Paragon Digital Services documents all of this insight into a comprehensive Standard Operating Procedures.
This privacy notice explains how we, PARAGON DIGITAL SERVICES LIMITED (Regent’s Place, 10 Triton Street, London, NW1 3BF) together with our group companies (we, us, our, Paragon) process your personal information (you, your).
This notice applies to visitors of our websites including www.paragondigitalservices.com, individuals who interact with our content and services, and individuals who contact us or receive our communications.
California residents should also read our section about “Your California Rights”.
Individuals in the European Economic Area (EEA) and the UK should also read our section about “Your EEA & UK Rights”.
1. Information we collect
The type of personal information we collect will depend on the circumstances and the content or services you are using. Generally, “personal information”, “personal data” or similar terms refers to any information that identifies you or relates to you. However, the exact meaning of personal information will be determined by the law of the country of your residence.
Specifically, we will collect the following personal information about you:
We will process your name, contact details, job title, employer, professional or employment details and other personal information when you send us a query or ask for information about our content or services.
You may input personal information when you interact with our content or services, or if you participate in our competitions, promotions, surveys, events, research, or other activities.
We will receive personal information if you use our chat tools, comment and feedback and other online functionalities.
All such personal information will be necessary to assist with your queries and delivering our content and services to you.
Third parties may provide to us information about you if you work for a supplier or client, and they contact us and offer your details as a point of contact.
We collect information about the device you use to access our content or services. This includes collecting unique mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, which are numbers that can uniquely identify a specific device on the internet, geolocation data, operating system, browser, time zone setting, clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our content or services.
We collect information about the pages you visit on our website and the links and content or services you choose to access.
When we send you emails, we may collect technical information about your interaction with the email, such as open rates and if you clicked on any content.
You may find more information on the cookies we use and the purpose for which we use them on our Cookies Notice.
Our websites are not intended for children, and we do not seek to collect information about children. If you have any concerns about your child’s privacy in relation to our content or services or if you believe that your child may have entered personal information in relation to our content or services, please contact us at paragondpo@dentsu.com.
2. How we use your information
Generally, we will use your personal information to (i) deliver our content and services; (ii) respond to your queries; (iii) develop and promote our organisation, content, and services; (iv) ensure the security and technical availability of our content and services; and (v) for recruitment purposes.
We would need your personal data for a contractual requirement, to enter a contract for our services or for employment with us. If you fail to provide us with your personal data, we may not be able to provide our services or engage with you for recruitment purposes.
Particularly, we will use your personal information for the following purposes:
* If you are an individual in the EEA or the UK, we must inform you about the “lawful basis” or “legal ground” for us to use your “personal data”. This will normally be your consent to our use of your personal data or our legitimate interest to use your personal data to ensure that our content and services are provided properly, efficiently, and securely, as is further explained in the table below.
| Purpose | Personal Information | Legal ground for processing* (for individuals in the EEA and UK only) |
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| To keep you informed about matters relevant to your use of our content or services and to your engagement with our organization, such as activities, events, surveys, changes in terms, etc. |
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| To send you information which you have requested about our services |
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| To provide you with our services which you have requested |
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To improve and develop our website functionality, including: to enable you to use our content and services and to interact with our organization engaging and sharing data with third party suppliers who fulfil functions in relation to our content and services; and conduct statistical analysis |
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| Sending you promotional information through various marketing channels including email, social media, etc. about our services and our organization and profiling your information for direct marketing purposes. |
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| To monitor our networks, websites and systems for suspicious activities and deploy security measures. |
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| To share information within our offices, departments, business units and our group companies. |
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| To share information with other third parties, such as regulator, law enforcement agencies or where this is mandatory under a court order. |
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We will update you about any new purposes of processing of your personal information from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.
3. How long we will keep your information
We will keep your personal information for as long as is necessary for the purposes listed above or longer, as may be required by law. Please contact us for further details of applicable retention periods.
After the retention period, your personal information will either be securely deleted or de-identified and it may be used for analytical purposes.
4. How we secure your personal information
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration, or destruction of personal information. We also seek to ensure our suppliers do the same.
We will endeavour to use the least amount of personal information as is required for each purpose. We will employ pseudonymisation and anonymisation, where appropriate.
Our staff will access your personal information on a need-to-know basis.
We are ISO 27001:2013 & ISO 27701:2019 certified.
5. Information sharing and disclosure
We will generally not share your information except with our offices, departments, business units and our group companies as is required for the purposes set out above.
However, we may also disclose or are compelled to disclose your personal information to third parties in the following scenarios:
to our suppliers, service providers or vendors to facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, analytics, engagement tools, plugin providers, communications providers, accounting/payroll, security tools, survey tools, consultants, CRM, content management and others.
to successor or partner legal entities or potential acquirers for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, or similar event relating to our business.
to courts, authorities (e.g., tax, audit), law enforcement, or other third parties where we are required by law to do so.
our professional advisers such as our accountants, auditors, lawyers, bankers, insurers, and other advisers; and
other third parties where you have provided your consent.
6. International transfer of your personal information
We are a global media group consisting of multiple group companies around the world and we may transfer your personal information to our group companies in countries different to your country of residence. We may handle your data in the UK, in the US, or in India where our servers are stored.
Where we transfer your personal data to our group companies, suppliers or other third parties outside the EEA or UK, we will only do so, where we are satisfied that your data protection rights are adequately protected by appropriate technical, organisational, legal, and contractual safeguards in accordance with data protection laws.
These safeguards may include the standard contractual clauses adopted by the European Commission and where transfers are to the United States of America, the EU-US Privacy Shield and Swiss-US Privacy Shield.
7. Your right to opt-out
If you would like us to stop sending you marketing communications and to process your personal information for direct marketing purposes, please let us know.
You can stop our communications at any time by clicking on the unsubscribe link at the bottom of the message.
8. Updates
This privacy notice may be updated from time to time to reflect changes in law, best practice, or a change in our practices regarding the treatment of personal information. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree to the changes, please do not continue to use our content or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.
9. Contact us
If you have any questions about this privacy notice, our approach to privacy or would like to exercise any of the rights mentioned in this privacy notice or find out if they apply to you, you can contact our Data Protection Officer by email to paragondpo@dentsu.com.
10. Your California Rights
This section provides further disclosures and describes the rights in relation to your personal information that you may have under The California Consumer Privacy Act of 2018 (“CCPA”) if you are a resident of California.
For the purposes of this notice, your “personal information” is any information that relates to you or your household or from which you or your household can be identified.
Where provided under the CCPA, you will have the following rights:
denying you goods or services.
charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
providing you a different level or quality of goods or services.
suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
To exercise your rights, please:
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.
If we cannot comply with a request in full or in part, we will explain our reasons.
Your EEA&UK Rights
This section provides further disclosures and describes the rights in relation to your personal data that you may have under The General Data Protection Regulation (“GDPR”) if you are an individual in the EEA or the UK.
“Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, all information relating to you will be your personal data.
We have implemented appropriate policies and procedures to ensure that your personal data is processed in accordance with the data protection principles under GDPR.
Subject to certain exemptions, limitations, and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data, including the following:
If you would like to access the rights listed above, or any other legal rights you have over your data under applicable laws, please contact us at paragondpo@dentsu.com.
