Last Updated February 2021
Acceptance of Terms
Information We Collect
In the course of operating the Websites and/or interacting with you, we will collect (and/or receive) the following types of information.
1. Personal Information.
When you sign up to receive any of our newsletters, respond to a survey, register for a class, or purchase any product or service, you may be required to provide us with personal information about yourself, such as your name, address, email address, and phone number. We do not collect any personal information from Visitors when they use the Websites unless they provide such information voluntarily, such as by registering or sending us an email or signing up for a newsletter. All information we collect and/or receive under this section is collectively called “Personal Information.”
2. Order Information.
When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase. Such information is collectively called the “Order Information.”
3. Billing Information.
4. Other Information.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
a. From You. Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as household income range, gender, product and service preferences, and other information that does not identify you personally.
b. From Your Activity. Information that we automatically collect when you use the Websites, including, without limitation:
• IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
• Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
c. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Websites. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Websites may not function properly.
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites.
e. From Other Sources. We also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.
Information Collected by or Through Third-Party Advertising Companies
Accessing and Modifying Personal Information and Communication Preferences
If you have registered for the Websites, you may access, review, and make changes to your Personal Information, Billing Information, and certain Other Information by following the instructions found on the Websites. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Paragon Road marketing email. Customers cannot opt out of receiving transactional emails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner.
How We Use and Share the Information
We use the Personal Information, the Order Information, the Billing Information, and the Other Information (collectively, the “Information”) to provide our services; to process Orders; to administer our rewards and promotional programs; to maintain and improve our Websites and services to you; to solicit your feedback; and to inform you about our products and services and those of our third-party marketing partners.
We may also use and/or share Information as described below:
• Paragon Road will access, use, and share the Information as required to process your Orders and provide support to you.
• In order to provide our services and administer our rewards and promotional programs, we may share the Information (excluding the Billing Information) with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
• With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
• We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, Order fulfillment, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
• In an ongoing effort to better understand our Visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
• We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
• As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
• To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Paragon Road or others.
Information You Share
Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example on message boards or web logs; through email; during webinars, classes, telephone conferences, or coaching calls; or in comment or chat areas — that information can be seen, collected, heard, and/or used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore take special care in deciding what information you send to us via email.
Important Notice to Non-U.S. Residents
GDPR Visitor Rights
Under the GDPR, if you are within the European Union, you are entitled to certain rights and information listed below.
We will retain any information you choose to provide to us until the earlier of:
- You ask us to delete the information by sending a request to email@example.com.
- Please note that such requests may result in you no longer being able to access paid or free content previously provided to you.
- Our decision to cease using our existing data providers.
- The Company decides to no longer be in business or continue to offer the services.
- The data is no longer needed to provide you service, is too costly to maintain further retention, or the Company finds it outdated.
You have the right to request access to your data that we store and have the ability to access your personal data.
You have the right to either rectify or erase your personal data. You have the right to verify the accuracy of your personal data and have it corrected or removed completely.
You have the right to seek restrictions on the processing of your data. When you restrict the processing of your data, we can store your data but cannot process it further.
You have the right to object to the processing of your data in certain circumstances including but not limited to direct marketing, profiling, scientific or historical research purposes, statistical purposes, automated decision making and profiling and tasks based on legitimate interests or in the public interest/exercise of official authority.
You have the right to the portability of your data. You have the right to request your personal data from us, receive it and transfer it to another controller.
You have the right to withdraw consent at any time. If you have provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent any time without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably necessary to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
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