks of paid parental leave for all new parents
• Access to industry-leading technology

About the company

Imprint helps the world's best brands grow the lifetime value of their customers through modern credit programs and payments infrastructure. They partner with companies like Crate & Barrel, Rakuten, Booking.com, H-E-B, Fetch, and Shell.