Overview
THE COMPANY AS A POLICY DOES NOT DISCLOSE ANY CONSUMER OR CUSTOMER NON-PUBLIC INFORMATION TO NON-RELATED THIRD PARTIES OTHER THAN IN CONTROLLED CIRCUMSTANCES AS SPECIFICALLY ALLOWED BY REGULATION S-P.
Paradyme, Inc. and its affiliates (collectively “Paradyme”, “we”, “us”, or “our”) operate internationally providing the www.paradymecompanies.com website and the Paradyme mobile application (hereinafter referred to as the “Service”). Paradyme is committed to ensuring that when we collect and use information about visitors to our websites (as described below) we do so in accordance with applicable data privacy laws.
This privacy notice discloses the privacy practices of Paradyme. This privacy notice applies solely to the information collected by the Service.
The Privacy Policy:
a. provides you information as to how Paradyme collects and processes your Personal Data, through the use of the Service and any data you may provide through the Service, and
b. outlines Paradyme’s duties of transparency under the SEC’s Regulation S-P, California Consumer Privacy Act (“CCPA”) and General Data Protection Regulation (“GDPR”).
We respect your privacy and we know that you care how information that you provide is used, stored and shared. Therefore, the use of Personal Data collected through our Service will be limited to purposes stated under this policy.
This Privacy Policy will inform you about the following:
c. What personally identifiable information is collected from you through the Service, how it is used and with whom it may be shared.
d. Your access to and control over personally identifiable information and how you can correct any inaccuracies in the information
e. Your right to “opt out” of sharing of your personal information with third-parties is protected because Paradyme will share your information only as needed to execute your transactions.
f. Your right to delete your personal information cannot be granted due to legal compliance mandating a 6-year retention of transactions executed on the platform.
g. The security procedures in place to protect the misuse of your information.
h. Use of cookies by our Service
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. We do not sell your personal information. We share your personal information with third-parties, such as banks, escrow company or any regulatory agency for executing business operations, complying with laws and other purposes that are consistent with this Privacy Policy.
By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in Definitions section below.
Definitions
a. Service: Service means the https://Paradyme.com website and the Paradyme mobile application operated by Paradyme, Inc.
b. Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
c. Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
d. Cookies: Cookies are small files stored on your device (computer or mobile device).
e. Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information gets processed. For this Privacy Policy and applicable data protection legislation, the data controller of your Personal Data is Paradyme. You can contact us by emailing operations@paradymecompanies.com.
f. Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
g. Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you. We collect your personally identifiable data when you use Paradyme website, signup or send us an inquiry. Paradyme may share this personal information with its business partners and third-parties for purposes that are consistent with this Privacy Policy.
We collect several different types of information for various purposes to provide and improve our Service to you. We collect your personally identifiable data when you use Paradyme website, signup or send us an inquiry. Paradyme may share this personal information with its business partners and third-parties for purposes that are consistent with this Privacy Policy.
SMS consent and phone numbers will never be shared with third parties or affiliates under any circumstances.
Personal Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally-identifiable information may include, but is not limited to:
a. First Name and Last Name
b. Date of Birth
c. Social Security Number
d. Phone Number
e. Address, State, Province, ZIP/Postal code, City
f. Cookies and Usage Data
g. Email Address
h. Public Address of your digital wallet
i. IP Address
Marketing Communications Preferences
In compliance with the Paradyme Public Communications Policy, we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we store certain information.
A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site. A cookie is also used to identify repeat visitors to our site. Cookies are sent to your browser from a website and stored on your device. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site.
Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site. Cookies may include an anonymous unique identifier. We also use other tracking technologies such as beacons, tags and embedded scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
a. Session Cookies.We use Session Cookies to operate our Service.
b. Preference Cookies.We use Preference Cookies to remember your preferences and various settings.
c. Security Cookies.We use Security Cookies for security purposes.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include but is not limited to information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device this Usage 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, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location (“Location Data”), if you give us permission to do so. We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings
Use of Data
Paradyme, Inc. uses the collected data for various purposes:
a. To provide and maintain our Service
b. To notify you about changes to our Service
c. To allow you to participate in interactive features of our Service when you choose to do so
d. To provide customer support
e. To gather analysis or valuable information so that we can improve our Service
f. To monitor the usage of our Service
g. To detect, prevent and address technical issues
h. To protect unauthorized access to customer information
i. To identity potential intrusion of malicious actors
j. To protect our network from malware intrusion
k. To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Paradyme will never ask you for your private key or passwords. Securing your private keys and your passwords is your responsibility.
Other than what is necessary to fulfill your request and execute business operations of Paradyme we will not share your information with any third party outside of our organization. Use of your information for business operations of Paradyme will include but is not limited to login enablement using third-parties, such as Google, Facebook and Microsoft, banks, escrow agency, regulatory compliance, verification of identity, development and improvement of our products, services content and advertising, loss prevention and anti-fraud purposes.
As part of our compliance with regulatory requirements the information that you provide will be used for validation against anti-money laundering databases.
You will need to provide the public address of your digital wallet to us in order for us to offer you our Service.
Unless you ask us not to, we may contact you via email in the future to tell you about our products or services, or changes to this privacy policy.
Your Access to And Control Over Your Personally Identifiable Information
By changing your preferences on the Paradyme website, you can do the following at any time:
a. See what data we have about you, if any.
b. Correct any data we have about you.
c. We cannot grant your request for deletion of your data, since we have to maintain historical transaction records for six years in compliance with SEC regulations.
d. Express any concern you have about our use of your data.
Also, you may opt out of any future contact from us at any time.
Your Requests for Opting Out and Deletion of Your Personal Data
We do not share your personal information with third-parties beyond what is necessary for our business operations and other purposes consistent with this privacy policy. We may send you newsletters, information about website upgrades and new products through emails. You can opt out of these communications by clicking on the unsubscribe link at the bottom of these communications.
