Paradigm Privacy Policy

Last Modified: August 15, 2019

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 your personal information as you use our website located at, including any content or features available on the website, 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 advanced 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 receiving the notice of changes, you acknowledge your acceptance of the updated Policy.

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. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.

2. Information You Provide Us

Personal information is any information that identifies you or makes you identifiable as defined by applicable law. Any information that is anonymized or aggregated is no longer personal information. In connection with the Services, we may ask you to provide these categories of personal information:

3. 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 (or “pseudonymizing”) 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.

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.

4. How We Share Your Information

We may share your personal information as follows:

  1. 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.
  2. 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
  3. 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.
  4. 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;
    3. Comply with applicable laws or regulations;
    4. Enforce or apply our policies or the policies of our business partners;
    5. Protect the security or integrity of the Services; or
    6. 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.

5. 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:

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

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:

6. Your Choices

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

7. 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 if you become aware of any unauthorized access to or use of your personal information.

8. 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 and Switzerland.”

9. Retention

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. 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.

10. California Privacy Rights

California law permits California residents 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 you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Us” section.

11. 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.

12. 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.

13. Children’s Personal Information

We do not knowingly or intentionally collect personal information from minors. 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.

14. Notice to Individuals in the European Economic Area and Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland (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 data controller with regard to any personal information collected from individuals directly. A “data 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.  We rely on the following legal bases under the European Union’s General Data Protection Regulation in processing your personal information.

Marketing. We will only contact you if you are located in the Designated Countries by electronic means (including email or SMS) or engage in marketing activities based on our legitimate interests, as permitted by applicable law or your consent. If you do not want us to use your personal information in this way, please click the unsubscribe link at the bottom of any of our email messages to you or contact us. You can object to direct marketing at any time and free of charge.

Individual Rights. We provide you with the rights described below when you use our Services.  We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic.  If you would like to exercise your rights under applicable law or if you believe we have infringed or violated your privacy rights, please contact us at so that we may resolve your dispute directly.

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 Standard Contractual Clauses approved by the European Commission to facilitate the international transfer of 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 considers to not provide an adequate level of data protection. In some instances we may  transfers of European Personal Information  to other parties for the performance of a contract between us and another party that we entered into for your interest.

Paradigm participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”), European Economic Area (“EEA”), United Kingdom, and Switzerland to the United States, respectively.. With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, Paradigm is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List at

European data subjects with inquiries or complaints regarding this Privacy Policy should first contact Paradigm at If we are unable to resolved your complaint or dispute arising under the requirements of Privacy Shield, you may refer your complaint under the Framework to an independent dispute resolution mechanism. Our independent dispute resolution mechanism is JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. The services of JAMS are provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at Privacy Shield Annex 1.


15. 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