Paradigm Privacy Policy

Paradigm Strategy, Inc. (hereinafter “Paradigm,” “we,” “our,” or “us”) is committed to safeguarding and handling your personal information in a responsible and secure manner. This Privacy Policy (the “Policy”) describes how we process personal information (defined below), including as you use our website located at www.paradigmiq.com, our platforms such as Paradigm Blueprint located at blueprint.paradigmiq.com and Paradigm Reach located at paradigmreach.com, including any content or features available on the website or platforms, any mobile applications, any application programming interfaces owned or operated by Paradigm, or any other websites, pages, features, or content owned or operated by Paradigm (collectively, the “Services”) that hyperlinks to this Policy (the “Services”). If you do not agree with our privacy practices as described in this Policy, please do not access or use our Services.

1. Changes to this Privacy Policy

We may modify this Policy at any time, without prior notice, and changes may apply to any personal information we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with notice if we make any material changes to how we collect, use or disclose your personal information or that impact your rights under this Policy by posting a new notice on our Services page. If you continue to access or use our Services after being provided with the notice of changes, you acknowledge your acceptance of the updated Policy.  If the applicable laws require notice and permission before making such material changes, we will do so.

In addition, we may provide you with real time or “just-in-time” disclosures or additional information about the data handling practices of specific parts of our Services when required by applicable laws. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.

2. Personal Information We Collect

Website and Account Information

Personal information is any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device as defined by applicable law (“personal information”).

In particular, we collect the following categories of personal information:

Demographic Information (Blueprint)

In addition to Website and Account Information, in connection with certain Services, such as the Blueprint platform, you may provide general demographic information regarding your company’s employee population (“Demographic Information”). Demographic Information is not intended to identify individuals. You shall not provide employee names, employee identification numbers, or any other similar unique identifiers within Demographic Information and we reserve the right to delete such information immediately upon receipt.

Demographic Information may include:

Job Applications

If you wish to apply for a job at Paradigm on our Website, you may provide the following information:

3. Sources of Personal Information

a) Information You Provide Us

In connection with the Services, we may ask you to provide these categories of personal information:

• Account Information: When you register for an account, you may provide information that allows us to identify you including your name, email address, password, job title and company name.
• Voluntary Information: You may provide personal information to us by voluntarily completing web forms, participating in polls, sending us an inquiry or customer service request, or contributing to blogs, postings, and other mediums.
• Job Applicant Information: When you submit a job application through our Services, we collect any personal information you provide to us, such as your name, current employment, resume, and cover letter.

b) Information We Collect Automatically

• Usage Information: We collect information about your interactions with the Services, such as the pages or other content you view, and other actions you perform while using the Services. The types of data we collect may include your IP address, access times, hardware and software information, device information, device event information (e.g. crashes, unsuccessful logins, browser type), the web page you’ve viewed or engaged with before or after using the Services, and other relevant information. We may use various tracking technologies to collect such information about your use of our Services. Please refer to the “Cookies and Similar Tracking Technologies” section below for more information.

4. How We Use Your Information

Your personal information can be used for various purposes, including:

1. To Provide Our Services. When you or your company access or use our Services, we may collect certain personal information about you to be able to provide you with our Services.  We cannot provide you with our Services without such processing of your personal information.
2. To Provide You with Customer Support. We process personal information you provide to us and relevant information we already have about you when you contact us for customer support or any other reason (e.g., to answer questions about our services, respond to a dispute, etc.). Without processing your personal information for such purposes, we cannot respond to you or ensure your continued use of the Services.
3. To Provide Secure Services. We are committed to ensuring your personal information is processed securely on our Services. To maintain the security of our Services, we may process your personal information to investigate, detect, prevent, or report fraud, misrepresentation, security incidents or breaches, spam, malware, malicious activities, or other prohibited or illegal activities. In addition, we process your personal information to improve the security of our Services. We cannot provide the Services securely without such processing.
4. To Conduct Product Research and Development. We want to ensure our Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process your personal information to improve, optimize, or expand our Services or features of our Services. We do so by processing information about your use of the Services, any information you provide to us, and by measuring, tracking, and analyzing trends and usage in connection to your use or the performance of our Services. We may take additional security measures when processing your personal information for such purposes, such as by de-identifying your personal information and limiting access to such data. Without processing your information for such purposes, we may not be able to ensure your continued satisfaction when using our Services.
5. To Maintain Legal and Regulatory Compliance. We may be required to process your personal information under certain laws and regulations, such as marketing laws, to mitigate business risk, or as otherwise required by applicable law. We cannot provide the Services to you without such processing.
6. To Send Marketing Communications. If you express interest in our products or services and provide us with your contact information, we may send you marketing communications as permitted by applicable law and your communication preferences. We may send you marketing communications to inform you about our events or our partner events; and to provide you with promotional offers based on your communication preferences. You can opt-out of our marketing communications at any time.
7. To Engage in Marketing Activities. We use information about your usage of our Services and your contact information to provide you with targeted marketing. You can control how we collect usage information about as described in the “Cookies and Similar Tracking Technologies” section of this Policy.
8. For the Purposes for Which You Provide It. We may also use your personal information to fulfill any purpose for which you provide it.

We will disclose to you any other use of your personal information in connection with our Services prior to processing your personal information for such purposes. You may choose not to allow us to process your personal information for any purposes that are not compatible with the purposes for which we originally collected your personal information or subsequently obtained your consent. However, you should be aware that if you choose to limit how we use your personal information, some or all of our Services may not be available to you.

5. How We Share Your Information

We may share your personal information as follows:

1. To Provide the Services. We may share your personal information as necessary for us to contact you about the Services.
2. As Authorized by You. With your authorization, we may share your personal information on your behalf with another person, entity, or as otherwise described to you at the time of sharing. For example, if you request and authorize us to share your contact information with a business partner, we will share such information with them.
3. Third-Party Service Providers. We may use third parties to perform the following types of services on our behalf to facilitate our internal operations and our provision of the Services: IT and security, staff administration and operations, payroll and accounting, customer training, data hosting and analysis, and hiring. The third parties we work with do not have permission to use the information we share with them beyond what is necessary to assist us. We execute agreements with third parties to ensure they use adequate safeguards when processing your personal information in accordance with this Policy
4. Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of Paradigm or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change. As required by law, we will notify you with any choices you may have regarding your personal information when we are engaged in a merger, bankruptcy, or corporate reorganization.
5. Legal Obligations and Safety. We may share your personal information if it is reasonably necessary to:
   1. Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
   2. Comply with requests or investigations by public authorities;

• Comply with applicable laws or regulations;

1. Enforce or apply our policies or the policies of our business partners;
2. Protect the security or integrity of the Services; or
3. Protect the rights, property, or safety of Paradigm, our employees or users, partners and affiliates, or other natural persons.

We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, unless we are prohibited from doing so by public authorities or the law.

6. Cookies and Similar Tracking Technologies

We use cookies and similar tracking technologies to collect information about your use of our Services. Cookies are small files, typically comprised of letters and numbers, that your computer or mobile device saves when you visit certain websites. When you return to the websites that save cookies on your device—or visit other websites that use the same cookies—the websites recognize such cookies and your browsing device.

How We Use Cookies. Generally, we use first-party and third-party cookies for the following purposes:

• To make our Services function properly;
• To provide a secure browsing experience during your use of our Services;
• To collect information about your use of our Services to help us improve and optimize our Services; and
• To remember your preferences for your convenience.

