Privacy Policy

Paradigm Personality 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 Certified
Practitioner.

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 ProfileTM suite, SchoolPlace Big Five ProfileTM 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.

CALIFORNIA DO NOT TRACK DISCLOSURE

At this time, we do not respond to browser ‘Do Not Track’ signals.

CALIFORNIA SHINE THE LIGHT

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites or Services that are
California residents to request certain information regarding our disclosure of personal information to third
parties for their direct marketing purposes. We do not disclose personal information to third parties for their
direct marketing purposes.

OPTING OUT OF COMMUNICATIONS

You may opt out of receiving newsletters, marketing or promotional materials from us by following the unsubscribe
link or instructions provided in the applicable communication or by contacting at engagement@paradigmpersonality.com.

ADDITIONAL PROVISIONS APPLICABLE TO INFORMATION OF CALIFORNIA RESIDENTS

In addition to any other applicable provisions of this Privacy Policy, if you are a resident of California, you may
have additional rights pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). This section
describes those rights and how to exercise them. As used in this section, the term “personal information” has the same
meaning as given to such term in the CCPA.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In addition to the information set forth in the section above entitled “Information that Paradigm Collects ”, the
table below sets forth (a) the categories of personal information we have collected with respect to California
residents, (strong) the sources from which such information was collected, and (c) the business purpose for such
collection, in each case within the last twelve (12) months.

Category of Personal Information Sources of Personal Information Business Purpose for Collection
Identifiers (e.g., name, postal address, online identifiers, IP address, and email address) We collect identifiers from you directly and from Certified Practitioners and Distributors. We use identifiers primarily for providing you with the Services requested, administering your account,
providing support, and performing our Assessment.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) Like identifiers, we collect this information from you directly and from Certified Practitioners and Distributors. We use this information primarily for providing you with the Services requested, administering your account,
providing support, and performing our Assessment.
Protected classification characteristics under California or federal law. As mentioned above, you may provide to us optional demographic information in connection with an Assessment. We use this information primarily for providing you with the Services requested and performing our
Assessment.
Commercial information (e.g., products purchased, obtained or considered, or other purchasing or consuming histories or tendencies) We may collect information regarding your purchases of Assessments and associated payments. We use this information for improving our Services, administering your account, providing support, and for
general business analysis.
Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website. As noted above, we collect this information automatically via cookies, log files and similar technologies. We use this information for improving our Services, administering your account and for general business
analysis.
Geolocation We may collect the region in which users of the Sites and Services are located automatically via cookies,
log files and similar technologies. We may also collect the country of residence in the demographic
questions of an Assessment.
We use this information for improving our Services, administering your account, providing support, and for
general business analysis.
Professional or employment-related information We collect this information from you directly and from Certified Practitioners and Distributors. We use this information primarily for providing you with the Services requested, administering your account,
providing support, and performing our Assessment.

SHARING PERSONAL INFORMATION

We may share your personal information as described above in the section entitled “Disclosure of Information by Paradigm ”.

SALE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we have not sold any categories of personal information.

YOUR RIGHTS UNDER THE CCPA

Pursuant to the CCPA, you have the right to know:

  • the categories of personal information that we have collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting or selling your personal information;
  • the categories of third parties with whom we share personal information (if any); and
  • the specific pieces of personal information that we have collected about you.

In connection with any personal information we may sell or disclose to a third party for a business purpose, you also
have the right to know:

  • the categories of personal information about you that we sold and the categories of third parties to whom such
    information was sold; and
  • the categories of personal information that we disclosed about you for a business purpose.

You have the right to request the deletion of your personal information from our records and those of our service
providers, unless an exception applies under the CCPA.

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
This means we cannot, among other things:

  • deny goods or services to you;
  • charge different prices or rates for goods or services, including through the use of discounts or other
    benefits or imposing penalties;
  • provide a different level or quality of goods or services to you; or
  • suggest that you will receive a different price or rate for goods or services or a different level or quality of
    goods or services.

EXERCISING YOUR RIGHTS

To exercise your rights described above, please submit a request by either:

Your request must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected
    personal information or an authorized representative; and
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the
personal information relates to you. Additionally, if you request specific pieces of your personal information or
the deletion of certain personal information, you may be required to provide a signed declaration under penalty of
perjury and otherwise authenticate your identity.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your
personal information. You may only submit a request to know twice within a 12-month period.

