Call Now 800-888-6060 Effective Date: January, 2021 We at Paragon Global Resources, Inc. and our subsidiary Paragon Relocation Resources, Inc. (“Paragon”), recognize the importance of protecting the privacy of personal and/or sensitive information (“Information”) collected about our client’s employees who become our customers, prospective customers, or are registered members of our affinity division (“Customers”). This Privacy Policy covers our collection, use and disclosure of information we collect through our websites https://paragonrelocation.com/ and https://www.paragongri.com/. It also describes the choices available to you regarding the use of, your access to and how to update and correct your personal information. It is our intention to provide an understanding about how we collect Customer Information and the use we make of it in the course of the services we provide. The use of Information collected through our services shall be limited to the purpose of providing the services for which either our clients or customers have engaged Paragon. Paragon acknowledges that you have the right to access your personal information. Paragon has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Paragon’s Client (the data controller). If requested to remove data we will respond within 30 days. Paragon collects information under the direction of its Clients. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. Personal Information We Collect Paragon collects information, including personally identifiable information (PII) such as name, address, phone numbers, emails, etc., when voluntarily submitted to us by visitors to our websites or provided to us directly from a client or supplier. The information is used solely to fulfill a request you specify or services authorized by a client. Service Providers Paragon uses other third parties such as moving companies, temporary housing facilities, mortgage originators, real estate brokers, destination service companies, visa & immigration service providers, etc. where necessary to facilitate the relocation services we deliver. Paragon will only share Information required for the services being performed and only with third parties who are either Privacy Shield compliant or who have a written agreement with Paragon stating they subscribe to the same level of privacy standards and principles as Paragon. Our Service Providers are not allowed to share, sell, rent or trade your personal information. When and How We Disclose Your Information We will share your Information with third parties only in the ways that are described in this privacy policy. We remain responsible for the handling of your information by our third-party Service Providers. Additionally, in accordance with our client contracts, your information may be made available to your employer. We may also disclose Information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so. If Paragon Global Resources is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your Information, as well as any choices you may have regarding your Information. How to Control Usage of Your Information For relocation and assignment services contracted through our clients, your employer, Paragon is an opt-in organization. You will be asked to login to PRISM (https://prism.paragonrelocation.com/Main/OtherPages/CustomSignIn.aspx) and accept the acknowledgement of Paragon’s Privacy Policy. Please understand that if you choose to decline the Privacy Policy Acknowledgement it will prevent the sharing of your Information, and Paragon may be unable to provide services to you. If you have any questions, please contact your Paragon Relocation Consultant or privacy@paragonrelocation.com or contact us by postal mail at the contact information listed below. Upon request Paragon will provide you with information about whether we hold any of your personal information. In case your Information (such as postal code or e-mail address) changes, you can request to correct, update or remove the Information that you give us. We also will give you the opportunity to control the communications we direct at you. Please send your request to your Paragon Relocation Consultant or privacy@paragonrelocation.com. We will respond to your request to update, correct or delete your personally identifiable information within 30 days. How We Protect Your Information To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we adhere to industry best practices and have in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, no data transmission over the internet is 100% secure transmission. If you have any questions about the security of your personal information, you can contact us at privacy@paragonrelocation.com. Server Locations and Transfer of Information to the United States Paragon’s websites https://paragonrelocation.com/ and https://www.paragongri.com/ are hosted by servers in the United States and thereby governed by United States law. If you access the websites from outside the United States, your information will be transferred to the United States. If you choose to submit your personal information, you are consenting to its transfer to the United States including its storage and processing in accordance with this privacy policy and United States law. User Data Supplementation We may receive information about you from other sources, including publicly available databases of third parties from whom we have purchased data, combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Data Retention We will retain personal data we process on behalf of our clients for as long as needed to provide services to our client and also your Information for as long as your account is active or as needed to provide you services. In the event you cease to be a Customer for any reason, we will continue to maintain your Information consistent with the privacy policies and practices that apply to our Customers. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Use of Tracking Technologies We and our analytics or service providers (e.g. online customer support provider, etc.) use cookies or similar tracking technologies. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We also use cookies to remember users’ settings (e.g. language preference) or for authentication. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. Log Files – As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Behavioral Advertising/Re-Tracking We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking http://preferences-mgr.truste.com/ (or if located in the European Union click http://www.youronlinechoices.eu/). Please note this does not opt you out of being served ads. You will continue to receive generic ads. What Happens When You Link to a Third-Party Site? Paragon provides links to third-party web sites. If a user “clicks” on an external link, the “click” may transfer the user off the Paragon site. Such linked sites are not under the control of Paragon, and we are not responsible for the terms of use, policies or contents of any linked site, or any link contained in a linked site. We urge you to review the terms of use and privacy policy of any linked site before sharing any Information with them. Our Newsletter If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at privacy@paragonrelocation.com. Social Media Widgets Our Web site includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it. Our Blog Our web site offers a publicly accessible blog. You should be aware that any Information you provide in these areas may be read, collected, and used by others who access them. Anytime you post on our blog, please be aware that you are posting using a third party application and we have no access or control over this Information. To request removal of your Information from our blog, you can both log into the third party application and remove your comment or you can contact the appropriate third party application. Your interaction with these features is governed by the privacy policy of the company providing it. Compliance with EU – U.S. Privacy Shield and Swiss – U.S. Privacy Shield Paragon complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Paragon has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@paragonrelocation.com. If requested to remove data, we will respond within a reasonable timeframe. Paragon is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@paragonrelocation.com. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Paragon is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In compliance with the Privacy Shield Principles, Paragon commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Paragon by email at privacy@paragonrelocation.com. Paragon has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. Changes to This Policy We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Who to Contact If you have any questions regarding this privacy statement or the practices of this website, please contact us via email at at privacy@paragonrelocation.com. If at any time you feel that Paragon has not taken the appropriate steps to correct inaccuracies, or has not provided the security required to insure the privacy of the Information we have acquired from or about you, contact Paragon in writing either by email at privacy@paragonrelocation.com, or through the US Postal Service or by courier at: Paragon Global Resources, Attn: Privacy Office, 30071 Tomas, Suite 200, Rancho Santa Margarita, CA 92688 USA. Please explain your complaint or dispute in as much detail as possible. Paragon will investigate as soon as possible and respond no later than 30 days. Paragon Global Resources Inc. Tel. # 800-888-6060 Email: info@paragongri.com 405 State Highway 121 Bypass, Suite A250 Lewisville, TX 75067 USA Home Leadership Team Contact Us Privacy Policy Copyright © 2021 Paragon Global Resources All Rights Reserved