Paragon Advisors Corp (together with its subsidiaries and affiliates, and whether doing business as Paragon Intel, Paragon Advisors Corp, or otherwise, “Paragon” or “we” or “us”) owns the content available at www.paragonintel.com, www.jettrack.io, www.managementtrack.com, and their affiliated application sites (known as “Sites”). Paragon conducts investigative intelligence on corporate executives, and publishes that content in various formats, including, without limitation, on our Sites, and in written PDF reports.
We have created this consumer privacy policy (this “Privacy Policy”) statement to demonstrate our firm commitment to our clients’ privacy.
The following discloses our practices regarding information collection and use solely for the Sites. By using or accessing the Sites, including, without limitation, clicking any link on the Sites, you agree to be bound by our Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITES.
What kinds of information do we collect?
When you subscribe, become a client, or request information from us (whether through any link on our Sites or otherwise), we collect your first and last names, your e-mail address, your phone number, and your institutional affiliation (the name of the company or firm where you work) (“Personal Information”), as well as other Non-Personal Information (as defined below), such as the business or industry in which such institution operates, and the job title or function of the specific user. By using our Sites, you certify that the information you are providing to us, in any medium, is accurate, is not spam, and is not intended to disrupt, harm, or interfere or tamper with, the operation of our business in any way. We may collect and store other Personal Information, such as your credit card data, when you become a client, the procedure for which is governed by our billing practices, as are described in further detail in our client agreement.
In addition, we may collect, either directly or indirectly using third party analytics engines or providers, non-personally identifiable information, such as, without limitation, certain analytics information from our Sites and our software-as-a-service (“SaaS”) products, including the IP address from which you are accessing the Sites (i.e. your IP host address), the pages that you’ve viewed and the time you’ve spent on each page, your log-in credentials such as your username and password, your browser type, and other such data (all non-personally identifiable data, “Non-Personal Information” and, together with Personal Information, “Information”), and we may aggregate that Information collected in a way that does not identify any individual.
We collect analytics Information when you use our Sites because we are continually working to improve our products and services. In addition to the IP address and username of the individual who is using our Sites, analytics information may include which product, feature, or function on our Sites is being used, the associated service license number and credentials, any Personal Information that may be incorporated into an individual username, the sizes and names of any files downloaded from or uploaded to the Sites within a particular function, product, or feature, as applicable, and potentially other Non-Personal Information required to monitor the functionality of the Sites, its operation, efficiency, and usage data. For example: as of the date this Privacy Policy went into effect, we plan to use Google Analytics as an analytics provider. To learn more about the Google Analytics privacy policy, refer to Google’s Policies and Principles. You may use the Google Analytics Opt-out Browser Add-on to prevent analytics information from being sent to Google Analytics.
Analytics information may also include Non-Personal Information that is part of the data we collect in running tests and internal queries against all user data and the content available on our Sites as a whole, as well as within a specific function, feature, or product available through our Sites, in order to generate usage data. Usage data is aggregated data about a group or category of users, services, features, or products and does not contain your Personal Information. The purpose of the usage data is to help us understand patterns and trends to that end, rather than to allow for the examination of any particular client or user’s Information.
What do we do with that information?
We use your name and e-mail address to send you emails and links to our Sites when new information is published and available for your consumption. We will also send you emails and/or alerts based on your client profile and user settings, as well as preferences that you select and can control within the Sites, relating to information that you’ve indicated is of interest to you. We may use your phone number to contact you, for example to obtain your feedback on our Sites and products, with the goal of improving the quality, utility, functionality, display characteristics, and/or relevance thereof, as well as for billing-related inquiries or other matters relating to your subscription and your subscription details, and any issues about which you contact us. We may also monitor which parts of the Sites you access, which links you click on, both on the Sites and in emails you receive from us, and how long you spend on the Sites; we may use your email address and IP address to those ends, and to run queries, compile usage data, and create reports for our own internal use and study. Our goal is to make the Sites as helpful to you as is possible, and the better we understand your usage patterns and what information is most relevant to you, the easier it is for us to make improvements.
We will never share individual Client data. In the course of business, we work with various third-party service providers and business partners, as well as other individuals and firms. Third-party service providers and business partners may provide application development, hosting, websites, maintenance, back-up, virtual infrastructure, storage, payment processing, analysis, and other services for us. As an unavoidable consequence of providing those services for or to us, these service providers may have access to and/or may process your Personal Information and Non-Personal Information.
