Paragon Systems - Privacy Policy

This Privacy Policy describes Paragon System’s, hereinafter referred to as Paragon, policies and procedures on the collection, use and disclosure of a User’s information when User uses the Product and Services of Paragon. The Privacy Policy informs User and tells User about User’s privacy rights and how the law protects User.

Paragon uses a User’s Personal data to provide and improve the Product and Services Paragon offers. By using these Products and Services, User agrees to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for User to access Paragon’s Products and/or Services.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to Paragon’s software applications, the software programs provided by Paragon.
Business, for the purpose of CCPA/CPRA, refers to Paragon as the legal entity that collects Users’ (Consumer’s) personal information and determines the purposes and means of the processing of Users’ (Consumers') personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "Paragon", or "Paragon’s" in this Agreement) refers to Paragon IT Services, Inc., 525 Newport Drive, Naples, FL 34114.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the U.S.A. for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on a User’s computer, mobile device or any other device by a website, containing information about the User’s browsing history.
Country refers to: United States
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to Paragon as the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Facebook Fan Page is a public profile named Paragon Systems specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/groups/160403421355284
GDPR refers to EU General Data Protection Regulation.
Paragon refers to the legal entity Paragon IT Services, Inc., the entity that has made the software applications and services available to User.
Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to User such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with the User.

Service refers to the Application or the Website or both.
Service Provider means any natural or legal person who processes the data on behalf of Paragon. It refers to third-party companies or individuals employed by the Paragon to facilitate the Service, to provide the Service on behalf of Paragon, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
User refers to the person or entity that has chosen to access and use Paragon’s software applications or services.
Website refers to Paragon, accessible from http://www.paragonsystems.com
User means the individual accessing or using the Service or application, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR, User can be referred to as the Data Subject or as the User as User are the individual using the Service.

Collecting and Using User’s Personal Data

Types of Data Collected

Personal Data

While using Paragon’s Service, Paragon may ask User to provide Paragon with certain personally identifiable information that can be used to contact or identify User. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Bank account information in order to pay for products and/or services within the Service
Usage Data

When User pays for a product and/or a service via a payment service such as Stripe or Paypal or a bank transfer, Paragon may ask User to provide information to facilitate this transaction and to verify User’s identity. Such information may include, without limitation:

Date of birth
Passport or National ID card
Address
Other information linking User to their Paragon account

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as User’s device Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Paragon’s Service that User visit, the time and date of Users visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When User accesses the Service by or through a mobile device, Paragon may collect certain information automatically, including, but not limited to, the type of mobile device User uses, User’s mobile device unique ID, the IP address of User’s mobile device, User’s mobile operating system, the type of mobile Internet browser User uses, unique device identifiers and other diagnostic data.

Paragon may also collect information that User’s browser sends whenever User visit Paragon’s Service or when User access the Service by or through a mobile device.

Information Collected while Using the Application

While using Paragon’s Application, in order to provide features of Paragon’s Application, Paragon may collect, with User’s prior permission:

Information regarding User’s location
Pictures and other information from User’s Device's camera and photo library

Paragon use this information to provide features of Paragon’s Service, to improve and customize Paragon’s Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on User’s device.

User can enable or disable access to this information at any time, through User’s Device settings.

Tracking Technologies and Cookies

Paragon uses Cookies and similar tracking technologies to track the activity on Paragon’s Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Paragon Service. The technologies Paragon uses may include:

Cookies or Browser Cookies. A cookie is a small file placed on User’s Device. User can instruct User’s browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if User do not accept Cookies, User may not be able to use some parts of Paragon’s Service. Unless User has adjusted User’s browser setting so that it will refuse Cookies, Paragon’s Service may use Cookies.
Web Beacons. Certain sections of Paragon’s Service and Paragon’s emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on User’s personal computer or mobile device when User go offline, while Session Cookies are deleted as soon as User closes User’s web browser. Learn more about cookies on the Free Privacy Policy website article.

