Who we are
This Privacy Policy governs the manner in which Shift Paradigm Holdings, LLC and its affiliates and subsidiaries (collectively “Shift Paradigm”) collects, uses, maintains and discloses information collected from users (each, a “User”) of the shiftparadigm.com website, and its related social media accounts (collectively, the “Sites”).
WHAT INFORMATION IS COVERED BY THIS POLICY?
Shift Paradigm collects two overall types of data: 1) Customer Data, such as user data of Shift Paradigm customers, in Shift Paradigm’s provision of services to its customers; and 2) User Data from visitors to its website. This is an important distinction that will continually be made in Privacy Policy, because the applicability of certain provisions, and awareness of additional contractual terms between Shift Paradigm and its customers, will depend on whether the data in question is either User Data, or Customer Data.
1. SHIFT PARADIGM CUSTOMER USER DATA
Customer Data. As noted above, since Shift Paradigm is a digital marketing service provider to businesses, written agreements between Shift Paradigm and its customers document the specific business purpose for Shift Paradigm’s collection of the user data of Shift Paradigm customers, if any. At times, and to allow Shift Paradigm to do its job, Shift Paradigm may receive identifiable personal information for those purposes outlined in its agreements with customers (“Customer Data”). Those agreements between Shift Paradigm and its customers, in addition to applicable provisions of this Privacy Policy, govern what Shift Paradigm does with Customer Data.
Regardless, Shift Paradigm does not use Customer Data for any purpose other than: 1) as permitted by customer agreements; and/or 2) on behalf of its customers in combination with personal information received from one or more other Shift Paradigm customers, to the extent necessary to detect data security incidents, or protect against fraudulent or illegal activity. The privacy policies of Shift Paradigm’s respective customers govern rights of consumers as to the personal information they may have previously provided to them, and that therefore may be present in some of the Customer Data processed by Shift Paradigm. Shift Paradigm’s customers are asked in agreements with Shift Paradigm to acknowledge their own compliance with applicable law in collection of data from their own users, and provision of such data to Shift Paradigm for use in the services Shift Paradigm provides.
Responding to Consumer Requests: Should Shift Paradigm receive a request to know or a request to delete from a consumer (or other similar request) regarding personal information contained in the Customer Data Shift Paradigm collects, maintains, or sells on behalf of its customer(s), Shift Paradigm will defer its response to such request to the applicable customer(s) (if any) so that the customer can carry out appropriate verification of the request, assessment, and resulting actions with respect to all of the requestor’s personal information (and not just that portion maintained or processed by Shift Paradigm). In compliance with applicable law, Shift Paradigm will inform the requestor that it should submit any such request directly to the business on whose behalf Shift Paradigm processes the information (if any) and, when feasible, provide the requestor with contact information for that customer.
International Data Transfers. Shift Paradigm has integrated into its agreements with certain customers the European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for those customers who operate in the European Union and the United Kingdom, and/or for other international transfers of Customer Data. A standard data processing addendum is agreed upon with customers who will provide Customer Data subject to such requirements. Shift Paradigm’s privacy practices, as described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.
Data Processed. We provide the Business Services to help customers market their products and services, and otherwise operate the marketing functions of their businesses. In providing the Business Services, the Customer Data we process may contain messages, files and other content our customers ask us to process in connection with our Services. As set forth in this Privacy Policy, Shift Paradigm collects other information that is not intended to be collected or transferred from residents of the European Union, the United Kingdom, or Switzerland (“Other Information”), such as email newsletter sign-up data, Sites usage, and cookie information.
Purposes of Data Processing. We process Customer Data for Business Services only in accordance with customer’s instructions, including any applicable terms in a customer’s agreement, and as required by law. Shift Paradigm is always a processor of Customer Data; Shift Paradigm’s customer is always the controller. We may therefore need to access Customer Data to provide the Services, to prevent or address service or technical problems, to respond to customer support matters, to follow the instructions of our customer who submitted Customer Data, or in response to contractual requirements with our customers. As set forth in this privacy Policy, Shift Paradigm uses Other Information in furtherance of our legitimate interests in operating our Services, Sites and business.
Third Parties With Whom We May Share Data. We use a limited number of third party providers to assist us in providing the Services to our customers and to support our business. As of the date of this Privacy Policy revision (posted below), these third party providers perform technical operations, such as database monitoring, data storage and hosting services, and help us provide customer support and other business functions. These third parties may access, process or store personal data in the course of providing these services, but do so only based on our instructions and for the purposes for which the personal data was originally obtained from Shift Paradigm customers. Those third party providers are currently as follows:
You should check this Privacy Policy periodically to determine if we have updated the above list.
Questions or Complaints. If you are a resident of a European country and you believe we maintain your personal data, you may direct any questions or complaints concerning compliance to the email or physical address provided at the bottom of this Privacy Policy.
Rights of Access and Choice. Some international users have certain legal rights to access certain personal data we hold about them and to obtain its correction, amendment or deletion. Those users may exercise some of those rights through the options described in our Privacy Policy, but since Shift Paradigm has a limited ability to identify and access an individual user’s personal data that a Shift Paradigm customer has submitted to the Services, if you wish to request access, to limit use, or to limit disclosure, we may first refer your request to the customer(s) who provided your personal data to Shift Paradigm, and we will support them as needed in responding to your request.
Requirement to Disclose. We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.
Sites Not intended For Use In Europe. We control and operate the Sites from the United States and Canada, and the Sites are not marketed to, intended to be utilized by, nor intended to be subject to the laws or jurisdiction of any country or territory in the European Union (EU) or European Economic Area (EEA). Other than as provided herein, Shift Paradigm does not represent or warrant that the Sites are appropriate for use in the EU/EEA, and those who choose to access the Sites or use our Service from the EU/EEA do so at their own initiative and are responsible for complying with all applicable laws, rules and regulations. The interpretation and enforcement of this Policy shall not be governed by the rules and regulations applicable to the EU/EEA.