Likewise, we reserve the right to access or disclose all Information that we gather as is required by law, for purposes of compliance with our regulatory obligations and/or internal business policies, or to the extent necessary for us to investigate suspected fraud, harassment, willful misconduct, or other breaches of any law, rule, or regulation, or Paragon’s terms of use or other policies.
What if I am using the Sites from outside the United States?
The Sites is maintained in the United States of America. By using the Sites from outside the United States, you authorize the export of your Personal Information to the United States, as well as the storage and use of your Personal Information as is specified in this Privacy Policy and, as applicable, in Paragon’s terms of use (“Terms of Use”).
What are cookies and do you use them?
“Cookies” are pieces of information that may be placed on your computer by a websites in order to facilitate and enhance your communication and interaction with that websites. Many websites use cookies for these purposes. We may use a cookie that says, in substance, “Remember me on this computer,” so that you only have to log in once no matter how many times you access the Sites from a single computer. The purpose of this cookie is to make it more convenient for you to use our Sites. We may use other cookies to customize your visit to the Sites, to make your visit more convenient in other ways, or to enable us to improve or enhance the Sites. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use the Sites, but the removal of the cookies may interfere with some of the Sites’ functionality. We do not use cookies to automatically retrieve any Personal Information from your computer without your knowledge.
What measures do you take to keep my information secure?
The security of your Personal Information is very important to us. We try to provide for the secure transmission of your Information from your computer to our servers by utilizing encryption software. Nonetheless, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Paragon or information stored on the Sites or our servers will be free from unauthorized access by third parties such as hackers, and your use of the Sites demonstrates your express understanding and assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard all Information that we collect. Only those employees or agents of, and service providers to, Paragon who need access to your Personal Information in order to perform their duties are authorized to have access to your Personal Information. All Paragon employees and all third-party service providers who do business with Paragon are subject to confidentiality obligations with respect to non-public information obtained by virtue of these relationships. As noted above, web developers and providers of software services, including, without limitation, CRM systems, to Paragon, may have access to and may store your Personal Information and Non-Personal Information, as is needed to facilitate Paragon’s business operations. Paragon conducts due diligence on third parties with whom it does business prior to engaging them in order to understand the protective measures they take and the policies they have in place in an effort to protect information that belongs to their clients.
What about links to other Web Sites?
As a convenience to you, we may provide links to third-party websites from within our Sites. Paragon is not responsible for the privacy practices or content of any third-party websites. PARAGON SPECIFICALLY DISCLAIMS ANY LIABILITY FOR INFORMATION ON ANY THIRD-PARTY WEBSITES.
How do you handle communications between me and Paragon?
Any communication or material you transmit to Paragon, by electronic mail or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, confidential. However, through the course of business, we will aggregate feedback from Clients to enhance our products.
How do I opt out of receiving any communications from Paragon?
If you wish to opt out of all or certain communications from Paragon, send your unsubscribe or opt-out request to us at legal@paragonintel.com and we will process your request within ten (10) business days. We are not responsible, however, for removing your Personal Information from the lists or records of any third party to whom we have previously transmitted such Personal Information in accordance with this Privacy Policy, such as a business partner, third-party service provider, or advertiser. We will not remove or attempt to remove any Non-Personal Information. If you are a client and you only wish to limit or change the communications that you receive from Paragon, you may adjust your email preferences through the Paragon products.
How will I know if you change this Privacy Policy?
We reserve the right, at our discretion, to change, modify, add to, or remove content from, this Privacy Policy at any time. If, however, at any time in the future we plan to use Personal Information in a way that differs from our current practices, we will post such changes here and give you the opportunity to opt out of the new or different aspects of the Privacy Policy. Your continued use of the Sites following the posting of any changes to this Privacy Policy means you accept such changes.
Is this Privacy Policy the only policy that governs my use of the Sites?
No, we have other policies that govern your use of the Sites, including, without limitation, our Terms of Use, to which you consent and unconditionally agree each time you log into our Sites as a client or subscriber. In the future, we may implement certain other policies, terms, and conditions that will impact your use of the Sites. If you become a client, you will also sign an agreement containing other provisions regarding your use of the Sites.
Whom do I contact if I have any questions about this Privacy Policy?
Please contact us at legal@paragonintel.com.
Effective Date: This privacy policy is effective and was last updated on October 8, 2020.