REQUESTS BY AUTHORIZED AGENTS

You are permitted to designate an authorized agent to make a CCPA request on your behalf. Your authorized agent can
use the methods described above to submit the request and will be required to provide proof of authorization.

INDIVIDUALS WITH DISABILITIES

Individuals with a disability may access an alternative format of this Privacy Policy using the contact information
in the section below entitled “Contact Us ”.

ADDITIONAL PROVISIONS APPLICABLE TO INFORMATION OF EU RESIDENTS

In addition to any other provisions of this Privacy Policy applicable to your information, the following additional
provisions apply to information relating to an identified or identifiable natural person residing in the European
Union (“EU Personal Data”) that is subject to the European Union’s General Data Protection Regulation (the
“GDPR”).

LEGAL BASIS FOR PROCESSING

As described above in the section entitled “How We Use Information We Collect ”, we use the information we collect
from you for various purposes. We rely on the following legal bases in connection with our processing of EU Personal
Data:

  • Processing is necessary to provide a service or feature you request. This includes (a)processing, evaluating,
    and respond to your requests, inquiries, and applications; (strong) monitoring compliance with and enforcing any
    applicable terms of service or use; and (c) providing features and functionality of the Sites and Services that
    you use.
  • Processing is necessary to pursue our legitimate interests and we have taken steps to ensure that our
    interests do not unduly intrude on your privacy. We rely on this justification when we (a) monitor aggregate
    Site or Service usage metrics; (strong) analyze the information we collect to improve performance and better
    understand the preferences of our customers; (c) develop and improve our marketing materials, and, where
    permitted, contact you (including with marketing communications); and (d) to protect our legal rights, resolve
    disputes, troubleshoot problems or assist with investigations.
  • Processing is necessary to comply with our legal obligations, such as to meet our record-keeping obligations.
  • Any purpose for which you consent, such as to place cookies on your device or if you agree that we may contact
    you.

Please note that where we rely on consent, you have the right to withdraw your consent to the processing of your EU
Personal Data at any time by providing notice to us using the contact information below in the section entitled
“Contact Us ”.

DATA SUBJECT RIGHTS

You have the right to rectify any of your EU Personal Data that is inaccurate, complete any of your EU Personal Data
that is incomplete, object to our use of your EU Personal Data (including for marketing purposes), request the
deletion or restriction of your EU Personal Data, or request your EU Personal Data in a structured, electronic
format. To make any of the foregoing requests, please contact us using the contact information below in the section
entitled “Contact Us ”.

Your request and choices may be limited in certain cases. For example, if fulfilling your request would reveal
information about another person, or if you ask to delete EU Personal Data which we are permitted by law or have
compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a
data protection authority in the country where you live, where you work, or where you feel your rights were
infringed.

COMPLAINTS

If you have a complaint about our use of your EU Personal Data, please contact us directly so that we can address
your complaint. If you are located in the EEA, you also have the right to lodge a complaint with the competent
supervisory authority.

DATA TRANSFERS

We may transfer EU Personal Data we collect about you to the United States and other countries that do not have the
same data protection laws as the country in which you initially provided such data. In the event we transfer EU
Personal Data outside of the European Union, we will ensure that the country to which we transfer such data has
received an adequacy decision by the European Commission or that such transfer is subject to an adequate transfer
mechanism pursuant to Article 46 of the GDPR.

RETENTION PERIODS

We will retain EU Personal Data for so long as it is reasonably required, and until deletion of such EU Personal Data
is requested. After such time period, we will either delete or anonymize your information or, if this is not
possible (for example, because the information has been stored in backup archives or we are required to retain such
information pursuant to applicable law), then we will securely store your information until deletion is possible.

CONTACT US

If you have any other questions about our Privacy Policy, you can:

  • Email us at privacy@paradigmpersonality.com
  • Call us at +1 704.331.0926
  • Send mail to us at:
    Paradigm Personality Labs
    615 S. College Street, Floor 10
    Charlotte, NC 28202 USA