Paragon uses both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Paragon

Purpose: These Cookies are essential to provide User with services available through the Website and to enable User to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that User has asked for cannot be provided, and Paragon only uses these Cookies to provide User with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Paragon

Purpose: These Cookies identify if Users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Paragon

Purpose: These Cookies allow Paragon to remember choices User make when User use the Website, such as remembering User’s login details or language preference. The purpose of these Cookies is to provide User with a more personal experience and to avoid User having to re-enter User’s preferences every time User use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify User as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device User use to access the Website. Paragon may also use these Cookies to test new pages, features or new functionality of the Website to see how Paragon’s users react to them.

For more information about the cookies Paragon uses and User’s choices regarding cookies, please visit Paragon’s Cookies Policy or the Cookies section of Paragon’s Privacy Policy.

Use of User’s Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain Paragon’s Service, including to monitor the usage of Paragon’s Service.
To manage User’s Account: to manage User’s registration as a User of the Service. The Personal Data User provides can give User access to different functionalities of the Service that are available to User as a registered User.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services User has purchased or of any other contract with Paragon through the Service.
To contact User: To contact User by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide User with news, special offers and general information about other goods, services and events which Paragon offers that are similar to those that User has already purchased or enquired about unless User has opted not to receive such information.
To manage User’s requests: To attend and manage User’s requests to Paragon.
For business transfers: Paragon may use User’s information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Paragon’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Paragon about Paragon’s Service Users is among the assets transferred.
For other purposes: Paragon may use User’s information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Paragon’s promotional campaigns and to evaluate and improve Paragon’s Service, products, services, marketing and User’s experience.

Paragon may share User’s personal information in the following situations:

With Service Providers: Paragon may share User’s personal information with Service Providers to monitor and analyze the use of Paragon’s Service, for payment processing, to contact User.
For business transfers: Paragon may share or transfer User’s personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Paragon’s business to another company.
With Affiliates: Paragon may share User’s information with Paragon’s affiliates, in which case Paragon will require those affiliates to honor this Privacy Policy. Affiliates include Paragon’s parent company and any other subsidiaries, joint venture partners or other companies that Paragon control or that are under common control with Paragon.
With business partners: Paragon may share User’s information with Paragon’s business partners to offer User certain products, services or promotions.
With other users: when User shares personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With User’s consent: Paragon may disclose User’s personal information for any other purpose with User’s consent.

Retention of User’s Personal Data

The Company will retain User’s Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Paragon will retain and use User’s Personal Data to the extent necessary to comply with Paragon’s legal obligations (for example, if Paragon is required to retain User’s data to comply with applicable laws), resolve disputes, and enforce Paragon’s legal agreements and policies.

Paragon will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Paragon’s Service, or Paragon are legally obligated to retain this data for longer time periods.

Transfer of User’s Personal Data

User’s information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of User’s state, province, country or other governmental jurisdiction where the data protection laws may differ than those from User’s jurisdiction.

User’s consent to this Privacy Policy followed by User’s submission of such information represents User’s agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that User’s data is treated securely and in accordance with this Privacy Policy and no transfer of User’s Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of User’s data and other personal information.

Delete User’s Personal Data

User has the right to delete or request that Paragon assist in deleting the Personal Data that Paragon has collected about User.

Paragon’s Service may give User the ability to delete certain information about User from within the Service.

User may update, amend, or delete User’s information at any time by signing in to User’s Account, if User has one, and visiting the account settings section that allows User to manage User’s personal information. User may also contact Paragon to request access to, correct, or delete any personal information that User has provided to Paragon.

Please note, however, that Paragon may need to retain certain information when Paragon has a legal obligation or lawful basis to do so.

Disclosure of User’s Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, User’s Personal Data may be transferred. Paragon will provide notice before User’s Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, Paragon may be required to disclose User’s Personal Data if required to do so by law or in response to valid requests by public authorities.

Other legal requirements

The Company may disclose User’s Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of User’s Personal Data

The security of User’s Personal Data is important to Paragon but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While Paragon strives to use commercially acceptable means to protect User’s Personal Data, Paragon cannot guarantee its absolute security.

Detailed Information on the Processing of User’s Personal Data

The Service Providers Paragon use may have access to User’s Personal Data. These third-party vendors collect, store, use, process and transfer information about User’s activity on Paragon’s Service in accordance with their Privacy Policies.

