What Information Do We Collect?
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.
When you create an account on the Services, including registering for a Paragon One Membership (an “Account”), you will provide information that could be Personal Information, such as your username, password, contact information (e.g., email address, phone number and mailing address), demographic information, academic information and short questionnaire responses. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services. You may unsubscribe from some these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.
IP Address Information and Other Information Collected Automatically:
· Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site and users of the Services. We may use this data in aggregate form, that is, as a statistical measure, or in other anonymous forms, but not in a manner that would identify you personally. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
· We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
· We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.
We may communicate with you via email, and we may collect information regarding such communications, such as confirmation when you open an email. We use this information to improve our Services, including without limitation our customer service.
Information Collected Using Cookies:
· Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.
We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.
How, and With Whom, Is My Information Shared?
Information Shared with Advisors and Career Guidance Counselors:
We may share Personal Information with advisors and career guidance counselors (“Advisors”) in order to provide products or services to you. Unless we tell you differently, our Advisors do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us and you. You hereby consent to our sharing of Personal Information with our Advisors.
Public Information About Your Activity on the Services:
Some of your activity on and through the Services is public. This may include, but is not limited to, content you have posted publicly on, through or in connection with the Services.
Please remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.
IP Address Information:
Information You Elect to Share:
Aggregate and Non-Personally Identifiable Information:
We share Aggregate Information with our partners, service providers and other persons with whom we conduct business (“Business Partners”). We may also share information with our Business Partners that is (i) not Personal Information or (ii) derived from Personal Information but has been anonymized so that it is no longer personally identifiable (collectively with Aggregate Information, “Non-Personal Information”). We use and share this type of data so that we and our Business Partners can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Business Partners may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.
Email Communications with Us:
As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account.
User Profile Information:
User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.
Information Shared with Our Service Providers:
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Service Providers”). We may need to share Personal Information with our Service Providers in order to provide products or services to you. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers.
Information Disclosed Pursuant to Business Transfers:
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
Information Disclosed for Our Protection and the Protection of Others:
Information We Share With Your Consent:
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
Is Information About Me Secure?
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Additionally, you are responsible for preventing unauthorized access to your Account and Personal Information by protecting your Account credentials.
What Information of Mine Can I Access?
If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 1412 Broadway, Floor 21, New York, New York 10018, US.
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so through the Account settings on the Site. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.
What Choices Do I Have Regarding My Information?
· You can always opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our features.
· You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email@example.com]. We will make every effort to resolve your concerns.
Effective Date: [August 22, 2018]