Website Privacy Notice

Paragraf Limited known as Paragraf or the Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we process your personal data on our website where you are a customer, supplier of services or a visitor on our website. This privacy notice also tells you about your privacy rights pursuant to Data Protection Laws such as the UK Data Protection Act 2018, the General Data Protection Regulation (UK GDPR) and the EU GDPR.

A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise Paragraf is the controller of your personal data for the purpose of this website.

This privacy notice applies to the processing of personal data by us in connection with:

• Customers: where we provide our services or products to you.
• Suppliers: For the provision of products and services to us by suppliers or service providers.
• Website visitors: Anyone browsing our website or interacting with our content online.

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

Paragraf may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity Data includes first name, last name, username or similar identifier and title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details
• Transaction Data includes details about payments to and from you and other transaction details for the provision of services.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or platform.
• Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Depending on your relationship with us we may process the categories of data above and categories of specific personal data that is specific to you. Please see below in the Processing Table on how we may process your personal data depending on our relationship with you and our lawful basis for doing so.

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

• Performance of a contract: Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when you order our products.
• Legal obligation: Where we need to comply with a legal obligation. For example, for accounting or legal purposes.

• Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
• Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at privacy@paragraf.com to withdraw consent. Please also see Marketing communications.
• Vital interests: Where it is necessary to protect your vital interests in case of emergencies.
• Public obligation: Where we need to comply with a public obligation, for example in the matters of public health or public interests.

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments; or (iii) by corresponding with us by email, post or by telephone.

Third-party sources: We receive Identity Data and Contact Data about you from third parties when:

• other parties send us your personal data to enable the provision of our products and/or services to you; or
• you provide your personal data to a third party for the purpose of sharing it with us.

The processing tables explain why we process personal data and the lawful basis for doing so. Depending on your relationship with us, you may need to refer to different tables relevant to your specific interactions or services.

Business Customer: Processing Information

This is where we directly transact with you to provide you with our services/products, i.e. where you are a customer.

Supplier: Processing Information

This is where you are a supplier of products and services to us.

Website visitor: Processing Information

This is where you are a website visitor on our website, regardless of whether you will be taking up our products or services.

We use artificial intelligence (AI) tools to enhance our services and provide you with a better experience. These tools assist us in improving efficiency, identifying trends and tailoring our offerings to your needs. However, please note that our use of AI is limited to supporting and streamlining our processes and it does not involve making decisions about you. All decisions related to your interactions with us are made by our team, ensuring a personal and thoughtful approach. We are committed to transparency and safeguarding your privacy as we continue to leverage technology responsibly for your benefit.

We may gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. Please also refer to our cookies notice for more information on how we set cookies.

Where we need to collect personal data by law or under the terms of a contract and you do not provide that information when requested we may not be able to perform the contract we have or are trying to enter into with you for example to provide you with our services. In this case we may have to cancel our service, but we will notify you if this is the case at the time.

We may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

In certain circumstances, we may disclose your personal information to third parties for contract fulfilment purposes, legitimate purposes and other reasons subject to this Notice.

Such circumstances where we disclose information may include:

• Internally: Your personal data will be used by our employees and contractors who are working on providing our products and services to you, on a need-to-know basis.
• With our affiliates: We may share information within our corporate group to operate and manage our business effectively and to provide you with the products and services you request.
• Our service partners: With vendors or other third parties who perform services on our behalf (for example IT management, cloud storage, fulfilment and shipping).
• Legal advisors: To enforce any applicable terms of service and to protect or defend the Services, our rights and the rights of our users or others.
• Professional advisers: This would include bankers, auditors and insurers who provide consultancy, banking, insurance and accounting services.
• Payment Service Intermediaries: These providers help facilitate payment to us.
• Business transactions: This is in connection with a business transaction, such as a funding round or acquisition. Where this is the case, your personal data shall continue to be processed in accordance with this Privacy Notice.

We may transfer and process your personal data outside of the United Kingdom (UK) /European Union (EU) to countries where data protection laws are less stringent than those in the UK/EU. When we transfer your personal data outside of the UK/ EU we only do so to entities that offer our users the same level of data protection as that afforded by the UK Data Protection Act 2018 (including the UK GDPR) and the EU GDPR/ Data Protection Laws.

1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
2. We will use specific contracts approved for use in the UK or EU which give personal information the same protection it has in the UK/EU. For example, the use of Article 46 UK and EU GDPR safeguard mechanisms to transfer personal data endorsed by the UK Government or European Commission.

To find out more about the transfer mechanism used please contact us at privacy@paragraf.com

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Paragraf cannot guarantee the security of your information transmitted and any transmission is at your own risk.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, you have rights under Data Protection Laws. Not all rights are absolute and depending on where you are located, not all rights are given to you. You can:

Request access to your personal data: This is known as a “subject access request” and enables you to receive a copy of the personal data we hold about you.

Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims.  See also Marketing communications.

Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.

Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, we may not be able to provide certain services to you if you withdraw your consent. We will advise you if this is the case at the time you withdraw your consent.

Automated decision making:  This is where decisions are made about you by automated means. We do not carry out automated decision making.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us at privacy@paragraf.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Please contact us if you wish to update your personal data.

We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved issues, you have the right to complain at any time to a data protection supervisory authority for data protection issues such as the UK data protection regulator – the Information Commissioner’s Office (ICO).

You may lodge a complaint with a supervisory authority if you live or work outside the UK or you have a complaint concerning our personal data processing activities.

This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.