Analytics

Paragon may use third-party Service providers to monitor and analyze the use of Paragon’s Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Paragon’s Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

User can opt-out of having made User’s activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

User may opt-out of certain Google Analytics features through User’s mobile device settings, such as User’s device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Payments

Paragon may provide paid products and/or services within the Service. In that case, Paragon may use third-party services for payment processing (e.g. payment processors).

Paragon will not store or collect User’s payment card details. That information is provided directly to Paragon’s third-party payment processors whose use of User’s personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Shopify

Their Privacy Policy can be viewed at https://www.shopify.com/legal/privacy

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

When User uses Paragon’s Service to pay for a product and/or service via bank transfer, Paragon may ask User to provide information to facilitate this transaction and to verify User’s identity.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

Paragon may process Personal Data under the following conditions:

Consent: User has given User’s consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with User and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Paragon is subject.
Vital interests: Processing Personal Data is necessary in order to protect User’s vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Paragon.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Paragon.

In any case, Paragon will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

User’s Rights under the GDPR

Paragon undertakes to respect the confidentiality of User’s Personal Data and to guarantee User can exercise User’s rights.

User has the right under this Privacy Policy, and by law if User are within the EU, to:

Request access to User’s Personal Data. The right to access, update or delete the information Paragon has on User. Whenever made possible, User can access, update or request deletion of User’s Personal Data directly within User’s account settings section. If User are unable to perform these actions User’s self, please contact Paragon to assist User. This also enables User to receive a copy of the Personal Data Paragon hold about User.
Request correction of the Personal Data that Paragon holds about User. User has the right to have any incomplete or inaccurate information Paragon holds about User corrected.
Object to processing of User’s Personal Data. This right exists where Paragon is relying on a legitimate interest as the legal basis for Paragon’s processing and there is something about User’s particular situation, which makes User want to object to Paragon’s processing of User’s Personal Data on this ground. User also has the right to object where Paragon is processing User’s Personal Data for direct marketing purposes.
Request erasure of User’s Personal Data. User has the right to ask Paragon to delete or remove Personal Data when there is no good reason for Paragon to continue processing it.
Request the transfer of User’s Personal Data. Paragon will provide to User, or to a third-party User has chosen, User’s Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which User initially provided consent for Paragon to use or where Paragon used the information to perform a contract with User.
Withdraw User’s consent. User has the right to withdraw User’s consent on using User’s Personal Data. If User withdraw User’s consent, Paragon may not be able to provide User with access to certain specific functionalities of the Service.

Exercising of User’s GDPR Data Protection Rights

User may exercise User’s rights of access, rectification, cancellation and opposition by contacting Paragon. Please note that Paragon may ask User to verify User’s identity before responding to such requests. If User makes a request, Paragon will try Paragon’s best to respond to User as soon as possible.

User has the right to complain to a Data Protection Authority about Paragon’s collection and use of User’s Personal Data. For more information, if User are in the European Economic Area (EEA), please contact User’s local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of User’s Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/groups/160403421355284, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

Paragon uses the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Paragon’s users.

For this purpose, Facebook places a Cookie on the device of the user visiting Paragon’s Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Paragon’s Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

Paragon collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which Paragon may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Paragon, but reflects Paragon’s good faith belief to the best of Paragon’s knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if User provided such personal information directly to Paragon.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with Paragon’s Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA/CPRA's scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Paragon’s Sources of Personal Information

Paragon obtains the categories of personal information listed above from the following categories of Paragon’s:

Directly from User. For example, from the forms User complete on Paragon’s Service, preferences User express or provide through Paragon’s Service, or from User’s purchases on Paragon’s Service.
Indirectly from User. For example, from observing User’s activity on Paragon’s Service.
Automatically from User. For example, through cookies Paragon or Paragon’s Service Providers set on User’s Device as User navigate through Paragon’s Service.
From Service Providers. For example, third-party vendors to monitor and analyze the use of Paragon’s Service, third-party vendors for payment processing, or other third-party vendors that Paragon uses to provide the Service to User.

