Data Paradigm, Inc.

Privacy Policy

Effective as of June 2, 2020, Data Paradigm, Inc. ("DPI"), has updated its Privacy Policy ("Policy").

  1. Introduction
  2. Scope Of This Policy
  3. Information That You Provide To Us
  4. Information That We Collect From You
  5. Information Collected From Other Sources
  6. How We Use Information That We Collect
  7. Sharing Of Information Collected
  8. International Transfer of Personal Information
  9. Other Important Privacy Information
  10. How to Exercise Your Data Protection Rights
  11. Children's Personal Information
  12. Business Transactions
  13. Supplemental Terms and Conditions for CCPA
  14. Changes To This Policy
  15. Contact Us

1. Introduction

For the purposes of this Policy, the term "Websites" shall refer collectively to www.DataParadigm.com as well as the other websites that DPI operates and that link to this Policy. This Policy describes how DPI collects, uses, shares and secures the personal information that you provide. It also describes your choices regarding use, access and correction of your personal information.

This Policy details our commitment to protecting the privacy of individuals who:

  1. visit our Websites ("Website Visitors") or individuals who request us to contact them via online web forms;
  2. use the products and services which we market for subscription available (the "Service(s)").

DPI is considered a third-party "Data Processor" under the General Data Protection Regulation ("GDPR"), and a "Service Provider" under the California Consumer Privacy Act ("CCPA"), because it acts on the behalf of its customers ("Clients"). It handles its Client's End-Users' (defined below) personal data on behalf of its Clients. Additionally, where the Services are made available to you through a Client of DPI's, that enterprise is the "Data Controller" of your personal information for GDPR and CCPA purposes.

2. Scope Of This Policy

When this Policy applies:

In addition to the Websites that link to this Policy, this Policy applies to the following:

On-demand web or mobile applications utilized in conjunction with some of the Services. If we create a web or mobile application and the application links to this Policy, this Policy applies. If a third party creates an application or service utilizing some of the Services, the privacy policy of the third party applies.

When this Policy does not apply - Third-party websites:

Our Websites may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

When this Policy does not apply - Service Data:

With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications or other materials submitted to and stored within the Services by our Clients' ("Service Data"). Service Data security and privacy practices are detailed in and governed by our Contract for Services, Data Protection Agreement, or other applicable agreement between you and DPI relating to your access to and your use of such Services (collectively referred to as the "Service Contract").

Clients of our Services are solely responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as "data subjects") with whom our Clients interact.

We collect information under the direction of our Clients and have no direct relationship with individuals whose personal information we process in connection with our Client's use of our Services. The use of information collected through our Services shall be limited to the purpose of providing the service for which Clients have engaged DPI. If you are an individual who interacts with a Client using our Services (such as a customer, agent, or representative of one of our Clients) and require assistance or would either like to amend your contact information or no longer wish to be contacted by one of our Clients that use our Services, please contact the Client that you interact with directly.

For more information on how DPI protects the Service Data of our Clients, you may refer to our Service Data Protection Policy.

3. Information That You Provide To Us

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an "Account"). We may also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with your Account (an "Agent", "Distributor" or "Personnel" as defined in the Service Contract (collectively defined here as, "End-User")). We base the processing of your personal information on our legitimate interest, to provide you with the necessary functionality during your use of our Service(s).

If you utilize a credit card to pay for Services, a third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

We refer to any information described above as "Account Information" for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including requesting customer support, or otherwise communicating with us. We process your personal information to perform our contract with you for the use of the Websites and the Service(s) and to fulfill our obligations under the Service Contract to you; where we have not entered into the Service Contract with you, we base the processing of your personal information on our legitimate interest to operate and administer the Websites and to provide you with the content you access and request.

Mobile Applications:

When you download a mobile application that uses our Services, we may collect information on the type of device you use, as well as the operating system version, to perform our Service Contract with you.

