Last Updated: 05^th January 2020

We at Paragon Micro UK Ltd ("Paragon Micro", "we" or "us") understand that making purchases online involves a great deal of trust on your part. We take that trust seriously. This privacy policy is an effort to answer your privacy-related questions. If you have questions that are not addressed herein, please submit them to us by sending an email to enquiriesuk@paragonmicro.com.

The purpose of this privacy policy (the "Policy") is to help you understand what kind of personal identifiable information we may gather about you when you visit the Paragon Micro Web site located at www.paragonmicro.co.uk and related sub- domains (the Site), how we may use that information whether we will disclose it, and how you can correct or update it. We note that this Policy sets forth our online information collection and use policies under UK Law. The site is intended for use by residents of the UK. who are over the age of 18. We do not knowingly collect personally identifiable information from children (that is minor younger than thirteen years of age).

If you do not agree to the terms of this Policy you should not use the Site. We reserve the right to update or modify this Policy from time to time, and such changes to the Policy will be effective immediately, therefore please bookmark this page and review it periodically to assure familiarity with the most current version of the Policy. You can tell if the Policy has been updated since you last reviewed it by checking the "Last Revised" date at the beginning of the Policy.

This Policy is the sole authorised statement of Paragon Micro's practices with respect to the online collection of personal information through the Site and the usage of such information. Any summaries of this Policy generated by third party software or otherwise shall have no legal effect, are in no way binding upon Paragon Micro, shall not be relied upon in substitute of this Policy, and neither supersede or modify this Policy.

To assist you with your review of our Policy, we have provided answers or questions that you may find important.

• What Personal Information We Collect
• How We Use the Personal Information We Collect
• How We Share or Disclose Personal Information We Collect
• Special Notification to California Residents
• Marketing Communications: Opting Out
• Cookies
• Web Beacons
• How We Protect Your Personal Information
• Other Information We Collect
• Advertisers
• Google Analytics
• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Sweepstakes and Promotions
• Co-branded Sites: Links to Other Sites
• Online vs. Offline Practices
• Contacting Paragon Micro

What Personal Information We Collect

Paragon Micro collects personal information that you specifically and voluntarily provide on the Site. Personal Information (“PI”) is information that identifies you as a specific individual, for example, your name, account number, physical or email address, and phone number, or from which you are identifiable. For example, we collect PI from you when you:

• Make a purchase
• Create an account
• Subscribe to our newsletter
• Request a catalog
• Participate in a survey
• Register at our website

How We Use the Personal Information We Collect

We use the PI that you provide to us in order to 1) fulfill requests for products, services and/or information, 2)provide customer service, 3) offer products and services to you, 4) measure and improve the effectiveness of our Site and our marketing endeavors, 5) tailor our online offerings to your preferences, 6) administer promotions or surveys, or 7) achieve other business purposes as permitted under applicable law.

When you make a purchase on our Site we collect credit card information including card number, card type, cardholder name and billing address, and expiration date in order to bill you for purchases made through us.

How We Share or Disclose Personal Information We Collect

Paragon Micro may disclose PI to service providers, consultants, professional advisors and contractors who perform services on our behalf. These disclosures may be to recipients based in other jurisdictions, such as the US, which may have a lesser standard of data privacy laws compared to those in your country of residence. At times, we may seek to validate the PI we have collected via an audit by a third party designed to determine the accuracy of and/or to update information collected. We may also combine data that we collect online with data collected offline (such as through purchases made through one of our catalogs), or with data provided by other parties

We reserve the right to disclose PI concerning any visitor when that visitor is believed by Paragon Micro to be in violation of any published guidelines for the use of the Site or participates (or is suspected of participating) in any illegal or potentially illegal activity. We also reserve the right to disclose PI to comply with applicable law or a regulatory request or in response to civil subpoenas or discovery requests or otherwise when we believe in good faith that disclosure is required to protect the rights, property, safety or security of Paragon Micro, our visitors or the public, or to respond to an emergency.