Use of Personal Information

Paragon may use or disclose personal information Paragon collects for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

To operate Paragon’s Service and provide User with Paragon’s Service.
To provide User with support and to respond to User’s inquiries, including to investigate and address User’s concerns and monitor and improve Paragon’s Service.
To fulfill or meet the reason User provided the information. For example, if User share User’s contact information to ask a question about Paragon’s Service, Paragon will use that personal information to respond to User’s inquiry. If User provide User’s personal information to purchase a product or service, Paragon will use that information to process User’s payment and facilitate delivery.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to User when collecting User’s personal information or as otherwise set forth in the CCPA/CPRA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how Paragon uses this information, please refer to the "Use of User’s Personal Data" section.

If Paragon decides to collect additional categories of personal information or use the personal information Paragon collected for materially different, unrelated, or incompatible purposes Paragon will update this Privacy Policy.

Disclosure of Personal Information

Paragon may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity
Category G: Geolocation data
Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed but reflects Paragon’s good faith belief to the best of Paragon’s knowledge that some of that information from the applicable category may be and may have been disclosed.

When Paragon discloses personal information for a business purpose or a commercial purpose, Paragon enters a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

Paragon may share, and have shared in the last twelve (12) months, User’s personal information identified in the above categories with the following categories of third parties:

Service Providers
Payment processors
Paragon’s affiliates
Paragon’s business partners
Third party vendors to whom User or User’s agents authorize Paragon to disclose User’s personal information in connection with products or services Paragon provides to User

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that Paragon may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Paragon can sell personal information as the term sell is commonly understood. Paragon does allow Service Providers to use User’s personal information for the business purposes described in Paragon’s Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

Paragon has has sold User’s information in the last twelve (12) months for the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity
Category G: Geolocation data
Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact has not sold but reflects Paragon’s good faith belief to the best of Paragon’s knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

Paragon does not knowingly collect personal information from minors under the age of 16 through Paragon’s Service, although certain third party websites that Paragon links to may do so. These third-party websites have their own terms of use and privacy policies and Paragon encourages parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

Paragon does not sell the personal information of Consumers Paragon actually knows are less than 16 years of age, unless Paragon receives affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, User (or User’s authorized representative) may submit a request to Paragon by contacting Paragon.

If User has reason to believe that a child under the age of 13 (or 16) has provided Paragon with personal information, please contact Paragon with sufficient detail to enable Paragon to delete that information.

User’s Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If User is a resident of California, User has the following rights:

The right to notice. User has the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to know/access. Under CCPA/CPRA, User has the right to request that Paragon discloses information to User about Paragon’s collection, use, sale, disclosure for business purposes and share of personal information. Once Paragon receives and confirm User’s request, Paragon will disclose to User:

The categories of personal information Paragon collected about User
The categories of source’s for the personal information Paragon collected about User
Paragon’s business or commercial purposes for collecting or selling that personal information
The categories of third parties with whom Paragon shares that personal information
The specific pieces of personal information Paragon collected about User
If Paragon sold User’s personal information or disclosed User’s personal information for a business purpose, Paragon would disclose to User:

The categories of personal information categories sold
The categories of personal information categories disclosed

The right to say no to the sale or sharing of Personal Data (opt-out). User has the right to direct Paragon to not sell User’s personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Paragon.
The right to correct Personal Data. User has the right to correct or rectify any inaccurate personal information about User that Paragon collected. Once Paragon receives and confirms User’s request, Paragon will use commercially reasonable efforts to correct (and direct Paragon’s Service Providers to correct) User’s personal information, unless an exception applies.
The right to limit use and disclosure of sensitive Personal Data. User has the right to request to limit the use or disclosure of certain sensitive personal information Paragon collected about User, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Paragon.
The right to delete Personal Data. User has the right to request the deletion of User’s Personal Data under certain circumstances, subject to certain exceptions. Once Paragon receives and confirms User’s request, Paragon will delete (and direct Paragon’s Service Providers to delete) User’s personal information from Paragon’s records, unless an exception applies. Paragon may deny User’s deletion request if retaining the information is necessary for Paragon or Paragon’s Service Providers to:

Complete the transaction for which Paragon collected the personal information, provide a good or service that User requested, take actions reasonably anticipated within the context of Paragon’s ongoing business relationship with User, or otherwise perform Paragon’s contract with User.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if User previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on User’s relationship with Paragon.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which User provided it.

