Privacy Policy

Paragon Philanthropy Inc., the owner and provider of this Website, takes the privacy of your information very seriously. Our services are provided exclusively to our grantmaking clients in the United States. Our clients include U.S. private foundations, donor advised fund sponsoring organizations, and grantmaking public charities. Our services include:

  1. Equivalency Determination PLUS

  2. Expenditure Responsibility PLUS

  3. Anti-terrorist financing screening

  4. Politically Exposed Person (PEP) screening

  5. Adverse Media Screening (AMS)

  6. Grantee Credibility Assessment

This privacy policy applies to our use of any and all Data collected by us or provided by you as (i) a user of this Website; (ii) a client of Paragon Philanthropy Inc., and (iii) an individual or organization being screened by Paragon Philanthropy Inc. for international grantmaking or anti-terrorist financing purposes. 

For website users, this privacy policy should be read alongside, and in addition to, our Terms of Use, which can be found at: https://www.paragonphilanthropy.com/termsofuse.

Please read this privacy policy carefully.

Definitions and interpretation 

1. In this privacy policy, the following definitions are used:

  • Data: collectively all information that you submit to Paragon Philanthropy Inc. via (i) the Website; (ii) email; or (iii) secure online forms operated by Paragon Philanthropy Inc. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

  • Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);

  • Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR;

  • GDPR: the General Data Protection Regulation (EU) 2016/679;

  • Paragon Philanthropy Inc., we or us: Paragon Philanthropy Inc., a company incorporated in the United States;

  • Data Controller: As defined by the GDPR, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

  • Data Processor: As defined by the GDPR, a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

  • User or you: (i) a user of this Website; (ii) a client of Paragon Philanthropy Inc., and (iii) an individual or organization being vetted by Paragon Philanthropy Inc. on behalf of our clients for counterterrorism screening or international grantmaking purposes; and

  • Website: the website that you are currently using, https://www.paragonphilanthropy.com/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

Any undefined term in this Privacy Policy has the same definition as that used by the European legislature for the adoption of the GDPR.

2. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d."including" is understood to mean "including without limitation";

e. reference to any statutory provision includes any modification or amendment of it;

f. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. With the exception of online forms operated by Paragon Philanthropy Inc. and hosted by Jotform (see Jotform, below), the application of this privacy policy does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Paragon Philanthropy Inc. is the "Data Controller”.

What Data do we collect?

Personal data will be processed on the basis of the consent of the data subject concerned or on the basis of another legitimate interest.

Data we collect via this website:

5. We may collect the following Data, which includes personal Data, from you, via this website:

a. name;

b. contact Information such as email addresses and telephone numbers;

c. IP address (automatically collected);

d. web browser type and version (automatically collected);

e. operating system (automatically collected);

f. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

g. data you provide to us to fulfill a specific request related to the delivery of our counterterrorism screening or international grantmaking compliance services;

in each case, in accordance with this privacy policy.

Data we collect from screened entities on behalf of our clients (via email, online forms, or telephone communications):

6. We collect the following information that is necessary to the provision of our services:

When screening an individual that is the recipient of a grant or payment from one of our clients, we obtain the individual’s name and date of birth and screen this information against government watchlists. If we are unable to resolve any matches with this information alone, we may request additional personal Data to attempt to resolve the match. 

We only share Personal information provided by an individual if the individual specifically consents to it being shared with the grantmaking client that requested it.

When screening an organization that is the recipient of a grant or payment from one of our clients, we obtain from the organization the names and titles of associated key staff members, board members, founders, and organization contacts, and screen these names against the watchlists.  We also obtain the name(s) used by the organization and, depending on the service we are providing to the requesting client, additional information and documents such as the organization’s mission, budget, governing documents, and certificate of legal registration.

We only share Personal information provided by an organization if the organization specifically consents to it being shared with the grantmaking client that requested it.

We retain information provided by individuals and organizations as long as is necessary to complete the service we are providing to our client and assist them in meeting any regulatory requirements.

Any grantmaking client receiving Personal information from Paragon as described above is also a Data Controller for purposes of the applicable Data Protection Laws.

How do we collect Data?

7. We collect Data in the following ways:

a. data is given to us by you; and

b. data is collected automatically.

Data that is given to us by you:

8. Paragon Philanthropy Inc. will collect your Data in a number of ways, for example:

a. when you contact or communicate with us through the Website, by telephone, post, e-mail, online form, or through any other means;

b. when you elect to receive marketing communications from us;

c. when you use our services;

d. when you respond to our request for information required in order to complete a client service request;

in each case, in accordance with this privacy policy.

Data that is collected automatically:

9. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

How do we use Data?

10. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a. internal record keeping;

b. to deliver our services; 

in each case, in accordance with this privacy policy.

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

With whom do we share Data?

12. We may share your Data with the following groups of people for the following reasons, in each case in accordance with this privacy policy:

a. our employees and our grantmaking clients, to deliver our services;

b. providers used to support delivery of our services. Paragon uses the following service providers to collect, screen, or store Data. Paragon has DPAs (Data Processing Agreements) in place with each:

When screening individuals and organizations for grant compliance and anti-terrorist financing purposes we:

When collecting information from prospective clients via our online form:

How do we keep Data secure?

13. We will use technical and organizational measures to safeguard your Data and prevent its loss or misuse. For example, we store your Data on secure servers, and we only use data processors that are GDPR compliant.

14. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via our contact form at:  https://www.paragonphilanthropy.com/contact

Data retention

15. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or until you request that the Data be deleted.

16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

17. You have the following rights in relation to your Data:

a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase - the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

e. Right to data portability - the right to request that we move, copy or transfer your Data.

f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

18. To make inquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via our contact form at https://www.paragonphilanthropy.com/contact or by mail at Paragon Philanthropy Inc., 2028 E. Ben White Blvd., Ste. 240-1100, Austin, TX 78741, USA. Paragon Philanthropy Inc. is a company incorporated in California. Our corporate representative and data protection officer is Andrzej Kozlowski, CEO/Managing Director.

19. If you are not satisfied with the way a complaint you make in relation to how your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the GDPR, this is the Office of the Inspector General for the Protection of Personal Data; For the UK, this is the Information Commissioner's Office (ICO). For complaints unrelated to GDPR, nothing in this Privacy Policy is intended to limit your right to file a complaint in the appropriate jurisdiction.

20. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers outside the European Economic Area

21. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. 

22. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, or by incorporating the current standard contractual clauses adopted by the European Commission.

23. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties with whom we share your Data. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

24. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

25. Paragon Philanthropy Inc. may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Paragon Philanthropy Inc. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

26. We may also disclose Data to a prospective purchaser of our business or any part of it. 

27. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General 

28. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

29. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

30. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

31. This Agreement will be governed by and interpreted according to the laws of California, United States of America. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of California courts.

Changes to this privacy policy

32. Paragon Philanthropy Inc. reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Paragon Philanthropy Inc. via our contact form at https://www.paragonphilanthropy.com/contact.

Cookies

33. Paragon by default disables nonessential, analytics cookies unless a visitor has acknowledged the following banner on our website: “By using this website, you agree to our use of cookies. We use cookies to provide you with a better experience and to help our website run effectively.” 

A description of the functional, required, analytics, and performance cookies we use can be found here: https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Children under thirteen

34. Paragon does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

 

Effective as of May 25, 2018

 

Attribution

This privacy policy was created and adapted using Rocket Lawyer