We've recently updated our privacy policy. The updated policy can be found here. Continued use of our services constitutes acceptance of our updated policy.
Last Updated: June 22, 2022
This Privacy Policy describes the policies of Paradigm Connect Asia Pte. Ltd., Paradigm Connect, Inc. and their affiliates (collectively, “us”, “Paradigm”, “we”, or “our”) applicable to your usage of our websites and the System (as defined in our User Agreement with you or your related User) (collectively, “Services”). Specifically, this policy sets forth our practices regarding the collection, use and disclosure of information that is linked or reasonably linkable to a particular User or individual person (“Customer Information” or “CI”). This Privacy Policy also describes the choices you have associated with that Customer Information.
By using the Services, you agree to the collection and use of CI in accordance with this Privacy Policy. If you are a User (or an Administrator of a User), you are providing consent on behalf of your Authorized Users. Capitalized terms used but not otherwise defined in this Privacy Policy have the meanings given to such terms in our User Agreement, accessible from https://www.paradigm.co/help/terms/paradigm-singapore/terms-and-agreements (all non-US jurisdictions).
When you use our Services, we may collect the following Customer Information:
● Contact Information - Name, email address, physical address and jurisdiction (for Users and Authorized Users);
● Relationship Information - Information relating to an Authorized User’s relationship with a User;
● Transaction Information - A record of transactions made by Users using our Services including, but not limited to the type and amount of transaction as well as the type of transaction;
● Online Information - Geolocation, IP Address and operating system browser fingerprint (of Users and Authorized Users);
● Communications Information - Information regarding your communications and other interactions with us, including information you provide to our coverage and technical support teams;
● Usage and Diagnostics - Information regarding your usage of our Services, such as user preferences, conversion events, and data collected via cookies and other technologies; and
● Information Collected from Third Parties – We receive cookies and other trackers from third parties who collect such information on our behalf. These technologies are used to track the activity on our Services and store certain information. For more information regarding the collection and use of cookies, please see our Cookie Policy here. We also may receive information about you from public sources as permitted by applicable law.
We may use the collected CI in the following ways:
● To provide and maintain our Services, including to (1) open and maintain User accounts, (2) provide customer, coverage and technical support and (3) process transactions (including to transmit transactions to User selected exchanges for settlement and clearance);
● To notify you about changes to our Services and potential trading opportunities;
● To improve our Services, including by gathering analysis or valuable information;
● To carry out our obligations and enforce our rights arising from any contracts with you, including to comply with legal requirements;
● To monitor the usage of our Service;
● To detect, prevent and address technical issues;
● To allow you to participate in interactive features of our Services when you choose to do so;
● To provide you with news, special offers and general information, including about the Services and events, unless you have opted not to receive such information;
● To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
● As described below under the “Customer Information Sharing and Disclosure” heading;
● In any other way we may describe when you provide the information; and
● For any other purpose with your consent.
We may disclose your Customer Information with third parties in the following circumstances:
Customer Information Shared in Order to Provide our Services or Support Transactions
We may share your Customer Information in connection with providing Services to you or your associated User and that User’s other Authorized Users, including to help service transactions, transmit transactions to exchanges, provide customer service and support, and provide technical support. We will also share any requested information with the exchange or other settlement venue to which you (or your related User) submit transactions to for settlement and clearance, including in the event of disputes regarding transactions.
Customer Information Shared with Our Service Providers
We may engage third-party service providers to support our business, including by providing services to us or on our behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, further development of our website and Systems and providing customer service.
Customer Information Disclosed in Connection with Business Transactions
We may disclose your Customer Information to a third party in the event of reorganization, financing, investment, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.
Customer Information Shared with Third Parties to Market Their Products or Services
If you have not opted out of these disclosures, we may disclose your Customer Information to third parties to market their products or services to you. Such third parties are contractually required to only use such information for the purposes for which we disclose it to them.
Customer Information Disclosed for Our Protection and the Protection of Others
We may disclose your Customer Information to legal or regulatory authorities if required by them or we deem it appropriate, or if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to:
● Conform to legal requirements or comply with legal processes (including subpoenas);
● Enforce or apply our terms of use and other agreements, including for billing and collections purposes;
● Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
● Stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in an Aggregated or Anonymized Manner
We may also share information on an aggregated or anonymized matter with our partners, other site visitors, and other third parties, including so that they can understand the kinds of visitors to our websites and Users of our Services as well as usages of our Services. Such information will not be considered your Customer Information because it will be anonymized and aggregated in such a way that it cannot reasonably be linked back to a specific User or Authorized User.
