Privacy Policy

*This Online Privacy Notice describes the types of personal information WTS Paradigm, LLC along with our affiliates (“Paradigm”, “we”, “our”, or “us”) may obtain through our websites, including www.myparadigm.com and other Paradigm affiliated websites and applications that link to this notice (collectively, the “Site”), how we may use the information and with whom we may share it. The Notice also describes how you can contact us about our privacy practices.

PERSONAL INFORMATION WE OBTAIN

We may obtain the following types of personal information directly from you, automatically through our Site’s interaction with your browser and devices, or from our service providers or third parties, depending on how you interact with us:

• Identifiers, such as name, email address, postal address, IP address, Site login credentials, and online identifiers.
• Personal Records, such as telephone number, or employment.
• Professional or Employment Information, such as your job title, position, and company.
• Internet or other electronic network activity information, such as browser type, operating system type or mobile device model; viewed webpages, links that are clicked websites or apps visited before coming to our Site; the amount of time you spend viewing or using the Site and the pages visited, the number of times you return, or other Site usage data; emails we send that you open, forward, or click through to our Site; type of device (such as laptop or smart phone); and device cookie settings and other device details.
• Geolocation data, such as location data inferred from your device IP address.
• Inferences used to create a profile reflecting the preferences, characteristics, behavior, and attitudes.
• Information Provided through Communications that we have with you.

If you provide us with information about other individuals (such as your references or the principals of your company), you represent that you have notified and obtained consent from the relevant individuals to provide us with their information for the applicable purpose. Please do not provide us with information about third parties unless you have notified them.

HOW WE USE PERSONAL INFORMATION

We may use personal information for:

• Providing Products and Services, such as creating, managing, or servicing your account; operating and maintaining our Site; and creating a Customer Relationship Management (“CRM”) entry.
• Communications, such as sending promotional materials and newsletters; handling requests; contacting you when necessary or requested, including responding to your questions and comments and providing customer support; and obtaining feedback.
• Event and Promotion Management, such as communicating about and administering participation in conferences, special events, programs, promotions, offers, surveys, and market research.
• Site Services, such as making sure our Site and app technology functions, customizing our users’ visits to our Site, delivering content tailored to our users’ interests and the manner in which our users browse our Site, diagnosing technical and service problems, administering our Site, identifying users of our Site, and developing statistics on engagement with our Site.
• Advertising and Marketing, including measuring the use of our services and effectiveness of our advertising and marketing; and uncovering insights to improve our services and provide our users with enhanced features and functionalities, such as personalized experiences.
• Business Operations, such as developing new products and services; enhancing, improving, and analyzing our Site, products and services, customer service, and customer experience; tracking and responding to quality and security issues; performing system administration and technology management, including optimizing our Site; identifying prospective customers, business clients, suppliers, and other vendors; administering our relationships with our customers, business clients, suppliers, and other vendors; fulling purposes that we describe to you at the time we collect your information; carrying out mergers, acquisitions, divestitures, or similar corporate transactions; and performing accounting, auditing, recordkeeping, and other internal functions.
• Security and Integrity, such as protecting the security or integrity of the Site and our business; protecting against, identifying, and preventing fraud and other unlawful activity; complying with and enforcing applicable legal requirements, relevant industry standards and our policies, including our Terms of Use; performing investigations; managing risk exposure, including by identifying potential hackers and other unauthorized users; complying with requests by law enforcement or government authorities; and for other legal and compliance reasons.

We may also use aggregate or deidentified information to perform data analyses including market and consumer research.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following parties:

• Our Family of Brands, including our affiliates, subsidiaries, and other related entities that may process your personal information as described in this Privacy Notice.
• Your Affiliated Company if you interact with us as part of a company account, including with your company’s account administrator.
• Service Providers, Vendors, and Suppliers that we engage to provide services on our behalf, such as support for our Site operations (including third parties we use to process orders on our behalf); electronic mail; product and service delivery; conducting analysis to improve our products, services, and Site experiences; research; digital marketing; advertising; fulfilling orders you place; and responding to questions.
• Contractors, Manufacturers, and Retailers, including businesses with which you interact on the Site to receive estimates, quotes, or other bids related to your projects.
• Business Partners and Other Third Parties where appropriate to provide our services and products and to operate our business.
• Corporate Transaction Partners, including to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, reorganization, dissolution, liquidation, or other transactions involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
• Law Enforcement, Government or Regulatory Bodies, or Other Authorized Parties in order to comply with laws, regulations, subpoenas, court orders, or other legal obligations; assist in investigations; protect and defend our rights and property or the rights or safety of other parties; enforce our Terms of Use, this Privacy Notice, or agreements with third parties; or prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
• Parties with Your Notice or Consent when we have provided specific notice to you or asked for your consent, as applicable.

We may combine your personal information with data we obtain from our Site, our services, other users, or other parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law.

PERSONAL INFORMATION OBTAINED BY AUTOMATED MEANS

Cookies and other Tracking Technologies

We, and vendors acting on our behalf, may use automated means, such as cookies, pixels, and web beacons (referred to as “Cookies”), to collect and analyze information about Site interactions, including internet or other electronic network activity information. We may use Cookies to help the Site function, allow you to access and navigate the Site, recognize your login and preferences, analyze your use of the Site, collect information about how you navigate the Site, customize your browsing experience, and deliver and customize advertisements and track advertising campaigns.

