CCPA PRIVACY NOTICE
Last Modified: January 8th, 2023
The California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), any other California privacy laws, and this CCPA Notice apply to visitors, employees, users, applicants for employment, and independent contractors, and others who are California residents (“consumers” or “you”). Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our website and Platform, or employee and business-to-business Personal Information.
PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:
(A) CATEGORIES of PERSONAL information WE COLLECT
We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.
Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below.
Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
We have collected the following categories of personal information within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes: Online identifier, unique online identifier, IP address, real name, account name, email address.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.|
Some personal information included in this category may overlap with other categories.
|Yes: for recruitment, SSN, telephone number, email address, and personal information provided in the CV submitted such as education, employment history, physical characteristics and address.|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes: where Customers purchase our Services.|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes: information on a consumer’s interaction with our website and Platform.|
|G. Geolocation data.||Physical location, approximate location derived from IP address or movements.||Yes: Approximate location.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes: for candidates submitting an application for an open position we publish.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No.|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
|L. Sensitive personal information.||Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.||No|
(B) CATEGORIES OF SOURCES OF PERSONAL INFORMATION
- Directly and indirectly from activity on our website and Platform: For example, from submissions through our website portal or website usage details collected automatically from measurement tools.
- Directly from you: For example, from forms you complete, contact us, applying for a job, etc.
- From third-parties: For example, from vendors who assist us in performing services for consumers, data analytics providers and social networks.
- Publicly accessible sources.
(C) USE OF PERSONAL INFORMATION
We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
(D) DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract, we further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:
|Category (corresponding with the table above)||Category of Recipient||Business Purpose|
|Cloud computing and storage vendors.||Storage, hosting.|
|Government Entities||Subject to a law requirement.|
|Operating systems.||Operating the website and Services.|
|Data analysis providers.||Providing analytic data on the use of our website and Platform. We limit the provider’s ability to share such information, as detailed above.|
|Marketing & promotions providers, CRM providers, social networks.||Marketing which is not cross-contextual, ad delivery.|
|Security service providers.||Debugging, security, fraud prevention.|
|Service providers||Improving the Services, development and optimization.|
|Customer support providers. Affiliated companies.||Customer and technical support.|
|Recruitment service providers.||Recruitment.|
(E) SALE OR SHARE OF PERSONAL INFORMATION
In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.
For retargeting and analytic purposes, when we promote our website and Services, we use third-party tools that are able to market online (“Campaigns”), measure those Campaigns, identify individuals that are interested in our Services, etc. This is done by placing cookies, pixel or other tracking technology on our website and sharing with these vendors the online identifiers and online behavior information. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.” In other words, we may share your Personal Information with a third party to help promote our services and understand your use of our website.
In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information:
|Category (corresponding with the table above)||Category Recipient||Purpose of Sale or Share|
|Marketing Cookies, Analytic Cookies.||Share for cross-context behavioral advertising.|
(F) CHILDREN UNDER AGE 16
We do not knowingly collect information from children under the age of 16.
(G) DATA RETENTION
The retention periods are determined according to the following criteria:
- For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry, and thereafter, where it is needed to handle your inquiry or for other legitimate interest as detailed in the table above.
- To comply with our regulatory obligations.
- To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
Online identifiers are usually kept for a few days. Other information usually will not be retained for more than 24-months.
When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed.
PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA and how to exercise them
(H) YOUR RIGHTS UNDER THE CCPA
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and the in the Data Subject Request Form available here.
|California Privacy Right||Details|
|The right to know what Personal Information the business has collected.||The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.|
|Deletion Rights.||The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.|
|Correct Inaccurate Information||The right to correct inaccurate Personal Information that a business maintains about a consumer|
|Opt-Out of Sharing for Cross-Contextual Behavioral Advertising||You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising”.|
|Opt-out from selling||The right to opt-out of the sale or sharing of Personal Information by the business|
|Limit the Use or Disclosure of SPI||Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.|
|Opt-Out of the Use of Automated Decision Making||In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.|
|Non-Discrimination||The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.|
|Data Portability||You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.|
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
(I) HOW CAN YOU EXERCISE THE RIGHTS?
- Paragone is committed to providing consumers notice and choice, Paragone offers an “opt-out” for those by clicking the link in the footer – “Do Not Sell and Share My Personal Information”
- To opt out of the sale or share of Personal Information, you may also directly opt out from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:
- Digital Advertising Alliance (US) here
- Digital Advertising Alliance (Canada) here
- Digital Advertising Alliance (EU) here
- Network Advertising Initiative here
- Use the Global Privacy Control (“GPC”) signals
- You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytic HERE.
We also are able to affirmatively the Global Privacy Control preference.
Other rights may be exercised by using the Data Subject Request Form available here, the Instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed in the Data Subject Request Form available here.
(J) AUTHORIZED AGENTS
“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:
a. When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
- Provide the authorized agent signed permission to do so or power of attorney.
- Verify their own identity directly with the business.
- Directly confirm with the business that they provided the authorized agent permission to submit the request.
b. A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
(K) Notice of Financial Incentive
We do not offer financial incentives to consumers for providing Personal Information.
Make Me Reach SAS (d/b/a Paragone)
PART III: OTHER CALIFORNIA OBLIGATIONS
Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use Data Subject Request Form available here.
Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
California’s “Shine the Light” law (Civil Code Section § 1798.83): permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form available here.