Paragon Intel Privacy Policy

Effective Date: 08/19/2024

This Privacy Policy describes how Paragon Advisors Corp., together with our subsidiaries and affiliates, whether doing business as Paragon Intel, Paragon Advisors Corp., or otherwise (“Paragon” or “we” or “us”) collects, uses, and discloses personal information in connection with our websites paragonintel.com, and www.managementtrack.com (collectively, the “Sites”) and the products and services we provide through the Sites (collectively, the “Services”). 

Our Services that involve personal information consist of reports on C-suite executives (e.g., Chief Executive Officers, Chief Operating Officers, and Chief Financial Officers) of publicly traded companies.  The reports feature details about the executives’ historical professional performance (as reflected by their employers’ financial performance), as well as details relevant to their management approach.  Our customers, who are major investors, use these reports as part of their investment decision-making processes.   These customers include asset managers responsible for managing the funds of pensions and for making other investment decisions that support millions of families.   Our reports are thus highly relevant to a matter of significant public concern.

TABLE OF CONTENTS

  1. Information We Collect
  2. Use of Information
  3. Disclosure of Information
  4. Your Rights and Choices
  5. International Data Transfer
  6. Data Retention
  7. Protection of Information
  8. Updates and Changes to This Policy
  9. Contacting Us

1. INFORMATION WE COLLECT

We collect the information described below.

a. Information about C-Suite Executives of Publicly Traded Companies

Our reports contain the following information:

  • Publicly available information about the financial performance of current and prior employers of the executive (such as from SEC filings of the company at which the executive previously was a C-suite officer);
  • Other publicly available information about the executive (typically from government records);
  • For some executives, transcripts of our interviews with former colleagues of the executive (but without information that identifies the former colleague); and
  • Our summary or analysis of the information above.

b. Information About Other Individuals

Our customers and other individuals may provide the following types of information to us:

  • Contact information, such as name, company, and contact details;
  • Records of purchases of our Services and of other interactions and with us.

c. Cookies and Other Technology

Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.

d. Information from Third Parties

We may also receive other personal information from third parties, including our service providers, affiliates, and partners such as analytics and advertising partners, payment processors, and publicly available sources.

2. USE OF INFORMATION

We use personal information about executives to provide our reports, which our customers use for their legitimate interest in making investment decisions about the publicly traded companies that employ the executives.

We use the other personal information we collect for the following purposes:

  1. Provide, manage and improve the Services generally;
  2. Process your registration and verify your information;
  3. Customize content, preferences, and advertising on our Sites, across the Internet and elsewhere;
  4. Conduct sales, surveys, and marketing;
  5. Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;
  6. Protect against, identify, investigate, and respond to misuse of the Services or other unlawful behavior;
  7. Address legal requirements;
  8. Establish, exercise, or defend our legal rights; and
  9. Create aggregated information. 

The laws in certain jurisdictions have a concept of the “legal basis” for processing personal information. From the perspective of such laws, in virtually all cases, we process personal information on the ground that it is necessary for our legitimate interests (primarily growing and protecting our business) and for the legitimate interests of our customers in making thoughtful investment decisions.  However, we also engage in some processing on the basis of consent (primarily certain direct marketing activities), and some processing to comply with legal obligations applicable to us.

3. DISCLOSURE OF INFORMATION

We disclose personal information as follows:

  • To our customers:  Our Services include the provision of reports about executives to our customers. 
  • To vendors and service providers: We disclose information to companies that provide services to us, such as providers that conduct interviews, analyze data, and support activities such as data storage, marketing, analytics, security, and fraud prevention.  We may engage a third party to host or operate any aspect of the Services, including any mechanism through which we send or receive communications, such as our email systems and our Sites.
  • To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Paragon.
  • In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
  • For the protection of Paragon and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
  • In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
  • In other situations: We may also disclose your information in other situations where legally permitted.  

We may use and disclose appropriately aggregated or de-identified information for any purpose.

4. YOUR RIGHTS AND CHOICES

a. Marketing Communications

You can unsubscribe from Paragon marketing emails by clicking the unsubscribe link in a marketing email or contacting us at privacy@paragonintel.com. If you are a customer, you can also limit or change the communications you receive from us by adjusting your email preferences directly through the Services.

b. Cookies and Other Similar Technologies

You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please do so through the pop-up in your browser.

You may also consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari).  If you replace, change, upgrade or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you may need to use this opt-out tool again.

As mentioned above, you may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain websites may not function as expected.

We do not respond to browser-based do-not-track signals.

c. Rights Regarding Your Information

Depending on your jurisdiction and which of its laws (if any) applies to us, you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:

  • Provide you access to or a copy of certain personal information.
  • Correct or update personal information.
  • Delete certain personal information.
  • Restrict or opt you out of certain uses of your information (right to object).
  • Withdraw any consent that you previously provided (without affecting the lawfulness of processing based on consent before the withdrawal takes effect);
  • Provide you with certain details regarding the processing of your information.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information to provide the Services to you, so we can’t delete it while still providing you with the Services.

We may take reasonable steps to verify your identity before responding to certain requests, such as verifying your name and email address. If we are unable to verify your identity in such situations, we may be unable to respond to your requests.

If you wish to exercise any privacy rights, or raise a complaint about our handling of your personal information, please contact us as described at the end of this Privacy Policy.

Depending on which law applies, you may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a legally sufficient authorization, such as signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.  

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You may also have the right to lodge a complaint with a supervisory authority.

5. INTERNATIONAL DATA TRANSFER

We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in this Privacy Policy) operate, pursuant to the laws of such countries. However, this Privacy Policy applies to Paragon’s operations worldwide, and we take appropriate steps for our transfers of information.

6. DATA RETENTION

We keep information until after we determine it is no longer necessary for the purposes described in this Privacy Policy.

7. PROTECTION OF INFORMATION

To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.

8. UPDATES AND CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.

9. CONTACTING US

If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email privacy@paragonintel.com.