Privacy Policy

Last Updated: July 25, 2022

Paradigm Personality Labs, LLC (“Paradigm”, “we”, “us” or “our”) takes your privacy seriously. This Privacy Policy (“Privacy Policy”) applies to your access to and use of any of our websites that links to this Privacy Policy, including,  www.paradigmpersonality.com (each, a “Site” and, collectively, the “Sites”), as well as any platforms, applications, or tools made available by us via the Sites or that otherwise link to this Privacy Policy, including the MyParadigm Dashboard (the “Services”). In this Privacy Policy, the words “you” and “your” refer to the individual accessing or using the Sites and/or
Services.

By using the Sites or Services, you expressly consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. Please note that if you access any of our Sites or use our Services: (a) in the scope of your employment or otherwise in connection with responsibilities to your employer, or (strong) in connection with your relationship with a third party distributor authorized by Paradigm (a “Distributor”), then in each case our collection and use of your information may be governed by, and subject to, a separate agreement between us and your employer or such Distributor, instead of this Privacy Policy. You should confirm with your employer or the relevant Distributor whether any such separate agreement exists that governs our collection and use of your information. To the extent there is a conflict between this Privacy Policy and another agreement between us and your employer or the relevant Distributor, as applicable, that agreement shall prevail.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to add to, update or change our Privacy Policy at any time in our sole discretion by posting a new version of this Privacy Policy to the Sites and/or Services. You should check this Privacy Policy for changes each time that you access the Sites and/or use the Services, as your continued use of the Sites and Services after we post any additions, updates or changes to the Privacy Policy will constitute your consent to be bound by the new Privacy Policy. If you do not agree to any addition, update or change to this Privacy Policy, you should not access or use our Sites or Services.

GENERALLY APPLICABLE PRIVACY PROVISIONS

INFORMATION THAT PARADIGM COLLECTS

In connection with your access to and use of the Sites and Services, we may collect the following information (each as further described below):

• information you submit to us (e.g., when taking an Assessment, registering for an account or completing an online form);
• information collected from or submitted by Certified Practitioners and their administrative users;
• information provided by Distributors; and
• information collected automatically.

Information You Submit to Paradigm

If you are a Certified Practitioner (as defined in our Terms of Use), you may provide to us the following information:

• Your name
• Your phone number
• Your email address
• Your postal address
• Your employer’s or organization’s name
• Your job title and the department for which you work
• Your credit card information (e.g., the last four digits of your payment card number)
• Any information you provide to us regarding an End User (as defined below), including the End User’s name and email address

Note that Certified Practitioners may choose to provide “code names” and other anonymized information regarding relevant End Users instead of providing us with the End Users’ name and email address. If you are an End User,please direct any questions regarding information provided by the relevant Certified Practitioner to such CertifiedPractitioner.

If you are invited by a Certified Practitioner to take any of our proprietary personality assessments and behavioral surveys (e.g., the WorkPlace Big Five Profile^TM suite, SchoolPlace Big Five Profile^TM suite, WorkPlace Values Profile, WorkPlace Performance 360) (each, an “Assessment” and, collectively, the “Assessments”), you are an “End User” hereunder and may provide to us the following information:

• Your name
• Your email address
• Answers to questions included in the Assessment

In addition, in connection with an Assessment, you may elect to answer optional research or demographic questions and your answers to such demographic questions will also be collected by us, which may include country, age, title,  education level, and industry.

Our Sites also offer multiple forms that are intended to offer you access to personalized information, sign up for our training programs, order books and ask us questions. Any information provided by you when completing such forms will also be collected by us.

You may always choose not to provide any of the foregoing information to us, but please note that this could prevent you from accessing desired online functionality

Information Provided by Distributors

Paradigm also collects additional information from its Distributors (i.e., Master Trainers). This information includes name, email, and dates of training for certification program participants (i.e., Certified Practitioners). Paradigm does not control this information and uses it primarily to keep a record of all authorized Certified Practitioners.

