1. PRIVACY POLICY

Last Modified: July 16th, 2023

This privacy policy (“Privacy Policy” or “Policy”) describes how Make Me Reach SAS (d/b/a Paragone) and its affiliated companies (collectively shall be referred to as “Paragone”, “we”, “us”, or “our”) collect, use and disclose certain information, and the choices you can make about our use of that information.

Paragone is a technology company that provides a range of services, including SaaS solution, for monitoring, managing, optimizing and improving social advertising campaigns (“Platform”) enabling our Platform’s users (“Customer”) to automate, monitor, optimize and exercise centralized control over their online advertising and social campaigns (“Services”).

When you use our Services, including log-in and use our Platform, or even we you merely browse our website: www.paragone.ai, you are trusting us with your information. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can control it.

This Privacy Policy is incorporated by reference in our website Terms and Conditions. Visitors of our website and our Customers shall be further collectively referred to herein as “user” or “you”.

1.1 POLICY AMENDMENTS
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.

1.2 CONTACT INFORMATION AND DATA CONTROLLER INFORMATION
Make Me Reach SAS (d/b/a Paragone – part of the Perion Network Ltd. Group), incorporated under the laws of France, is the “data controller” (as such term is defined under the EU General Data Protection Regulation known as the “GDPR” or equivalent privacy legislation).

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows:

• Data Protection Officer:
  privacy@perion.com
  Make Me Reach SAS (d/b/a Paragone)

• Data Protection Representative for Data Subjects in the EU and UK:
  We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
  Prighter Group provides you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter Group, or exercise your data subject rights, please visit the following website. https://prighter.com/q/11106546394.
  Attn: Andreas Mätzler
  Email: rep_perion@prighter.com

1.3 DATA SETS WE COLLECT AND FOR WHAT PURPOSE
You can find here information regarding the data sets we collect, purposes for which we process your data as well as our lawful basis for processing, and how the data is technically processed. In general, we may collect two types of information from you, depending on your interaction with us:

Non-Personal Data
During your interaction with our website and Services, we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your access to and use of our website and Services (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device, such as: browser version, operating system type and version, mobile network information, device settings, and software data.

Personal Data
We may also collect from you, during your access or interaction with our website or the Services, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information”).

For avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).

The table below details the types of Personal Data we collect, the purpose, lawful basis and processing operations:

We use various technologies to collect and store the information listed above, including cookies, pixel tags, local storage, databases and server logs. We use different technologies to process your information listed above, for the purposes listed above.

Therefore, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third party countries as further detailed in the International Data Transfer section is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce our policies and agreements, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

1.4 HOW WE COLLECT YOUR INFORMATION
Depending on the nature of your interaction with the website and Services, we may collect information either automatically or voluntarily provided by you. Automatic collection of information is usually made through the use of cookies, pixel tags, local storage, databases, and server logs.

1.5 COOKIES AND SIMILAR TRACKING TECHNOLOGIES
When you browse our website or interact with the Platform, we, or our third-party vendors, place “cookies”, “pixels” or “web beacons”, that collect certain information about your usage and interaction with the website and use this information for operational, analytic, fraud detection and marketing purposes, as detailed in the table above.

First party cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our website quicker. The use of cookies is a standard industry-wide practice.

You can find more information about cookies at www.allaboutcookies.org.

The cookies we use on are website are listed here: Cookie List
You can opt-out of data collection through cookies or otherwise change your preferences at any time by using the cookie preference and consent management tool available on our website.

In addition, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website and Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Additionally, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising.

Please note that once you choose to opt out or disable cookies, some features of the Services may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.

Please note that, where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.

1.6 DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We share your Personal Data with third parties, including with service providers that help us provide our Services. You can find here information about the categories of such third-party recipients

Where we share information with services provider and agents, we ensure they only have access to such information that is strictly necessary in order for us to manage and operate our business operation. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

1.7 USER RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“DSR”) available here.

Certain rights can be easily executed independently by you without the need to fill out the DSR Form:

• You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
• you can withdraw consent for processing Personal Data for analytics or marketing purposes, by using the cookie settings on the website, or as detailed in the section below.

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.

For additional rights under various jurisdictions, please refer to Section “JURISDICTION-SPECIFIC NOTICES” herein below.

1.8 OPT OUT OPTIONS

Interest-Based Advertising (“IBA”): We do not sell your Personal Data. We may “share” your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many way to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.
You may opt-out directly 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.  

In addition, you can opt-out of data collection through cookies or otherwise change your preferences at any time by using the cookie preference and consent management tool available on our website.

Ad choices settings and options will vary depending on your browser and device settings, and this is not an exhaustive list. Please note that your opt-out choices will only apply to the specific browser or device from which you opt out. We encourage you to explore your device and browser settings to better understand your choices.

1.9 DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable.

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 Data was initially processed. For example: if you contacted us, we will retain your contact information 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.

Other circumstances in which we will retain your Personal Data for longer periods of time include: for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data. 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.

1.10 SECURITY MEASURES:

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures that comply with applicable laws and industry such as: encryption using SSL, we minimize amount of data that we store on our servers, restrict access to Personal Data to Paragone’s employees, contractors and agents, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@perion.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

1.11 INTERNATIONAL DATA TRANSFER

Our data servers in which we host and store the information are located in the EU and UK. The Company’s HQ are based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes.

1.12 ELIGIBILITY AND CHILDREN PRIVACY

Our website and Platform are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the US, under the age of 13) and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: privacy@perion.com if you have reason to believe that a child has shared any information with us.

2. JURISDICTION-SPECIFIC NOTICES:

2.1 ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

2.2 ADDITIONAL NOTICE TO COLORADO RESIDENTS

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.

Section ‎‎1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE” of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, in Section ‎1.6 “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH” details the categories of third-parties the controller shares for business purposes.

2.2.1 YOUR RIGHTS UNDER CPA:

Herein below, we will detail how consumers can exercise their rights, and appeal such decision, or if Paragone sells the personal data, or sells the personal data for advertising and how to opt-out.

2.2.2 HOW TO SUBMIT A REQUEST UNDER CPA?

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@perion.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

2.3 ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The VCDPA requires Paragone discloses the Categories of data processing and the purpose of each category, as detailed in Section ‎‎1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE” of the Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in Section ‎‎1.6 “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”. Disclosure of sale of data or targeted advertising are detailed in Section ‎‎1.8 OPT OUT OPTIONS above, and in the DSR Form. Further, the table above under Section ‎2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under VCDPA and how you may exercise your rights.

2.3.1 HOW TO SUBMIT A REQUEST UNDER VCDPA?

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@perion.comand specifying you wish to appeal.  Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.

2.4 ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

The categories of personal data processed, purpose of processing, are detailed in Section ‎1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section ‎1.6 “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”. Disclosure of sale of data or targeted advertising are detailed in Section ‎1.8 OPT OUT OPTIONS above, and in the DSR Form.

Instructions on how to exercise your rights are detailed in the table above under Section ‎2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

2.4.1 HOW TO SUBMIT A REQUEST UNDER CDPA?

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension.

If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

2.5 ADDITIONAL NOTICE TO UTAH RESIDENTS (effective January 2024)

Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below. “Personal Data” refers that is linked or reasonably linkable to an identifiable individual, and does not include de-identified data and publicly available data. 

The categories of personal data processed, purpose of processing, are detailed in Section ‎1.3 “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section ‎‎1.6 “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”. Disclosure of sale of data or targeted advertising are detailed in Section ‎‎1.8 OPT OUT OPTIONS above, and in the DSR Form.

Further, the table above under Section ‎2.2 “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.

2.6 NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to privacy@perion.com.