Types of Cookies on Our Services. We use the following types of cookies on our Services:

• Strictly Necessary Cookies: These cookies are essential because they enable you to move around and use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
• Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
• Performance or Analytic Cookies. These cookies collect anonymous information about how you use our Services. For example, the cookies will collect information about the pages you view or click on while using our Services or if you get an error message from certain pages. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.
• Advertising or Marketing Cookies. These cookies allow us to deliver relevant marketing and advertisements to you. They collect information about your interactions with our marketing activities (e.g., on the website or via emails) to determine what your interests and preferences are, and how effective such advertising or marketing campaigns are.

How to Manage Cookies. Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:

• First-Party (or Paradigm’s) Cookies: You can enable, disable, or delete cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Services, and/or parts of the Services may not work properly for you. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
• Third-Party Cookies: You can disable cookies from third parties by using your browser settings or, if available, directly opting-out of cookie collection with the third-party cookie service provider via their website.

7. Your Choices

You have certain choices about the way we use or handle your personal information, including:

• Voluntary Information: You may choose not to provide us with some of your personal information. For example, you are not required to submit an inquiry form to us or complete any survey we send to you. In some instances, you may be able to edit your answers to forms, surveys or features you submit to us.
• Communication Preferences: If you do not want to receive marketing emails from us, please adjust your communication preferences or click the unsubscribe link within the email you received from us.

8. How We Secure Your Information

Paradigm employs commercially reasonable physical, administrative, and technical safeguards to help protect and secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

You should be aware that, unfortunately, no system can be 100% secure. Although the security of your personal information is our highest priority, there will always be a risk that your personal information gets compromised. We also depend on you to keep your information secure by ensuring you access our Services via secure connections and taking other precautionary measures. Please notify us immediately at privacy@paradigmiq.com if you become aware of any unauthorized access to or use of your personal information.

9. Transfers of Your Information

When you access or use our Services, your personal information may be processed in the United States or any other country in which Paradigm, its affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

If you are located in the European Economic Area or Switzerland, please refer to the section below entitled, “Notice to Individuals in the European Economic Area, Switzerland and UK”.

10. How We Retain Personal Information

We generally retain your personal information for as long as necessary to fulfill the purposes of collection or to comply with applicable law. Otherwise, we will try to delete your personal information upon your request or when we no longer need it for the purposes it was originally collected, if your state or country of residence provides requires such. We will not delete any personal information that also relates to other individuals, unless such other individuals also wish to delete their personal information at the same time.

We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.

• Usage and Cookie Data. We collect information about your interactions with our Services and we may store such information for the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.
• Marketing Data and Communications. Any contact information you provide to us for marketing purposes, such as your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. Thereafter we will add your contact information to our do-not-contact list to respect your unsubscribe request.

11. Privacy Rights

If you are a U.S. resident, your state of residence may provide you certain rights regarding your personal information, including:

• Right to Know and Data Portability: The right to know what personal information Paradigm has about you and the right to access and request a copy of such personal information.
• Right to Delete: The right to request the deletion of your personal information.
• Right to Opt Out: The right to opt out of the sale or sharing of your personal information or use of your personal information for targeted advertising.
• Right to Correct: The right to correct inaccuracies in personal information about you.

To exercise any privacy rights provided by your state of residence, please contact us at privacy@paradigmiq.com. Please note that certain employment information (e.g. job title, job level, department, functional group, etc.) may require administrator approval. If you wish to change employment information, please contact the administrator for your account.

Your state of residence may also permit you to ask us for a notice that identifies the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If your state provides you these rights and you would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Us” section.If you are an EEA, Switzerland or UK resident please see “Notice to Individuals in the European Economic Area, Switzerland and UK” section.

12. Third Party Links On Our Services

You may find links to other websites, third party applications, and widgets on our Services that we do not own or control (“Third Party Links”). Paradigm is not responsible for the content on Third Party Links, nor do we endorse or review the privacy practices of such websites. Please read the privacy policies of such Third Party Links to understand how your personal information will be handled before using their websites or services.