Information Paradigm Collects Automatically

Paradigm collects certain information from you automatically. This information can include, but is not limited to, your IP address, the type of browser used to access our Sites and Services, pages viewed, the device used to connect to our Sites, and websites from which visitors may have accessed our Sites. This information is used to better understand how our Sites and Services are used and to improve our Sites and Services.

Paradigm automatically receives and stores certain types of information whenever you interact with its Sites and Services. When visiting our Sites, for example, certain data is collected from your web browser and through the web server Paradigm uses. This data may include IP addresses, email address, login information, password, purchase history, computer browser types (e.g., Internet Explorer, Firefox, Chrome, etc.), browser versions, various pages that users are visiting, and URL clickstream related to our Sites, including date and time.

When you access the Services by or through a mobile device, this log data may include information such as the type of
mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use and other statistics.

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information (e.g., browser type, device information, geolocation information) in order to improve our Sites and Services and improve our user experience.

In addition to our own cookies, log files and similar technologies, we may engage third parties (e.g., Google) to use their cookies, log files and similar technologies to report to us usage statistics of the Sites and Services, deliver advertisements on and through the Sites and Services, and for other similar purposes. Google Analytics, for example, uses cookies to track your interactions with our Sites and Services. Google collects information and reports it to us, without identifying individual users. This information helps us improve our Sites and Services so that we can better serve users. For more information on Google Analytics, please visit www.google.com/policies/privacy/partners/.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services.

HOW WE USE INFORMATION WE COLLECT

We may use the information that we collect in order to:

• respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Services;
• provide customer support;
• present and administer the Sites and Services;
• personalize the Sites and Services for you;
• improve the Sites and Services;
• authenticate you when you log in to the Services;
• for the safety and security of you or the Sites or Services;
• prevent, detect and investigate potentially prohibited or illegal activities;
• for internal tracking and optimization efforts;
• conduct internal business analysis, research and development, or other business purposes;
• protect our legitimate business interests;
• send you communications, including marketing communications regarding our Services, news and events, as well as general education pertinent to our areas of expertise; and
• to fulfill any other purpose for which you provide it.

Additionally, we may use the information we collect to create aggregate information, such as de-identified statistics and other performance information related to the Sites or Services. This aggregate information will not identify you personally, and we may use and disclose such information for research, analytics, improving our Sites or Services, and any other legally permissible purposes.

DISCLOSURE OF INFORMATION BY PARADIGM

We disclose information collected by us to third parties as described below:

• when we have your permission to make the disclosure;
• where the disclosure is necessary for the purpose for which the information was obtained;
• to our parent company, subsidiaries and affiliates, joint venturers or other companies under common control with us for business purposes;
• in order to protect against fraud, to protect the property or other of our rights or other users of the Sites or Services, or the public;
• to contractors, third party service providers, or other third parties in order to provide services to us (including third parties that help us operate, provide, improve, integrate, customize, support and market our Sites and Services or that provide us with marketing communications, email delivery, business operations, and payment processing); or
• as otherwise disclosed in this Privacy Policy.

If you are an End User, please note that the Certified Practitioner that ordered your Assessment (and any Distributor
with whom such Certified Practitioner is associated, if applicable) will also receive your information, including the answers to your Assessment. Such Certified Practitioner may also share your information with other Certified Practitioners within the same organization. Distributors are able to access all information, including the answers to Assessments, ordered through any of its customers or clients.

In the event we are acquired by, or merge or consolidate into, another entity, if there is a divestiture, restructuring, or reorganization, or if there is a sale of our assets (including in bankruptcy), your information may be transferred to the entity acquiring us or our assets or that survives the merger or consolidation. You acknowledge and agree that in the foregoing circumstances, your information may be disclosed to such third party.

We may also disclose your information where permitted by applicable law or when the disclosure is necessary, in our sole discretion, for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, in connection with litigation, or to enforce or apply any terms of use or contract.

SECURITY

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from.

INTERNATIONAL TRANSFER

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we may transfer your information to United States and process it.

If you are a resident of California or the European Union, please also review the sections below, as applicable, entitled “Additional Provisions Applicable to Information of California Residents ” and “Additional Provisions Applicable to Information of EU Residents ”.

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.