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 and the German Federal Data Protection Act, as amended or supplemented (the “Data Protection Laws”). Paragon is the controller of your personal data.
Personal data 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 data 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 data 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 data we hold about business contacts may be shared with:
- companies who process personal data 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 data about you is that such processing is necessary for our legitimate interests in running and promoting our business, or your consent, as applicable.
Personal data of suppliers and professional advisors
If you are a supplier or professional adviser to Paragon, we will process limited amounts of personal data relating to you, including your name, job title, qualifications, employer organisation, (potential) transactions that we have discussed and contact details. We will process this personal data 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 data we hold about suppliers and professional advisors may be shared with:
- companies who process personal data 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 processing personal data that you provide to us is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal data 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 process personal data – with your consent as applicable – 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 data is processed 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 data we hold about actual and/or potential management teams may – with consent as applicable – be shared with:
- companies who process personal data 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 affiliated companies of Paragon.
In accordance with the Data Protection Laws, our legal basis for processing personal data about you is that its processing is either your explicit consent or, where not required, 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 data for the purpose of performing that contract with you and to comply with our regulatory and legal obligations.
Personal data of applicants
When you apply for a job at Paragon or visit Paragon’s career website we may process personal data such as: your CV, e-mail communication, notes about you, certificates that you provide us with, work history, motivation letter and other documents provided by you, date and time of usage and traffic source.
This data is processed in order to:
- handle your application;
- assess your suitability for our job offers;
- offer you a job or refusing your application;
The personal data may be shared with companies who process personal data on Paragon‘s behalf.
In accordance with the Data Protection Laws, our legal basis for processing personal data about you is that its processing is necessary for preparing a hiring decision and, where applicable, to take steps to entering into an employment contract with you.
Mandatory provision of information
We shall explain to you when the provision of particular data is mandatory and the possible consequences of not providing particular data. Paragon will only process the personal data 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 or special category personal data as generally we do not need it.
International transfers of personal data
Paragon has operations throughout Europe and as such, the personal data that we hold may be transferred to and processed at a country outside of your country of residence, including countries outside of the EEA. In the event that Paragon transfers personal data to Paragon-companies or third parties outside of the EEA, we will ensure that those transfers take place in accordance with the Data Protection Laws, for example by entering into EU Standard Contrat clauses or other tranfer instruments under Art. 46 GDPR.
We use analytics services provided by Google. This allows us to process usage data to better understand how our website and web-related services are used. This enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data. The data collected by Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g. for profiling or linking it to other data.
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 underhttps://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
Our website uses Borlabs Cookie Consent technology to obtain your consent to store certain cookies in your browser and to do so in a privacy compliant manner. consent to the storage of certain cookies in your browser and to document this consent in documented in accordance with data protection law. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (hereinafter referred to as Borlabs).
When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you the consent you have given or the revocation of this consent. This data will not be shared with the Borlabs cookie provider.
The data collected will be stored until you request us to delete it, or until you delete the Borlabs cookie yourself, or until the purpose of the data storage changes. delete the Borlabs cookie yourself or the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/
Periodic business updates
We may use personal data 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 data
The period for which Paragon will retain personal data 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 data in connection with a potential management position with one of our portfolio companies, we may keep your data until the position has been filled or – subject to your consent – indefinitely to stay in touch for potential future positions.
Individuals whose personal data we hold are entitled to access their personal data, or to request that it is erased, that its processing is restricted, or that any inaccurate personal data is rectified. You also have the right to object to the processing of your personal data. You have the right to data portability, i.e. to receive the personal data concerning you, which you have provided to a Paragon, in a structured, commonly used and machine readable format and have the right to transfer those data to another controller. 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 data to the Supervisory Authority, which in Bavaria is the “Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)”. ( https://www.lda.bayern.de/de/index.html). You can file your complain online under https://www.lda.bayern.de/de/beschwerde.html.
Accuracy and security
Paragon will take all reasonable steps to keep your personal data accurate and, where necessary, up to date. If you believe that any of the data 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 data, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing data online over the Internet and will not hold Paragon responsible for any breach of security if Paragon proves that it is in no event responsible for the event giving rise to the damage.
Paragon Data Privacy Contacts
For all enquires, please email email@example.com
Data Protection Officer for Germany:
Paragon Partners GmbH
Tel. +49 (89) 38 88 70 0