13. Do-Not-Track Signals

Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

14. Children’s Personal Information

Our Services are not for or directed towards children. We do not knowingly or intentionally collect personal information from minors, which we consider to be under the age of 13 or the equivalent age as specified by applicable law in your jurisdiction.

If we learn that we have collected personal information from a child, we will remove that information immediately and delete it (subject to applicable law). Please contact us if you believe we have collected personal information about a child without consent from their parent or guardian so we can take action to prevent such access and to delete their information from our Services.

15. Nevada Privacy Rights.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@paradigmiq.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

16. Notice to Individuals in the European Economic Area, Switzerland and the UK

This section only applies to individuals using or accessing our Service while located in the European Economic Area, Switzerland or the United Kingdom (“UK”) (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.

Our Relationship to You. Paradigm is a controller with regard to any personal information collected from individuals directly. A “controller” is an entity that determines the purposes for which and the manner in which any personal information is processed.  Paradigm is a data processor with regarding to any personal information it processes at the request of a data controller.

Legal Bases for Processing Your Personal Information.  For personal information collected about you in the EEA, Switzerland and the UK, we set out below, in a table format, a description of the ways in which we use your personal information and the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests in processing your personal information.

We may process your personal information for more than one legal basis depending on the specific purpose for which we are using your personal information. Please contact us at privacy@paradigmiq.com. If you need details about the specific legal basis we are relying on to process your personal information where more than one ground has been set out in the table below.

Individual Rights. If the processing of your personal information is subject to the EU, Swiss or UK GDPR, the rights available to you depend on our reason for processing your personal information.  Your rights may include:

• Access: You have the right to ask us for copies of your personal information subject to applicable exemptions, which means you may not always receive all the personal information we process.
• Rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete personal information you think is incomplete. Note, however, that we may need to verify the accuracy of the new information you provide to us.
• Erasure/deletion: You have the right to ask us to delete or erase your personal information in certain circumstances. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Restriction of processing: You have the right to ask us to restrict the processing of your personal information under the following circumstances: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Right to object to processing: You have the right to object to processing if we are processing your personal information where the processing is in our (or those of a third party’s) legitimate interests. In some cases, we may refuse to comply where we can demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms and where the processing is for the establishment, exercise or defence of legal claims.
• Profiling: The right not to be subject to a decision based solely on automated processing, including profiling.
• Data portability: Where you have provided us with personal information you have the right to ask that it be given to you or transferred to another organization. Note this right only applies when our processing of your personal information is carried out by automated means and based on your consent or performance of a contract with you.
• Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you are unhappy with any aspect of our processing of your personal information.

For residents of France and Germany, you can send us specific instructions regarding the use of your data after your death.

You are not required to pay any charge for exercising your rights. These rights will be exercisable subject to limitations as provided for by GDPR.

Any requests to exercise the above-listed rights may be made to privacy@paradigmiq.com.

You can also withdraw your consent at any time where we are relying on your consent to process your personal information. Please note that your withdrawal will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Transfer of Your Personal Information. We transfer your personal information subject to appropriate safeguards as permitted under the relevant data protection laws. We rely primarily on the Standard Contractual Clauses as approved by the European Commission to facilitate the international transfer of your personal information collected in the EEA, the United Kingdom and Switzerland (“European Personal Information”), and any onward transfer of such information to the extent the recipients of the European Personal Information are located in a country that the EU, Switzerland or the UK considers to not provide an adequate level of data protection. Please contact us if you would like to learn about the specific transfer security mechanisms we use.

Data retention. We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, our obligations to the Plan Sponsor, and the applicable legal requirements.

17. Further Assurances

You agree to perform, execute, acknowledge, and deliver or cause to be performed, executed, acknowledged, and delivered all such further acts, agreements, and assurances as may reasonably requested by Paradigm or required by applicable privacy laws or regulations.

18. Contact Us

If you have any questions, complaints, or feedback about this Privacy Policy or our treatment of your personal information, please feel free to contact us at privacy@paradigmiq.com.