We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. We, and our vendors, may combine the information collected by Cookies with other information collected about you, which may include data we obtain from others.

We also may use web analytics services that collect information to analyze your use of our Site, such as Google Analytics. These services help us analyze how visitors use the Site, help us administer and improve the quality of our Site, and serve ads on our behalf across the internet. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by our vendors.

Interest-Based Advertising

Interest-based advertising (also known as online behavioral advertising) occurs when advertisements are displayed to you based on information collected from your online interactions over time and across multiple websites that you visit, or across multiple devices or online services that you may use. Companies that engage in interest-based advertising use this information to predict your preferences and show you ads that are most likely to be of interest to you.

We, and our vendors, may obtain personal information about your online activities, over time and across different devices and online services.

Some of the content, applications, and tracking technologies on our websites and mobile applications are controlled by other parties, which include ad tech companies (such as Google) or other online service providers that serve interest-based advertisements. These parties may use Cookies and other storage technologies to collect or receive information from our Site and elsewhere on the internet and use that information to provide measurement services as well as for interest-based advertising.

We may use information collected from web analytics services to implement Google advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and impression reporting. For more information on how Google Analytics uses data collected through our Site, visit: www.google.com/policies/privacy/partners/.

We do not control vendors’ collection or use of your information to serve interest-based advertising. However, these parties may provide you with ways to choose not to have your information collected or used in this way, as set out in the Your Choices – Cookies section below. You may still see “contextual” ads even if you opt out of interest-based ads. These ads, however, are based on the context of what you are looking at on the websites and pages you visit. Even if you opt out of interest-based ads you will still receive these non-personalized, contextual ads.

INTERACTIVE FEATURES AND INTEGRATIONS

We may engage vendors to provide certain interactive features on the Site. Your use of these interactive features is voluntary, and we may retain the information that you submit through the features. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

We have implemented Google reCAPTCHA to protect our websites from fraud and abuse. Your use of reCAPTCHA is subject to Google’s Privacy Policy, available at policies.google.com/privacy, and Terms of Use, available at policies.google.com/terms.

While using the Site, you may intentionally interact with providers of external services, apps, tools, widgets and plug-ins, such as third-party Facebook “Like” buttons, which also may use automated means to collect information regarding your interactions with these features. If you use these features, information you post or provide access to may be publicly displayed by the service you use and both Paradigm and the other party may have access to certain information about you and your use of the Site and the external service. This information is subject to the privacy policies or notices of these providers.

We may also offer third-party integrations on the Site. If you choose to connect a third-party account to our system, you should refer to that party’s privacy policy for information on how your personal information is collected, used, and protected.

YOUR CHOICES

Your Account

If you have an account with us, you can log in and update, modify, and delete certain personal information.

Your Communication Options

We offer you certain choices about how we communicate with you. To unsubscribe from our marketing emails, click the unsubscribe link in a relevant email. To submit a request, please contact us as indicated in the “How To Contact Us” section of this Online Privacy Notice.

Cookies

Certain brand Sites offer the opportunity for you to opt out of the use of certain Cookies, including Cookies that may be considered a sale or sharing under California law, by clicking the “Do Not Sell or Share My Personal Information” link in the footer of the Site you are visiting. If you choose to use the Global Privacy Control (GPC) browser signal, brand Sites that offer the opportunity to manage your Cookie preferences will opt you out of certain Cookies, as explained in the Site’s Cookie preference center. You will need to turn GPC on for each browser you use.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Site is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit allaboutdnt.com. You may set your browser to notify you of or decline the receipt of Cookies; however, certain features of the Site may not function properly or be available if your browser is configured to disable Cookies. We are not responsible for opt-out processes provided by external parties.

For more information on how Google Analytics and other Google products use collected data, visit policies.google.com/technologies/partner-sites. To opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout. To adjust your Google advertising settings, visit adssettings.google.com.

You can block the collection and use of information related to you by certain online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the following websites of the self-regulatory programs of which those companies are members:

• The Network Advertising Initiative’s opt-out page is available at optout.networkadvertising.org.
• The Digital Advertising Alliance’s opt-out page is available at optout.aboutads.info

State Privacy Rights

Please see our U.S. State Privacy Notice section for information on consumer privacy rights.

LINKS TO EXTERNAL WEBSITES

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Paradigm. We are not responsible for the content of any websites that are not affiliated with Paradigm, any use of those websites, or the privacy practices of those websites. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites.

SITE VISITORS FROM OUTSIDE THE UNITED STATES

The Site is hosted in the United States. If you are visiting the Site from outside the United States, please be aware that your information will be transferred to, stored, and processed in jurisdictions other than your country of residence, including the United States. The data protection laws of these jurisdictions, including the United States, might not be the same as those in your country.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

U.S. STATE PRIVACY NOTICE

This section provides additional information for residents of states with applicable comprehensive privacy laws (collectively, “Covered States”), including the California Consumer Privacy Act (“CCPA”). In the event of a conflict between any other policy, statement, or notice and this section, this section will prevail as to Covered State residents as required under applicable Covered State privacy laws.

