At Paradigm we are committed to ensuring that the data you share with us is treated responsibly.  We want you to be confident that the way we use, store and protect your data is done effectively and with the respect it deserves.          

For the purposes of the General Data Protection Regulation (GDPR) (EU) 2016/679, the data controller is:

Paradigm Partners Limited
Paradigm House
Brooke Court
Lower Meadow Road
Wilmslow
Cheshire, SK9 3ND

Changes to this policy

This privacy policy is subject to change at any time. Paradigm Partners Ltd will communicate any major changes to this policy on its websites or using other methods, where appropriate. Any changes to this policy will be communicated prior to them becoming effective. 

Links to other websites

Our website may contain links to other websites not hosted or controlled by us. You should note that we cannot be responsible for the protection of information which you provide whilst visiting such sites and it’s important to tell you that this privacy policy does not govern these sites.

We accept no responsibility or liability for such other websites and you should always exercise caution when entering personal information online, paying particular note to the privacy statement applicable at the point you may enter such information.

Newsletters and communications

For firms that subscribe to us for regulatory consultancy services, we use a third-party provider, MailChimp ®, to deliver regulatory updates and Paradigm related communications via your email address. Before we can do this we will ask for your consent via a link on our website. MailChimp® self-certify to both the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield regimes, and lawfully transfer EU/EEA personal data to the U.S. pursuant to their Privacy Shield Certification. For more information please see MailChimp’s privacy statement.

Website

We use a third-party service to publish our website. We use a standard service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it.

Using our web based ‘Contact’ and ‘Join’ services

If you use the ‘Contact’ feature of our website we will receive an email which may contain your name, email address, company/firm name/ subject and additional message.

If you use the ‘Join’ feature of our website we will receive an email which may contain your name, email address, phone number and company/firm FCA Number.

This information will not be shared with any other organisations.

People who email us

Our mail services use Transport Layer Security (TLS) to encrypt and protect email traffic between our servers and others that are running this feature. We do not force TLS with other mail services and any transmission encryption using TLS between your mail service and ours will be purely opportunistic. We recommend that all personal or sensitive information sent to us is done using a suitably secure method.

We also monitor any emails sent to us for malicious or prohibited content. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Use of data processors

Data processors are third parties who provide some aspects of our services. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

What we do with the information you provide to us?

All information you provide to us will only be used for the purpose it was collected for, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide to Paradigm with any third parties for marketing purposes. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

Where we store your information

Our servers are situated in inside the European Economic Area (EEA) and all of the information that we collect about you will be stored on these servers.

In certain circumstances your information may be processed outside of the EEA such as when we engage third parties based outside of the EEA to assist us with the services that you have requested from us. In such circumstances, we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Policy. You consent to this transfer and processing of your information.

How we look after your information and how long we keep it for

We use appropriate technological and operational security measures to protect your information against any unauthorised access to or unlawful use. We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as the law otherwise permits.

Transmission of information over the internet can be insecure, and although we employ measures to protect your information from unauthorised access, you acknowledge that we cannot always guarantee the security of information sent over the internet once it has left, or before it reaches, our organisation.

Consent

We will collect your consent for processing any Personal Data other than for the provision and support of your services with us. You have the right to opt-out of additional processing at any time by contacting us directly with your request.

Your rights

Under data protection legislation (GDPR), you have rights as an individual which you can exercise in relation to the information we hold about you. 

You can read more about these rights on the Information Commissioner’s Office (ICO) website at this link: https://ico.org.uk/your-data-matters/

Use of Cookies by Paradigm

When somebody visits www.paradigm.co.uk we collect standard internet log information using Cookies. Our cookies are not used to identify you personally, they are used to make the site work better and allow us to analyse how it is being used. You can delete these cookies any time you want, but some aspects of this site may not work correctly without cookies.

What are cookies?

Cookies are small text files that are placed on your computer by websites that you visit. Websites use cookies to help users navigate efficiently and perform certain functions. Cookies that are required for the website to operate properly are allowed to be set without your permission. All other cookies need to be approved before they can be set in the browser. 

How do we use cookies?

We use cookies to remember if you have agreed (or not) to our use of cookies on this site.

Videos embedded in our pages may use a cookie to anonymously gather statistics on how you got there and what videos you visited.

Google Analytics sets first party cookies via a piece of JavaScript code. It sets four cookies automatically, and a fifth via opt-in.  We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

The following details the cookies in use on this website:

Strictly Necessary

Strictly necessary cookies allow core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies.

Name	Domain	Expiration	Description
_GRECAPTCHA	.google.com	6 months	Google reCAPTCHA sets a necessary cookie (_GRECAPTCHA) when executed for the purpose of providing its risk analysis.

Performance

Performance cookies are used to see how visitors use the website, eg. analytics cookies. Those cookies cannot be used to directly identify a certain visitor.

Name	Domain	Expiration	Description
_ga	.paradigm.co.uk	2 years	This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.

Targeting

Targeting cookies are used to identify visitors between different websites, eg. content partners, banner networks. Those cookies may be used by companies to build a profile of visitor interests or show relevant ads on other websites.

Name	Domain	Expiration	Description
PHPSESSID	www.paradigm.co.uk	Session	Cookie generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages.
YSC	.youtube.com	Session	This cookie is set by YouTube to track views of embedded videos.
VISITOR_INFO1_LIVE	.youtube.com	6 months	This cookie is set by Youtube to keep track of user preferences for Youtube videos embedded in sites;it can also determine whether the website visitor is using the new or old version of the Youtube interface.
IDE	.doubleclick.net	1 year	This cookie is set by Doubleclick and carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Other Cookies

Name	Domain	Expiration	Description
thirdPartyCookiesEnabled	.purechat.com	1 day	Purechat sets cookies to enable use of the online chat facility.
_PCCSID_444641	.purechat.com	20 minutes
_PCCID	.purechat.com	5 years

How to control cookies

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

How to contact us

If you would like further information about this privacy policy you can contact us using the details below:

Data Governance Manager
Paradigm Partners Limited
Paradigm House
Brooke Court
Lower Meadow Road
Wilmslow
Cheshire, SK9 3ND

[email protected]