This Privacy Policy explains how information is collected, used, and disclosed by Paragraph Inc. (“Paragraph”) and applies to information collected when you use or access Paragraph’s website at www.paragraph.ph (the “Website”) or when you use the software-as-a-service we offer through the website (together with the Website, the “Service”). We respect the privacy rights of users and recognize the importance of protecting information collected about you.

Please read the following carefully to understand how we will collect, use, and maintain your personal information. It also describes your choices regarding the use, access, and correction of your personal information. By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy.

We may change this Privacy Policy from time to time. If we make any changes, we will revise the "Last Updated" date at the end of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Service to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate your account with us and stop using the Service. Your use of the Service after the posting of such changes shall constitute your consent to such changes.

We may collect certain user information (including personal information and/or sensitive personal information) in the following ways:

Information You Provide To Us. We collect information you provide directly to us including when you visit the Website and/or use our Service.

• For example, we collect information when you enter into an agreement with Paragraph as a customer, create or modify your profile and account, access and use the Service (including but not limited to when you upload, download, or share information), participate in any interactive features of the Service, submit a contact form, participate in a survey, activity or event, apply for a job, request customer support, or communicate with us via third-party social media sites.
• The types of information we may collect directly from you include your name, email address, postal address, phone number, information about your account preferences, employer name, job title, transactional information (including services purchased or subscribed to and billing address), as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in your account profile may reveal or identify information that is not expressly stated (for example, information you provide may reveal your gender). We also store information that you upload or provide to the Services in order to provide you with the features and functionality of the Service.

Information Your Employer Provides to Us. We collect information about individual users from our corporate customers who employee them.

• For example, if your employer is one of our corporate customers, they may provide to us, either directly or via integration with their other systems, personal data about you, such as your name, email address, work postal address, phone number, and job title.

Information We Collect Automatically When You Use the Service. When you access or use the Service, we may automatically collect information about you, including:

• Usage, Log, and Device Information: We collect information from your use of the Service such as system activity, hardware settings, browser type, browser language, the date and time of your visit, and the referral URL. We monitor user activity in connection with the Service and may collect information about the features you use, the content you upload, download, share, or access while using the Service, the content you access, and any actions taken in connection with the access and use of your content in the Service.
• Information Collected by Cookies and Other Tracking Technologies: A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

Integrated Services. You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Gmail account and Google’s API Services (“Google API Access”), or otherwise have the option to authorize an Integrated Service to provide personal data or other information to us, including, in the case of Google API Access, the content of email messages. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, email message contents and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

We may use the information collected through the Service for the limited purpose of providing the Service and related functionality and services for which Paragraph has been engaged. The information may be used for a variety of purposes, including:

• Provide, operate, maintain, and improve the Service;
• Enable you to access and use the Service;
• Allow you to send and receive messages and compose drafts using the Service in connection with an Integrated Service;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Provide and deliver the services and features you request, process, and complete transactions, and send you related information, including purchase confirmations and invoices;
• Respond to your comments, questions, and requests, and provide customer service and support;
• Communicate with you about services, features, surveys, newsletters, offers, promotions, events, and provide other news or information about Paragraph and our select partners;
• Monitor and analyze trends, usage, and activities in connection with the Service;
• Investigate and prevent unauthorized access to the Service, and other illegal activities;
• Personalize and improve the Service, and provide content and/or features that match your interests and preferences or otherwise customize your experience on the Service;
• Generate anonymized and aggregated analyses, benchmarks and statistics; and
• For other purposes about which we notify you.

Additionally we may disclose personal data in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) protect and defend our rights or property; or (c) act to protect the interests of our users or others.

Do Not Track. Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

Additional Limits on Use of Your Google and Github User Data

Notwithstanding anything else in this Privacy Policy, if you provide the Service with access to your Gmail data via Google API Access, our use of that data will be subject to these additional restrictions:

• We will not use this Gmail data for serving advertisements.
• We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the Service’s internal operations and even then only when the data have been aggregated and anonymized.
• Paragraph's use and transfer to any other app of information received from Google and Github APIs will adhere to Google API Services User Data Policy and Github API Services User Data Policy, including the Limited Use requirements. .

We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy, or as defined in an agreement with us, in connection with the Service. For example, we may share personal information about you:

• To Vendors, Consultants, and Other Service Providers: We may share your information with third-party vendors, consultants, and other service providers who are working on our behalf and require access to your information to carry out that work, including companies that provide services such as cloud hosting and customer database software. These service providers are authorized to use your personal information only as necessary to provide services to Paragraph.
• In Compliance with Laws: We may disclose your information to a third party: (a) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; (b) to enforce our agreements and policies; (c) to protect the security or integrity of the Service; (d) to protect Paragraph, our customers, or the public from harm or illegal activities; (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or (f) as otherwise directed by you.
• For Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You may be notified thereafter via email of any such change in ownership or control of your personal information.
• As Aggregated and/or Anonymized Data: We may also share aggregated and/or anonymized information with third parties that does not directly identify you.

We have adopted reasonable physical, technical, and organizational safeguards designed to protect against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of information we collect. All personal data processed by the Service is encrypted both in transit and at rest using AES-256 encryption.

To protect the confidentiality of your information, you must keep your account credentials confidential and not disclose them to any other person. Please advise us immediately if you believe your account credentials have been compromised in any way. In addition, please always log out and close your browser when you finish your session.

Account Information and Retention. You may update, correct, or delete information about you at any time by logging into your account on the Service and modifying your information, or by emailing us at [email protected]. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email us at [email protected] but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days.

We will retain your information for as long as your account is active or as needed to provide you with the Service. We will retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will retain personal data we process on behalf of our customers as directed by paying customers. Paragraph will retain this personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

Upon request, Paragraph will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information that we are aware of. To request this information, contact us at [email protected].

Promotional and Newsletter Communications. You may opt out of receiving promotional and newsletter emails from Paragraph by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing [email protected] with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Service or those about your account or our ongoing business relations.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Service.

California Residents. In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. To the extent we share your personal information in this way, you may receive the following information:

(a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and

(b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section.

For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. We will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.

To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. We do not sell your personal information in our ordinary course of business and will never sell your personal information to third parties without your explicit consent.

To make such requests, contact us at [email protected] or the other contact information set out below.

If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

In accordance with California Civil Code Section 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at (916) 445-1254 or (800) 952-5210; or by email to [email protected].

We may place links on the Service. When you click on a link to a third-party website from our Website, your activity and use on the linked website is governed by that website’s policies, not by those of Paragraph. We encourage you to review their privacy and user policies.

Any questions about this Privacy Policy should be addressed to [email protected]

To report vulnerabilities, please email [email protected]