4. Information That We Collect From You

Cookies and Other Tracking Technologies:

We, and our authorized partners, may use cookies and other information-gathering technologies for a variety of purposes. These technologies may provide us with personal information as well as information about devices and networks you utilize to access the Websites, and other information regarding your interactions with the Websites. For detailed information about the use of cookies on the Websites and how to manage your cookie settings, please read and review our Cookie Policy found at www.DataParadigm.com.

We may use web beacons, tags and scripts on the Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to the Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We may use local storage such as HTML5 and Local Shared Objects ("LSOs," also known as Flash cookies) to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with the Websites and Services. This information includes Internet protocol (IP) addresses as well as browser type, Internet service provider, URLs of referring/exit pages, operating system, date/time stamp of visit, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve the Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them, through various ways including the use of cookies. We may also share aggregated and/or anonymized data about your actions on the Websites with third-party service providers of analytics services. We also use mobile analytics software to allow us to better understand the functionality of the mobile versions of the Services on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

5. Information Collected From Other Sources

Social Media Widgets:

The Websites may include social media features, such as the "Facebook Like" button, and widgets, such as the "Share This" button or interactive mini-programs that run on the Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Services Provided by Third Parties:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through the Websites. For example, we may have access to certain information from a third-party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third-party service, we will access and store your name, email address(es), current city, profile picture URL, and any other personal information that the third-party service makes available to us, and use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services. For example, you may choose to log in to the Services using single sign-in services such as Microsoft Office365/Azure Active Directory or Google.

These single sign-on services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form.

6. How We Use Information That We Collect

General Uses:

We may use the information we collect about you (including personal information, to the extent applicable) in order to perform our obligations under our Service Contract with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications); (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

Legal basis for processing (EEA visitors only):

If you are a visitor from the European Economic Area ("EEA"), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with the Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "Contact Us" section below.

7. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of the Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Contract, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We always obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@dataparadigm.com.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

8. International Transfer of Personal Information

International Considerations

We do not share your personal information with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection laws.

We store personal information about Website Visitors and Clients within the EEA and the United States. To facilitate our global operations, we may transfer and access such personal information from countries in which DPI has operations. Therefore, your personal information may be processed outside of the EEA and in countries which may not provide for the same level of data protection as the EEA.

In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance, by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

DPI has corporate policies in place which guarantee an adequate level of data protection wherever your data is physically kept.

If you are a visitor from the EEA, you can obtain more details on the protection given to your personal information when it is transferred outside the EEA by contacting us using the details set out at Clause 15 below.

9. Other Important Privacy Information

Notice to Account Holders

The Services are intended for use by enterprises. Where the Services are made available to you through a Client of ours, that enterprise is the Data Controller of your personal information. Your data privacy questions and requests should initially be submitted to the DPI Client in its capacity as your Data Controller. DPI is not responsible for its Client's privacy or security practices which may be different than this Policy.

DPI's Clients are able to:
  • restrict, suspend or terminate your access to the Services;
  • access and describe your personal information that you provided to them;
  • access and export your personal information processed by them; and
  • amend your personal information, including your End-User profile.

Data Retention

Where DPI is the Data Controller of personal information (for example, personal information relating to Website Visitors, attendees and individuals who register to use the Services), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with the Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or aggregate it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If your personal information is processed within a Client's Service Data, we will process the personal information for as long as we are instructed to do so by the relevant Client that is the Data Controller of the Client Service Data.

10. How to Exercise Your Data Protection Rights

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.

Correcting, updating and removing your information:

An individual who seeks to exercise their data protection rights with respect to personal information stored or processed by us on behalf of a Client of ours within the Client's Service Data (including to seek access to, or to correct, amend, delete, port or restrict processing of such personal information) should direct his/her query to our Client (the Data Controller). Upon receipt of a request from one of our Clients for us to remove the personal information, we will respond to their request within thirty (30) days. We will retain personal information that we process and store on behalf of our Clients for as long as needed to provide the Services to our Client.

