Where used in this Policy, “Paragon Partners”, “Paragon” or “the Firm”, shall mean Paragon Partners GmbH, or any of its subsidiaries or related companies. For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), Paragon that you have dealings with is the controller of your personal information.
Personal information of business contacts
If you have had contact with Paragon, for example through emailing, from a previous meeting or making contact with the Firm, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation, (potential) transactions that we have discussed and contact details. We will collect and store this personal information for the purposes of:
- providing periodic business updates (see below);
- organising meetings between you and Paragon‘s representatives;
- inviting you to events; and
- similar communication of a professional nature;
- maintaining a record of contacts.
The personal information we hold about business contacts may be shared with:
- companies who process personal information on Paragon‘s behalf such as providers of cloud CRM or hosting solutions;
- professional advisors, for example accountants, lawyers or other consultants; and
- other companies within the Paragon group.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal information of suppliers and professional advisors
If you are a supplier or professional adviser to Paragon, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation, (potential) transactions that we have discussed and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, commissioning further services, and for other purposes of this nature.
The personal information we hold about suppliers and professional advisors may be shared with:
- companies who process personal information on Paragon‘s behalf;
- professional advisors, such as accountants, lawyers or other consultants; and
- other companies from Paragon.
In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.
Personal information of actual/potential management teams
If you are involved in a transaction that Paragon and/or the funds that it manages or advises enters into, or a potential transaction that Paragon considers, we may store personal information such as: your CV, details of your previous employment history, your financial status and dealings, nationality information (including copies of a passport etc), references provided by third parties, and results of other due diligence carried out. This information is collected and stored in order to:
- assessing and administering actual and/or potential transactions;
- assessing your suitability for involvement in future transactions;
- complying with our regulatory and legal obligations, including assessing and managing risk;
- safeguarding our legal rights and interests;
- seeking and receiving advice from our professional advisors;
- providing periodic business updates, as described below;
- maintaining records of investment;
- administering any transaction that we enter into; and
- assessing your suitability for involvement in a transaction, including by verifying your identity.
The personal information we hold about actual and/or potential management teams may be shared with:
- companies who process personal information on Paragon‘s behalf and third party outsourced services providers;
- credit reference agencies;
- financial intermediaries;
- professional advisors;
- other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Paragon transaction, for example: co-investors, finance providers and investors in Paragon’s funds; and
- other companies from Paragon.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that its processing is necessary for our legitimate interests in running our business (in particular by considering potential investments, and administering transactions that we enter into). Should we enter into a transaction with your involvement, it will also be necessary to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Mandatory provision of information
We shall explain to you when the provision of particular information is mandatory and the possible consequences of not providing particular information. Paragon will only process the personal information you provide to Paragon for the purposes listed above.
Sensitive or special category personal data
Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it.
International transfers of personal information
Paragon has operations throughout Europe and as such, the personal information that we hold may be transferred to and stored at a country outside of your country of residence, including countries outside of the EEA. In the event that Paragon transfers personal information to Paragon-companies or third parties outside of the EEA, we shall endeavour to ensure that those transfers take place in accordance with the Data Protection Laws, for example by entering into data transfer agreements with the recipient.
We use analytics services provided by Google. This allows us to collect anonymous usage information to better understand how our website and web-related services are used. Our use of these cookies does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it relevant to your interests and needs.
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again.
The table below explains the cookies we use and why.
|_icl_current_language||Enables our website to choose the correct language version for the user.||WPML – Expires: When you close your browser|
|_ga||Used to distinguish users by assigning a randomly generated number as a client identifier.||Google – Expires: 2 years|
|_gid||Used to distinguish users.||Google – Expires: 24 hours|
|_gat||Used to optimize performance and throttle request rate.||Google – Expires 1 minute|
Google may adjust their cookies from time to time, please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage to review their latest cookie details.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout
To opt out of being tracked by this website you can click the following link:
Google Analytics deativate
By using our website without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device.
Periodic business updates
We may use personal information that we hold to send you periodic updates about Paragon‘s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Paragons’s Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.
Retention of personal information
The period for which Paragon will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you provide us with your information in connection with a potential management position with one of our portfolio companies, we may keep your information for up to fifteen years from the date of last contact with you.
Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to the Data Protection Team (firstname.lastname@example.org). Individuals also have the right to complain about the use of their personal information to the Supervisory Authority, which in Bavaria is the “Bayerische Landesbeauftragte für den Datenschutz” Dr. Thomas Petri (www.datenschutz-bayern.de).
Accuracy and security
Paragon will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Paragon holds about you is incorrect please notify Paragon (see “Paragon‘s Privacy Contacts” below).
Paragon will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Paragon responsible for any breach of security unless this is due to Paragon‘s negligence or wilful default.
Paragon Data Privacy Contacts
For all enquires, please email email@example.com
Data Security Officer for Germany:
Herr Lukas Gleim
Paragon Partners GmbH
Tel.: +49 (89) 38 88 70 0