European Addendum

This European Addendum is part of Paradox’s Privacy Policy located at https://www.paradox.ai/legal/privacy-policy (the “Policy”) and aims to give additional information to UK and European Union (“EU”) residents regarding how Paradox processes your Personal Data in order to comply with European laws. The detail set out below, and the specific rights listed, apply only to those in the UK and EU. Capitalized terms not defined herein shall have the meaning set out in the Policy.

It is important that you read this section of the Policy together with the main body of the Policy you so that you are fully aware of how and why we are using your Personal Data. This section of the Policy supplements the other information given and is not intended to override any other part of the Policy.

EU countries are listed below:

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details listed in the Policy under Section 11.2 “Paradox Contact Information”.

You have the right to make a complaint at any time to the relevant data protection regulator in your jurisdiction. Please see below for further details. We would, however, appreciate the chance to deal with your concerns before you approach the relevant regulator so please contact us in the first instance.

As set out in Section 5 of the Policy, Paradox processes your Personal Data for a number of different reasons that we have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one basis has been set out in the table below.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Data.

Right to access Personal Data

You have a right to request that we provide you with a copy of your Personal Data that we hold and you have the right to be informed of; (a) the source of your Personal Data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Data may be transferred.

Right to rectify or erase Personal Data

You have a right to request that we rectify inaccurate Personal Data. We may seek to verify the accuracy of the Personal Data before rectifying it.

You can also request that we erase your Personal Data in limited circumstances where:

• It is no longer needed for the purposes for which it was collected; or
• You have withdrawn your consent (where the data processing was based on consent); or
• Following a successful right to object (see right to object); or
• It has been processed unlawfully; or
• To comply with a legal obligation to which Paradox is subject.

We are not required to comply with your request to erase Personal Data if the processing of your Personal Data is necessary:

• For compliance with a legal obligation; or
• For the establishment, exercise or defence of legal claims;

Right to restrict the processing of your Personal Data

You can ask us to restrict your Personal Data, but only where:

• Its accuracy is contested, to allow us to verify its accuracy; or
• The processing is unlawful, but you do not want it erased; or
• It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

Can continue to use your Personal Data following a request for restriction, where:

• We have your consent; or
• To establish, exercise or defend legal claims; or
• To protect the rights of another natural or legal person.

Right to transfer your Personal Data

You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• The processing is based on your consent or on the performance of a contract with you; and
• The processing is carried out by automated means.

Right to object to the processing of your Personal Data

You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your Personal Data for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your Personal Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of Personal Data safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside of the UK or the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Additional information and contact details

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us using the details listed in the Policy under Section 11.2 “Paradox Contact Information”. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legallyentitled to deal with the request in a different way.