Paradigm

Privacy policy

This Privacy Policy (“Privacy Policy” or “Policy”) applies to the collection and use of Personal Information by Paradigm (“Company,” “we,” “us,” or “our”). It describes the Company's practices regarding the collection, use, and disclosure of Personal Information. This Policy applies to your access and use of any of our websites (the “Site”) or online services on which we post this Policy, when you communicate with us via email, and when you engage with us offline (collectively with the Site, the “Services”). By accessing or otherwise using our Services, you agree to our collection and use of Personal Information as described herein and agree to our Terms of Use.

This Policy does not apply to information we collect about employees, job applicants, and independent contractors, or individuals when acting as representatives (e.g., employees, contractors) of entities with which we do business. This Policy also does not govern the information handling practices of our portfolio companies.

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information.

Personal Information We Collect

We may collect information about you when we provide our Services. We collect information directly from you, automatically when you access our Services, and from unaffiliated parties.

Information You Provide to Us Directly: We may collect information directly from you when you use our Services, request information about our Services, provide us with your information at an event, or when you otherwise voluntarily provide information to us.

Automatically-Collected Information: We and our vendors may use cookies and other technologies for analytics and to improve the Site. These technologies, for example, may allow us to tailor the Site to your needs, track the pages you visit, help us manage content, and compile statistics about usage of our Site. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Site, because the Site may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.

Information We Collect from Third Parties: We may collect information about you or others through our affiliates or through non-affiliated parties. We may also collect information about you from others. For example, users may provide us with information about colleagues or other prospective users of our Services. We may collect information when you communicate with us on social media services such as LinkedIn and Twitter. We may combine information that we collect from you through the Services with information that we obtain from other parties and information derived from other products or services we provide.

The categories of Personal Information we may have collected from these sources include the following:

  • Personal identifiers: Such as name, address, email address, telephone numbers, IP address or other unique identifier, account name and password, and other similar information.
  • Commercial information: Such as transaction data regarding transactions you've made with us.
  • Internet or other electronic activity information: Such as device and browser type, your browsing and search history on our Site, and information regarding your interaction with our Site and our advertisements.
  • Business information: Such as general information about your employment or business, such as a business title, business phone, business email address, business product and service offerings, and other information you provide us when communicating with us.
  • Other information: Such as other information we may collect from or about you, including when you communicate with us for support, product evaluation, dispute resolution, or other issues.
  • Inferences drawn from the Personal Information identified above.

Some of the categories of Personal Information above may also be “sensitive personal information” under the California Consumer Privacy Act (“CCPA”). We may collect the following type of “sensitive personal information”: information you may voluntarily provide that may reveal race/ethnic origin or other protected classifications.

You are not required to provide us with information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

We collect the categories of Personal Information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) third parties such as social media networks.

How We Use Personal Information

We use your Personal Information for business and commercial purposes, including:

  • to provide you with information you request from us,
  • to contact you from time to time with news and other information about the Company, or in response to your inquiries or other requests,
  • to provide and improve the Services,
  • to monitor or improve our Site,
  • for internal business analysis,
  • to prevent fraud, activities that violate our Terms of Use or that are illegal,
  • to protect our rights and the rights and safety of our users or others,
  • to process payments for the Services,
  • to comply with our legal obligations or as permitted by law, and
  • to administer and troubleshoot the Services.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also disclose such data to other parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

When We Disclose Personal Information

Categories of Personal Information that we have disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy are as follows:

  • personal identifiers,
  • financial information,
  • internet or other electronic network activity information, and
  • inferences from the foregoing.

Categories of Third Parties With Which We Shared Personal Information for a business purpose in the 12 months prior to the date of this Policy are as follows:

  • Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our products; provide website hosting; and provide legal and accounting services.
  • Service providers that facilitate transactional services requiring payment information; and provide legal and accounting services.
  • Service providers that provide data security services and cloud-based data storage; host our Site and assist with other IT-related functions; advertise and market our products; and provide analytics information.
  • Service provides that host our Site and assist with other IT-related functions; advertise and market our products; provide analytics information; and provide legal and accounting services.

We may also disclose your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your Personal Information to third parties to help detect and protect against fraud or data security vulnerabilities. We may transfer your Personal Information to a third party in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring. We may disclose or transfer your information to affiliates, portfolio companies, or other related businesses. We may also disclose your information for other reasons and to others with your consent.

Cookies and Other Tracking Technologies

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our Site, we may place a “cookie” or other online tracking devices (e.g. web beacons) that recognize you. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with the Site. We may use cookies or similar tracking technologies to capture information about the use of our Site, including to improve your user experience.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google's Privacy Policy.

State Privacy Rights – California

If you are a California resident, you may have separate rights regarding your Personal Information, in accordance with California law.

California Consumer Privacy Act

The California Consumer Privacy Act (CCPA) gives California residents rights described below with respect to their Personal Information. This Section only applies to you if you are a California resident. It applies to “Personal Information” (as defined by the CCPA) that we collect on or through the Services and through other means (such as information collected offline and over the telephone). It does not apply to Personal Information we collect from our employees and job applicants in their capacity as employees and job applicants.

CCPA Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of Personal Information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your Personal Information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” Personal Information; and the categories of Personal Information we “sell” or “share.”
  • Provide access to and/or a copy of certain information we maintain about you.
  • Delete certain information we maintain about you.
  • Correct inaccurate Personal Information we maintain about you.

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 purposes for which you cannot opt out under the CCPA.

You also have the right to opt out of “sales” and “sharing” of Personal Information. We have not “sold” or “shared” your Personal Information in the 12 months preceding the effective date of this Policy. As our Services are not directed to minors, we do not knowingly “sell” or “share” the Personal Information of children under 16.

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

Exercising Your Rights

To exercise any of the rights above, or to ask a question, contact personnel@paradigm.xyz.

Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination

You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.

Verification of Identity – Access or Deletion Requests

We also will take reasonable steps to verify your identity before responding to a request. For example, we may ask you for identifying information and attempt to match it to information that we maintain about you, which may involve you providing identifying information. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to honor your request. We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.

If you would like to designate an agent to act on your behalf, you and the agent will need to provide us with a power of attorney or your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We may also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

California Do Not Track

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Site does not respond to browsers' “DNT” signals.

Retention of Your Personal Information

The Personal Information we do or will collect, including sensitive personal information, will be retained for as long as necessary to fulfill the purposes of the collection or for legal obligations as set forth in this Privacy Policy. These purposes may include to comply with reporting, legal and accounting obligations.

Personal Information of Minors

The Services are not intended for minors under 16. If we discover that an individual under 16 has provided us with Personal Information, we will delete the Personal Information to the extent required by the Children's Online Privacy Protection Act or other applicable law.

Third Party Websites

Our Site may contain social media buttons or links to third-party websites or services, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those social media platforms or third-party websites. We recommend that you review the privacy policies posted on any platform or website that you may access through our Site.

How We Keep Your Personal Information Secure

We implement and maintain security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Residents

Personal Information collected from you, including via our Site, will be transferred to the United States where the Site is hosted. You hereby consent to the transfer of your Personal Information to the United States as described in this Privacy Policy. Please do not use the Site if you do not agree to the transfer and processing of your Personal Information in the United States, which may not provide the same level of protection for your data as your home country.

Changes to This Policy

We will review and update this Policy periodically. We will notify you of material changes in accordance with applicable law. By continuing to use the Services, you acknowledge the applicability of the updated Privacy Policy. If you disagree with any changes and do not wish your information to be subject to a revised Privacy Policy, you will need to stop using the Services.

Contact Us

If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at personnel@paradigm.xyz.