Information Disclosed to Others in Accordance with Your Preferences
We may disclose your Customer Information to third parties if you, your User or your Authorized User consent to such disclosure. For example, when you or your User configure your or its profile, you may have the option to indicate that you would like to receive information about the opportunities, products or services of third parties.
Customer Information Disclosed to Affiliates
We may share your Customer Information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Information Disclosed With Your Consent
We may disclose your Customer Information for any other purpose to which you or your related User consent.
Your Customer Information may be transferred to — and maintained on — computers located outside of your state, province, country or other jurisdiction where the data protection laws may differ from those of your home jurisdiction.
If you are located outside the United States and choose to provide Customer Information to us, please note that we may transfer such information to the United States and process it there.
In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that jurisdiction may be able to obtain access to your CI through the laws of the jurisdiction. Whenever we engage a service provider, we include customary confidentiality and non-disclosure obligations from that service provider regarding any CI that is provided to it.
We will retain your Customer Information for as long as is necessary for the purposes set out in this Privacy Policy, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), to resolve disputes and/or to enforce our legal agreements and policies.
No persons under 18 are eligible to utilize our Services. We do not knowingly collect CI from anyone under the age of 18. In the event that we become aware that we have collected Customer Information from children without verification of parental consent, we take steps to remove that CI from our servers.
The security of CI is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Customer Information, we cannot guarantee its security.
Our Services 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. Please be advised that we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. As such, we strongly advise you to review the Privacy Policy of every site you visit.
We may update this Privacy Policy from time to time. When we make a material change to this Privacy Policy, we will provide notice of the change by a prominent notice on our websites and update the “effective date” at the top of this Privacy Policy. We may also choose to provide an email notice to the administrators of Users.
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.
If you have any questions about this Privacy Policy or would like to exercise your rights, please contact us at privacy@paradigm.co.
This portion of our Privacy Policy describes the Customer Information we collect or process about European residents in connection with our Services, how we use, share, and protect that Customer Information, and what your rights are concerning Personal Data (as defined below) that we collect or process. This portion of our Privacy Policy does not apply to any Customer Information other than Personal Data (as defined below) or to any person other than a natural person resident of the European Economic Area (“EEA”).
For the purposes of this portion of our Privacy Policy, “Personal Data” has the same meaning as under the General Data Protection Regulation (“GDPR”), Article 4(1) as any information relating to an identified or identifiable natural person.
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, please contact us.
a. Your Rights
In certain circumstances, you have the following data protection rights:
● The Right to Access, Update or Delete the Information We Have On You. You have the right to access, update, or request deletion of your Personal Data by contacting us at privacy@paradigm.co.
● The Right of Rectification. You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.
● The Right to Object. You have the right to object to our processing of your Personal Data.
● The Right of Restriction. You have the right to request that we restrict the processing of your Personal Data.
● The Right to Data Portability. You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
● The Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your Personal Data.
● The Right to Complain to a Data Protection Authority. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.
b. Legal Basis for Processing Personal Data under the GDPR
When processing the Personal Data of individuals residing in the EEA, the legal basis we rely on for collecting and using the Personal Data described in this portion of the Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. For example, we may process your Personal Data because:
● We need to perform a contract with you;
● You have given us permission to do so;
● The processing is in our legitimate interests and it is not overridden by your rights; or
● To comply with the law
Contacting Us
You may contact us if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, or would like to exercise your rights, please contact us at privacy@paradigm.co.
Scope of this Privacy Notice
This portion of our Privacy Policy describes the Personal Data (as defined below) we collect or process about Singapore residents in connection with our Services, how we use, share, and protect that Personal Data, and what your rights are concerning Personal Data that we collect or process. This portion of our Privacy Policy does not apply to any Customer Information other than Personal Data (as defined below) or to any person other than a Singapore natural person resident.
