Privacy Policy

Paragon Data Labs, Inc. (PDL) is committed to handling all Personal Information in a manner consistent with all applicable privacy and data protection laws. PDL owns and operates a Public Website as well as Software Solutions that are restricted to authorized users. Respect for the privacy of personal and other information is fundamental to us and reflected in our business practices. This Privacy Policy describes the potential information collected during your interactions with our Public Website or Software Solutions. By using our Public Website and/or Software Solutions, you consent to the collection and use of Personal Information in accordance with this policy.

Information Collected

We use Personal Information to provide services and information that you request and to enhance, improve, operate, and maintain our Public Website and Software Solutions, to prevent fraudulent use of our Public Website and Software Solutions, to tailor your user experience, to maintain a record of our dealings with you, and for other administrative purposes. Some of this information is not personally identifiable, such as information collected automatically through cookies, and other information is personally identifiable, such as information provided when an Employer registers for any of our online services or uses our applications.

We may also use the Personal Information you provide to contact you regarding our Software Solutions and services. We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section of this document.

Information Collected Automatically

PDL may collect site usage information from visitors to our Public Website including information about your browser, domain name, IP address and the web pages you visit while interacting with our Public Website or Software Solutions. Information automatically collected does not personally identify visitors.

Information Provided

In addition to information automatically collected, PDL will also collect information that is provided to us through our Public Website and/or Software Solutions.

Public Website

The PDL Public Website includes options to provide Personal Information to request sales and marketing materials or to schedule a meeting with PDL.

Software Solutions

Our enterprise Software Solutions streamline employee compliance for financial services firms. Access to our Software Solutions is restricted to authorized users of our Clients with whom we have an ongoing contractual relationship. Clients determine what data is collected, how it is updated, how it is tracked and how long it is held. Prior to sharing any data, the Client and PDL enter into agreements that govern the use, confidentiality and security of the data. Data collected is used exclusively to support the business requirements of the client and their Registered Users. Information collected may include your name, email address, brokerage account number(s) and associated holdings, as well as other information required by the client to ensure your compliance with their Employee and Covered Party requirements. Information collected may be submitted by you, by the client, or by Brokers. In order to carry out our services and ensure client requirements we may view transactional information in the brokerage accounts disclosed by you or the client. PDL is not responsible for the accuracy of the information provided to us by you, by the client, or by Brokers.

Email Contact

If your email address is provided through the Public Website, or if you send us an email or request information, PDL will retain your contact information and use it to respond to your inquiry. We may also use your email and contact information for our general business purposes including to notify you about product updates or to provide marketing materials. You may unsubscribe or change your email address for these communications at any time by following the instructions in each such email. If your email address is in our Software Solutions, PDL may use your email address to respond to your inquiries or communicate with you regarding the software solution based on business requirements defined by the client.

By providing Personal Information through our Public Website or Software Solutions you explicitly agree to our collection and use of information provided as described in this Privacy Policy. Additionally, you agree that we may use the Personal Information you provide to contact you regarding our Software Solutions and services. We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section of this document.

Disclosure of Personal Information

PDL does not share, sell, rent, or trade Personal Information about our prospects, clients and clients’ registered users with third parties other than as disclosed within this privacy statement. We will not disclose your Personal Information to third parties without your consent, other than as described in this policy. We may disclose Personal Information to third-party service providers (e.g., data storage and processing facilities) that assist us in our work. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions.

We may also disclose Personal Information if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

Additionally, information about our prospects, users, clients and registered users, including Personal Information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information could be transferred to third parties as one of our business assets.

Cookies

Our Sites use cookies and other similar technologies to help personalize your online experience and to remember you when you return to the site. Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.

If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Alternatively, you can visit www.internetcookies.org , which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device. However, please be aware that doing this may affect your ability to use some applications in the future.

If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

Choice

If you receive a commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this policy.

Other Contractual Relationships

If you enter into a separate contractual relationship with PDL which requires, or contemplates, collecting, using, or sharing information about you in a manner that is different than that which is described in this Privacy Policy, the terms of that agreement will apply.

Links

For your convenience, the Public Website and Software Solutions may contain links to other websites, products or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.

Children

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. We do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent.

International Visitors

Our Public Website and Software Solutions are generally hosted in the United States. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring Personal Information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing Personal Information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.

Security

PDL protects the Personal Information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures that are designed to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any Personal Information or other information. You transmit information to us at your own risk.

Updates to this policy

We will occasionally update this Policy. The use of your information is subject to the Privacy Policy in effect at the time of use. The provisions contained in this policy supersede all previous policies.

Definitions

“PDL” is PDL, Inc. and its subsidiaries in the United States of America.

“Personal Information,” means information that specifically identifies an individual or could be used to identify an individual. Personal information does not include aggregate or other non-personally identifiable information. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

“Public Website” is the publicly accessible website for PDL, Inc. with the following web address:
paragondatalabs.com

“Software Solutions” refers to software developed and licensed by PDL, Inc.

“Client” refers to any entity with whom PDL has an on-going contractual relationship for
Software Solutions.

“Registered User” refers to a user of PDL Software Solutions that has a legal or regulatory
relationship with a Client of PDL. This includes employees, contractors, affiliated persons and
persons covered by business requirements and policies defined by the Client.

“Covered Party” refers to a user or person identified by a user of PDL Software Solutions as
covered by business requirements and policies defined by the Client.

“Brokers” refers to any financial institution or custodian providing information relating to
transactions and account holdings disclosed by a Client Registered User, or Covered Party.

Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or your Personal Information as it relates to this Privacy Policy, please email support@paragondatalabs.com.

Privacy Notice Policy
Last Updated: November 25, 2020