The remainder of this Privacy Policy is primarily applicable to what has been described above as User Data collected by Shift Paradigm on its Sites, rather than Customer Data. If you have any questions about Customer Data, or wish to request that Shift Paradigm provide you with contact information for those of its customers who may have provided Shift Paradigm with your personal information, please contact us at the address, telephone number, or email provided at the end of this Privacy Policy.
2. USER DATA
User Data (i.e., data collected from visitors to Shift Paradigm’s website). There are only two types of User Data we collect for Shift Paradigm’s own business purposes, and how it is used or shared depends on the reason(s) why it was collected. The purpose, however, is always to facilitate communication with businesses and people who utilize, or may become a future customer of, Shift Paradigm’s digital marketing services. To that end, Shift Paradigm collects the following categories of User Data:
- Identifiable information, and anonymous information, through technologies such as “cookies” collected when you visit and interact with the Sites, as more fully described in the cookies section below; and
- Identifiable personal information you voluntarily give us (such as your name, address, telephone number, email address, or other information requested) so that we can communicate with prospective customers, current customers, former customers, and visitors further about our services, offerings, and digital marketing industry news and events that may be of interest to you, as well as in the course of providing services to Shift Paradigm customers, whether or not collected through the Site or otherwise.
PERSONAL IDENTIFICATION INFORMATION
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, fill out a form, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site or outside or the Site. By way of example, Users may be asked for, as appropriate, name, email address, mailing address, phone number. We will collect personal identification information from Users only if they voluntarily submit such information to us through the Site or otherwise. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities or obtaining services from Shift Paradigm for which it is necessary to first obtain such information.
NON-PERSONAL IDENTIFICATION INFORMATION
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
WEB BROWSER COOKIES
Our Site may use “Cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. Cookies on our site include:
rc::a
rc::b
rc::c
Cookie purpose description: These cookies are used to distinguish between humans and bots. This is beneficial for the web site, in order to make valid reports on the use of their web site.
ads/ga-audiences google.com
Cookie purpose description: Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behavior across web sites.
NID
Cookie purpose description: Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads.
_ga shiftparadigm.com
Cookie purpose description: Registers a unique ID that is used to generate statistical data on how the visitor uses the web site.
_gat shiftparadigm.com
Cookie purpose description: Used by Google Analytics to throttle request rate._gid shiftparadigm.com
Cookie purpose description: Registers a unique ID that is used to generate statistical data on how the visitor uses the web site.
collect google-analytics.com
Cookie purpose description: Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.
bcookie
lids
Cookie purpose description: Used by the social networking service, LinkedIn, for tracking the use of embedded services.
lang
Cookie purpose description: Remembers the user’s selected language version of a web site.
UserMatchHistory
Cookie purpose description: Used to track visitors on multiple web sites, in order to present relevant advertisement based on the visitor’s preferences.
Marketo
Marketo Munchkin (_mkto_trk)
This cookie is set by Marketo. This allows a website to track visitor behavior on the sites on which the cookie is installed and to link a visitor to the recipient of an email marketing campaign, to measure campaign effectiveness. Tracking is performed anonymously until a user identifies himself by submitting a form.
Crazy Egg
AWSELB
Cookie purpose description: Used to distribute traffic to the web site on several servers in order to optimize response times.
HOW WE USE COLLECTED INFORMATION
Shift Paradigm may collect and use Users personal information for the following purposes:
- To run and operate our Site we may need your information to display content on the Site correctly.
- To improve customer service, information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience we may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To run a promotion, contest, survey or other Site feature.
- To send Users information they agreed to receive about topics we think will be of interest to them.
- To send periodic emails
- To respond to inquiries, questions, and/or other requests.
HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
SHARING YOUR PERSONAL INFORMATION
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding. We may share personal information for legal, protection, and safety purposes, such as to comply with laws, to respond to lawful requests and legal process, to enforce our agreements, policies, and terms of use, and to protect the safety of our employees, agents, customers, or any person. It is important to note and understand that unless we have arranged otherwise in an express contractual term with a customer, all personal information collected or processed by Shift Paradigm (whether Customer Data or User Data) is stored in the United States, and could therefore be accessed by courts, law enforcement and national security authorities in the United States. We may also share aggregated and/or anonymized data with others for their own uses. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
ELECTRONIC NEWSLETTERS
If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
MINIMUM AGE
To the extent prohibited by applicable law, Shift Paradigm does not allow use of our Sites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
CHANGES TO THIS PRIVACY POLICY
Shift Paradigm has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
YOUR ACCEPTANCE OF THESE TERMS
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
HOW YOU CAN CHANGE INFORMATION YOU PROVIDED
If you have provided information to Shift Paradigm and would like it deleted from our records, or you would like to access or update information you’ve given us, please send an email to privacy@shiftparadigm.com.
CONTACTING US
Shift Paradigm does not send or condone unsolicited email, or “spam”. We send email only to people who have requested our newsletter, or asked for information about us.
If you feel you’ve received unsolicited email from Shift Paradigm, please send a message to privacy@shiftparadigm.com. We promise to deal with your issue promptly.
Email addresses found on this page do not accept consent to receive promotional email messages.
Any question, concern or complaint concerning compliance with our Privacy Policy, including requests regarding personal information of consumers processed by Shift Paradigm on behalf of its clients, should be addressed to our Privacy Officer:
Chris Arrendale
Chief Privacy Officer (Data Protection Officer)
Phone: 470-369-6711
Email: privacy@shiftparadigm.com