We will not be able to comply with your request for deletion of your personal data due to following restrictions:
a. personal data of an investor or borrower must be retained for a period of six years per SEC regulations;
b. data related to an investor or borrower who is participating in an issue of unregistered securities must be retained for a period of six years per SEC regulations.
Refusal to Provide Necessary Personal Data
We require your Personal Data:
a. to provide the products and services contracted by you or your organization
b. to further a professional relationship, venture, or other collaboration, or
c. to comply with applicable law or regulation.
Where you fail to provide that data when requested, we may not be able to provide our products and/or services to you or your organization or to collaborate with you or your organization.
Security Procedures in Place to Protect the Misuse of Your Information
Wherever we collect sensitive information (such as date of birth), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and by looking for “https” at the beginning of the address of the Web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally-identifiable information. The computers/servers, in which we store personally- identifiable information, are kept in a secure environment behind a firewall.
Legal Basis for Processing Personal Data under the GDPR
If you are from the European Economic Area (EEA), Paradyme’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Paradyme, Inc. may process your Personal Data because:
a. We need to perform a contract with you
b. You have given us permission to do so
c. The processing is in our legitimate interests and it is not overridden by your rights
d. For payment processing purposes
e. To comply with the law
Retention of Data
Paradyme, Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data for a minimum of 6 years to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Paradyme, Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or when we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, 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 from those of your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Paradyme, Inc. will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Under certain circumstances, Paradyme, Inc. may be required to disclose your Personal Data:
a. Business Transaction: If Paradyme, Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
b. Disclosure to Law Enforcement: if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
c. Disclosure for Legal Reasons: Paradyme, Inc. may disclose your Personal Data in the good faith that such action is necessary to:
i. Comply with a legal obligation
ii. Protect and defend the rights or property of Paradyme, Inc.
iii. Prevent or investigate possible wrongdoing in connection with the Service
iv. Protect the personal safety of users of the Service or the public
v.Protect against legal liability
d. Service Providers: We may employ third party companies and individuals (“Service Providers”) to facilitate our Service. These provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. These service providers include, but are not limited to the cloud platform that hosts Paradyme’s technology infrastructure, escrow services agency responsible for holding investors’ payments until conditions specified in the debt agreement for release of funds to the issuer are met and call center services, which support users of the Paradyme platform.
e. Professional Advisors: We may share your Personal Data with our auditors, lawyers or other professional advisors so they can support our business. Like the other service providers, these professional advisors are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them
Security of Data
We have reasonable and appropriate security measures (including technical and organizational measures) in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you. However, there is no guarantee, and we cannot guarantee, that information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. When you submit information to us, you should be aware that your information is transmitted across the Internet and that no method of transmission over the Internet is completely or 100% secure.
California Online Protection Act (CalOPPA)
Do Not Track
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Disclosure Information
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data about you by Paradyme to third parties for the third parties’ direct marketing purposes. Paradyme does not share your personal data with third parties for direct marketing. If you would like to confirm if we have shared your data for direct marketing, please send an email to: operations@paradymecompanies.com.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Paradyme, Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
Please contact us if you wish to be informed about what Personal Data, we hold about you and if you want it to be removed from our systems. Removal of your data will be subject to legal, regulatory and business operations-related exceptions as outlined in this privacy policy.
In certain circumstances, subject to legal, regulatory and business operations-related exceptions outlined in this privacy policy, you have the following data protection rights:
a. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
b. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
c. The right to object. You have the right to object to our processing of your Personal Data.
d. The right of restriction. You have the right to request that we restrict the processing of your personal information. However, with such a request Paradyme will not be able to process your transactions.
e. The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. You can find this information in the profile section of your Paradyme dashboard.
f. The right to withdraw consent. You also have the right to withdraw your consent at any time where Paradyme, Inc. relied on your consent to process your personal information. However, with such a request Paradyme will not be able to process your transactions.
g. The right to complain to a Data Protection Authority about our collection and use of your Personal Data.
Please note that we may ask you to verify your identity before responding to such requests.
For more information, please contact your local data protection authority in the European Economic Area (EEA).
Analytics
We may use third-party service providers to monitor and analyze the use of our Service. Such service providers will have access to anonymized service usage data, including but not limited to, location, device, browser, operating system, language and time of visits.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:https://policies.google.com/privacy?hl=en
Google Analytics engine will drop a cookie in the user’s browser and use it to track every interaction that the user performs on the Paradyme website. Google Analytics collects detailed interaction information, including but not limited to, the language of the user’s browser, name and URL of the page the user is viewing, user’s device and screen resolution, operating system, IP address, Internet service provider, country and city.
Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. Our Service will identify the payment processors that we use.
We will collect payments using USDC. Prior to receiving a payment from you we will validate the public address of your digital wallet and store the public address in our database. Paradyme will not share your digital wallet ownership information with business partners beyond what is necessary to execute payment transactions.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click 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.
Children’s Privacy
Our Service is not intended for use by anyone under the age of 18 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you become aware that your Child has provided us with Personal Data, please contact us immediately at operations@paradymecompanies.com.
If we discover that we have inadvertently collected Personal Data from a Child without verification of parental consent, we will take steps to delete that information from our servers. To request the removal of your Child’s Personal Data, please send an email to operations@paradymecompanies.com. You may be required to verify your identity as the parent or legal guardian before we process your request.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
We will update registered users initially and annually by email regarding this privacy policy.
Contact Us
If you have any questions about this Privacy Policy, please contact us by email at operations@paradymecompanies.com.
If you feel that we are not abiding by this privacy policy, you should contact us immediately via email at operations@paradymecompanies.com.