Accessing and updating or deleting your information:

Agents and End-Users have the ability to access, update and delete certain personal information from within the Service. For example, you can access your Agent or End-User profile and make updates to your personal information. In cases where we act as the Data Controller of your personal information, we will provide you with information about whether we hold any of your personal information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Deactivating your End-User account:

If you no longer wish to use our Services, DPI's Client may be able to deactivate your End-User account. First, please contact DPI's Client with your request. If you are a DPI Client and are unable to deactivate an End-User account through your administrator settings, please email privacy@dataparadigm.com.

Request that we stop using your information:

You may request that your personal information no longer be accessed, stored, used and otherwise processed where you believe that a DPI Client or DPI do not have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this Policy. Where you gave us consent to use your personal information for a limited purpose, you can contact us to withdraw that consent. You can also opt-out of our use of your personal information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. Please note that an End-User of a DPI Client should first contact DPI's Client with a request to stop access, storage, use of personal information. If there is delay or dispute as to whether we have the right to continue using your personal information, we will restrict any further use of your personal information until the request is honored or the dispute is resolved, provided the DPI Client does not object (where applicable).

Opt-out of communications:

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the "unsubscribe" link located on the bottom of our marketing emails or you may send a request to privacy@dataparadigm.com. You may opt-out of receiving promotional communications from us by using the unsubscribe link within each email. Even after you opt-out from receiving promotional messages from us, if you are an Agent then you will continue to receive transactional messages from us regarding our Services. You can also opt out of some notification messages in your account settings.

Other data protection rights:

If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to privacy@dataparadigm.com and we will respond to your request in accordance with applicable data protection laws.

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices. Contact details for data protection authorities in the European Economic Area are available at:

11. Children's Personal Information

We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not submit any personal information through the Websites or Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Websites or Services, please contact us at privacy@dataparadigm.com, and we will use commercially reasonable efforts to delete that information.

12. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.

13. Supplemental Terms and Conditions for CCPA

DPI Supplemental Terms and Conditions for California Residents:

The California Consumer Privacy Act ("CCPA"), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.

DPI is both a Business and a Service Provider under the CCPA. The following Supplemental Terms and Conditions applies to information we collect in our role as a Business—this is when we interact directly with you.

When we act as a Service Provider (for example, by providing our services to another company that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a Service Provider, please contact those companies directly.

These Supplemental Terms and Conditions are effective as of January 1, 2020, shall apply only to residents of California, and may be subject to change. The general Privacy Policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have.

Information We May Collect:

We may collect the following categories of information:
  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information
For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the CCPA.

Additional Disclosures:

We do not sell personal information of any individual, including personal information of minors under 16 years of age.

We have disclosed the following categories of personal information for a business purpose in the 12 months prior to this Policy's last update.
  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information
  • Inferences drawn from any of the above information.
We have not disclosed any personal information for valuable consideration in the 12 months prior to this Policy's last update.

Your Rights:

You may have certain rights with respect to your personal information, including:
  • The right to access, including the right to know the categories and specific pieces of personal information we collect;
  • The right to deletion of your personal information, subject to certain limitations under applicable law;
  • The right to request disclosure of information collected;
  • The right to disclosure of information disclosed for valuable consideration; and
  • The right not to be discriminated against for exercising certain rights under California law.
To exercise these rights, please submit a request by emailing privacy@dataparadigm.com. Please be as specific as possible in relation to the personal information you wish to access. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt or notify you if we require additional time.

If you would prefer, you may designate an authorized agent to make a request on your behalf.

Contact:

If you have questions regarding this Policy or about DPI's privacy practices, please contact us by email at privacy@dataparadigm.com, or at:

Data Paradigm, Inc.
Attn: Data Security Officer
1861 Brown Blvd, Suite 217-761
Arlington, TX 76006, United States

14. Changes To This Policy

This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective.

If you do not accept any changes made to this Policy, please discontinue use of the Websites and the Services.

15. Contact Us

If you have questions or complaints regarding this Policy or about DPI's privacy practices, please contact us by email at privacy@dataparadigm.com, or at:

Data Paradigm, Inc.
Attn: Data Security Officer
1861 Brown Blvd, Suite 217-761
Arlington, TX 76006, United States

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