Personal Information We Obtain, Use, and Disclose

We may obtain the types of personal information described in the Personal Information We Obtain section above from offline sources as well. We may also collect:

• Audio, Electronic, Visual, or Similar Information, such as CCTV or audio recordings of customer service calls.

We will use and disclose your personal information as described in the How We Use Personal Information and How We Disclose Personal Information sections above.

If you apply for a position with Paradigm, we may evaluate your application, obtain background and credit information, and contact your references, as appropriate.

Sales, Sharing, and Targeted Advertising

Under certain Covered State privacy laws, a “sale” of Personal Information can refer to disclosing personal information to third parties who may use the information for their own purposes, such as Cookie providers. We do not sell Personal Information for monetary consideration, but we may disclose Personal Information to vendors for cross-contextual behavioral advertising and targeted advertising (collectively “Targeted Advertising”) through Cookies. We may sell and/or share for Targeted Advertising the following categories of personal information through Cookies: Identifiers, Personal Records, Internet or Other Electronic Network Activity, Geolocation Data, and Inferences. We sell or share this information with advertising networks, data analytics providers, and other marketing and advertising vendors. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Your Privacy Rights

If you are a resident of a Covered State, you may have the following rights related to your personal information:

Right to Know, Confirm, and Access. You may have the right to confirm whether we are processing your personal information; access your personal information; and request certain details about the processing of your personal information, including regarding parties to whom your personal information may be disclosed.

Right to Delete. You may have the right to request that we delete personal information we collected from about you, subject to certain exceptions.

Right to Correct. You may have the right to request that we correct personal information we maintain about you that you believe is inaccurate.

Right to Opt Out of Sales, Sharing, and Targeted Advertising. You may have the right to opt out of the sale of your personal information, and to request that we do not share your personal information for Targeted Advertising. Sites that sell and/or share personal information offer a “Do Not Sell or Share My Personal Information” link in the Site footer. To opt out of sales or sharing of your personal information using Cookies, click “Do Not Sell or Share My Personal Information” in the footer of the Site you are visiting. Sites that do not include this link, do not sell or share personal information for Targeted Advertising. If you choose to use the Global Privacy Control (GPC) browser signal, Sites that offer the opportunity to opt out will opt you out of sales, sharing, and Targeted Advertising as explained in the Site’s Cookie preference center. You will need to turn GPC on for each browser you use.

Right to Data Portability. You have the right to request to receive the personal information we hold about you in a portable format.

Rights Related to Profiling and Automated Decision-Making. We do not use personal information for profiling and automated decision making in furtherance of decisions that produce legal or similarly significant effects. For this reason, this right is not applicable.

Right to Appeal. If you have been denied one of the above enumerated rights and you believe it was denied in error, you may have the right to request an appeal.

Submitting Rights Requests

Covered State residents have the right to submit certain requests related to your privacy rights. We will not discriminate against you for exercising any of your privacy rights.

You may submit requests to delete, correct, and know/confirm/access by contacting us via email at [email protected].

You may designate an authorized agent to make a request on your behalf. An authorized agent may submit a request on your behalf using the information listed above.

We will respond to your request in compliance with the requirements of applicable law.

If we deny your rights request and you believe such request was denied it in error, you may appeal for reconsideration of your request by emailing [email protected].

Verification of Your Identity

When you exercise these rights and submit a request to us, we or our partners will verify your identity via standard authentication procedures. For example, we may ask you to log in to your account if you have one with us. If you do not have an account with us, we may ask for your email address, order numbers of previous orders of our products and services, the last four digits of a credit or debit card or a bank account number used to make a purchase, or the date of your last purchase from us. We also may use a third-party verification provider to verify your identity.

Additional California Disclosures

Unless otherwise noted, the disclosures in this section that describe how and why we collect, use, and disclose personal information also describe how we have collected, used, and disclosed personal information in the preceding twelve (12) months.

Record Retention

We may retain your personal information for as long as necessary to fulfil the purpose for which it was collected or a disclosed purpose that is reasonably compatible with the context in which the personal information was collected, to manage our operations, as reasonably required to protect or defend our rights or property, to comply with legal or regulatory requirements, or as otherwise permitted by law.

We strive to retain your personal information no longer than is reasonably necessary to carry out the purposes listed in this Notice or as required by law. Where personal information is used for more than one purpose, we will retain it until the purpose with the latest retention period expires. We retain your personal information in accordance with applicable law and internal document retention practices.  For more information about our retention policies, please contact us using the contact details in the How To Contact Us section.

California Privacy Rights

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, this right is not applicable.

California Privacy Notice at Collection:

• For Job Applicants

UPDATES TO OUR ONLINE PRIVACY NOTICE

This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will notify you of any material changes to our Online Privacy Notice by updating the Effective Date at the top of this Notice.

HOW TO CONTACT US

If you would like to contact us regarding the disclosures or rights in this Online Privacy Notice, please contact us by email at [email protected].