In this portion of our Privacy Policy, “Personal Data” has the same meaning as under part 1, section 2 of the Singapore Personal Data Protection Act of 2012 (“PDPA”) as data, whether true or not, about an individual who can be identified from that data or from that data and any other information to which the organization has or is likely to have access.
Withdrawing Your Consent
The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to us at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you (or your related User) and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us by contacting us in the manner outlined below.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted, in connection with the processing of transactions, or as required under applicable laws or for compliance purposes.
Access to and Correction of Personal Data
If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Contacting Us
You may contact us if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, or would like to exercise your rights, please contact us at privacy@paradigm.co.
Your Rights Under the California Consumer Privacy Act
Scope of this Privacy Notice
This portion of our Privacy Policy describes the Personal Information (as defined below) that we collect or process about California residents in connection with our Services, how we use, share, and protect that Personal Information, and what your rights are concerning Personal Information that we collect or process. This portion of our Privacy Policy does not apply to any Customer Information other than Personal Data (as defined below) or to any person other than a natural person resident of the State of California.
In this portion of our Privacy Policy, “Personal Information” has the same meaning as under the California Consumer Privacy Act (“CCPA”), California Civil Code Section 1798.83: information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Customer Information does not include information that has been de-identified or aggregated.
Personal Information We Collect and Share, and For What Purpose
In the past 12 months, we have collected and/or shared the following Personal Information of visitors when they interact with our Services, as described in detail above:
● Contact Information
● Relationship Information
● Transaction Information
● Online Information
● Communications Information
● Usage and Diagnostics
● Information Collected from Third Parties
● Customer Information Shared in Order to Provide our Services or Support Transactions
● Customer Information Shared with Our Service Providers
● Customer Information Disclosed in Connection with Business Transactions
● Customer Information Shared with Third Parties to Market Their Products or Services
● Customer Information Disclosed for Our Protection and the Protection of Others
● Information Disclosed in an Aggregated or Anonymized Manner
● Information Disclosed to Others in Accordance with Your Preferences
● Customer Information Disclosed to Affiliates
● Information Disclosed With Your Consent
As outlined above, in the past twelve months, we have used your Personal Information for a variety of purposes to operate, assess activity on, and improve the performance of our Services, including the following:
● To provide and maintain our Services;
● To notify you about changes to our Services and potential trading opportunities;
● To improve our Services, including by gathering analysis or valuable information;
● To carry out our obligations and enforce our rights arising from any contracts with you, including to comply with legal requirements;
● To monitor the usage of our Services;
● To detect, prevent and address technical issues;
● To allow you to participate in interactive features of our Services when you choose to do so;
● To provide you with news, special offers and general information, including about the Services and events, unless you have opted not to receive such information;
● To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
● As described below under the “Customer Information Sharing and Disclosure” heading;
● In any other way we may describe when you provide the information; and
● For any other purpose with your consent.
Except as described in detail above, we will not share with third parties Personal Information without your consent.
We do not share your Personal Information with third parties for third party marketing purposes without your consent.
Your Choices as a California Resident
Under California law, users who are California residents have specific rights regarding their Personal Information. These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.
Right to Disclosure of Information
You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
● The categories of Personal Information we have collected about you in the last 12 months.
● The categories of sources for the Personal Information we have collected about you in the last 12 months.
● Our business or commercial purpose for collecting that Personal Information.
● The categories of third parties with whom we share that Personal Information.
● The specific pieces of Personal Information we collected about you.
● If we disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.
Right to Delete Personal Information
You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law. Please note that a request to delete Personal Information may result in us terminating you or your Authorized User from further access to our Services.
How to Exercise these Rights
You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by emailing us at privacy@paradigm.co.
We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 10 days of receipt.
In order to protect your privacy and the security of your Personal Information, we verify consumer requests by contacting the administrator of the User that is listed on our records for that User. Any additional verification-related information you provide will be used only to verify your identity and not for any other purpose.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney under Probate Code sections 4000-4465 may submit a request on your behalf.
Right to Opt Out of Sales of Your Personal Information
You have a right to opt-out of the sale of your Personal Information. You may, at any time, request that we stop selling (pursuant to the CCPA’s definition) your Personal Information. In the past 12 months, we have not sold (as so defined) any Personal Information.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
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.
Right to Non-Discrimination
You have the right not to be discriminated against for the exercise of your California privacy rights described above.