The right not to be discriminated against. User has the right not to be discriminated against for exercising any of User’s consumer's rights, including by:

Denying goods or services to User
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to User
Suggesting that User will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising User’s CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of User’s rights under the CCPA/CPRA, and if User are a California resident, User can contact Paragon:

By email: support@paragonsystems.com

Only User, or a person registered with the California Secretary of State that User authorize to act on User’s behalf, may make a verifiable request related to User’s personal information.

User’s request to Paragon must:

Provide sufficient information that allows Paragon to reasonably verify User are the person about whom Paragon collected personal information or an authorized representative
Describe User’s request with sufficient detail that allows Paragon to properly understand, evaluate, and respond to it

Paragon cannot respond to User’s request or provide User with the required information if Paragon cannot:

Verify User’s identity or authority to make the request
And confirm that the personal information relates to User

Paragon will disclose and deliver the required information free of charge within 45 days of receiving User’s verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures Paragon provides will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, Paragon will select a format to provide User’s personal information that is readily usable and should allow User to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

Paragon does not sell personal information as the term sell is commonly understood. Paragon does allow Service Providers to use User’s personal information for the business purposes described in Paragon’s Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

User has the right to opt-out of the sale of User’s personal information. Once Paragon receives and confirms a verifiable consumer request from User, Paragon will stop selling User’s personal information. To exercise User’s right to opt-out, please contact Paragon.

The Service Providers Paragon partner with (for example, Paragon’s analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If User wishes to opt out of the use of User’s personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, User may do so by following the instructions below.

Please note that any opt out is specific to the browser User use. User may need to opt out on every browser that User uses.

Website

If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review User’s privacy preferences and opt out of cookies and other technologies that Paragon may use. Please note that User will need to opt out from each browser that User use to access the Service.

Additionally, User can opt out of receiving ads that are personalized as served by Paragon’s Service Providers by following Paragon’s instructions presented on the Service:

The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform http://www.User’sonlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on User’s computer that is unique to the browser User use to opt out. If User change browsers or delete the cookies saved by User’s browser, User will need to opt out again.

Mobile Devices

User’s mobile device may give User the ability to opt out of the use of information about the apps User use in order to serve User ads that are targeted to User’s interests:

"Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
"Limit Ad Tracking" on iOS devices

User can also stop the collection of location information from User’s mobile device by changing the preferences on User’s mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If User are a California resident, User has the right to limit the use and disclosure of User’s sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

Paragon collects, uses and discloses sensitive personal information in ways that are necessary to provide the Service. For more information on how Paragon uses User’s personal information, please see the "Use of User’s Personal Data" section or contact Paragon.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Paragon’s Service does not respond to Do Not Track signals.

However, some third party websites do keep track of User’s browsing activities. If User are visiting such websites, User can set User’s preferences in User’s web browser to inform websites that User do not want to be tracked. User can enable or disable DNT by visiting the preferences or settings page of User’s web browser.

User’s California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Paragon can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If User'd like to request more information under the California Shine the Light law, and if User are a California resident, User can contact Paragon using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if User are a California resident, User can contact Paragon using the contact information provided below and include the email address associated with User’s account.

Be aware that User’s request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children's Privacy

Paragon’s Service does not address anyone under the age of 13. Paragon does not knowingly collect personally identifiable information from anyone under the age of 13. If User is a parent or guardian and User is aware that User’s child has provided Paragon with Personal Data, please contact Paragon. If Paragon becomes aware that Paragon has collected Personal Data from anyone under the age of 13 without verification of parental consent, Paragon will take steps to remove that information from Paragon’s servers.

If Paragon needs to rely on consent as a legal basis for processing User’s information and User’s country requires consent from a parent, Paragon may require User’s parent's consent before Paragon collects and uses that information.

Links to Other Websites

Paragon’s Service may contain links to other websites that are not operated by Paragon. If User selects a third party link, User will be directed to that third party's site. Paragon strongly advises User to review the Privacy Policy of every site User visit.

Paragon has no control over and assumes no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

Paragon may update Paragon’s Privacy Policy from time to time. Paragon will notify User of any changes by posting the new Privacy Policy on this page.

Paragon will let User know via email and/or a prominent notice on Paragon’s Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

User is advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Paragon

If User has any questions about this Privacy Policy, User can contact Paragon:

By email: support@paragonsystems.com