Paragon Micro also may share PI with third parties for marketing and other business of Paragon Micro and our affiliates. For example, we may share PI collected from our visitors and customers with our affiliated or related companies, including our parent company, affiliates, and subsidiaries, or our parent company’s other subsidiaries( collectively, our “affiliates”). We also may share PI with unaffiliated third parties, such as our marketing or business partners. For purposes of this Policy, “unaffiliated third parties” are third party individuals or entities not affiliated with Paragon Micro or our affiliates.

In the event that we sell or otherwise transfer to a third party assets related either (a) to the Site (b) to one or more of our businesses, divisions or affiliated companies, we reserve the right to also transfer any and all information (including any PI) associated with the Site and/or any business, division or affiliated company to such third party.

Marketing Communications: Opting Out

Other than residents in the European Union, when you provide PI to us, including when registering to receive email newsletters, catalog subscriptions or other information, or to make a purchase, Paragon Micro provides you with the opportunity to opt- out of having your PI used by us to send you advertising or promotional materials. Unless you have opted out of receiving such marketing materials we may use your PI to send you via email, or postal mail advertisements concerning our products, services, special promotions, surveys or other opportunities from us that we think may be of interest to you. Such advertisements may also concern third party companies, products and services including companies in industries such as hardware and software, and other providers of the types of products that are sold or featured on the Site.

Paragon Micro has partnered with unaffiliated third parties to offer our customers and Site visitors a variety of products and services. We may share PI (such as physical mailing address - but not your email address) with our third -party marketing partners in order for them to offer you additional products and services that we believe may be of interest to you. Although we only work with third parties whom we believe to be reputable, our third- party marketing partners may have different privacy policies and practices than Paragon Micro. We are not responsible for the privacy practices of our marketing partners or any other third parties.

Special Notification for European Union Residents

Paragon Micro will ask you for express opt in consent to us using your PI for marketing, advertising or promotional purposes and to Paragon Micro sharing your PI with unaffiliated third parties.

Cookies

Upon visiting our Site we will assign you a unique ID in the form of a "cookie". A cookie is a piece of information that our server places in your computer's hard drive, which we may associate with your PI when you log on to the site. Cookies are used for such purposes as facilitating and personalising your shopping and ordering experience, keeping track of your shopping basket during your visit, helping diagnose problems with our server and administering our Site. We may use the information collected through cookies for marketing purposes to inform you of special offers, better understand your needs or answer your questions.. NOTE: You can control how and whether cookies will be accepted by your web browser, and you may remove them from your computer at any time at your discretion. We recommend, however, that you accept and leave cookies on as they enable you to utilise some of our features or services. Blocking or rejecting our cookies will prevent you

Web Beacons

Some of Paragon Micro Web pages and HTML -formatted e-mail newsletters may use Web beacons to compile aggregate statistics about website usage. A Web beacon is an electronic image often called a single- pixel (1x1) or clear GIF, which is ordinarily not visible to the site visitor. Web beacons can recognise certain types of information on a visitor's computer, such as visitor's cookie number, time and date of page or image view and 2description of the page where the web beacon is placed. When used in an e-mail they can tell us whether an e- mail has been opened. NOTE: You may control whether your email client is allowed to download images and web beacons.

How We Protect Your Personal Information

To help protect the security of your PI, Paragon Micro seeks to use security technology and procedures, which are reviewed periodically. We use encryption technology and Secure Socket Layers ("SSL") in all areas of the Site where your personal account information is required. This means that the PI you submit to us via our Site is encrypted by your computer and decrypted again on our side. If your browser does not support SSL, or if you are unable to establish a secure connection due to company firewall, please call us at +44 (0) 1908 010 555 to place your order by phone.

In addition, your personal account information, and transaction history are kept behind a firewall. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Paragon Micro” section below.

Other Information We Collect

Information About Your Computer and Your Site Activities: When a visitor comes to our Site we collect and aggregate information about the visitor's computer such as (IP address, operating systems and browser software), and click stream information (such as the address or "URL") of the website that the visitor came from before visiting our Site, which pages of the Site were visited, the order in which they were visited and which hyperlinks were clicked for the purpose of assessing our Site traffic and the effectiveness of our Site content, as well as to help diagnose problems with our servers. This data allows us to improve the quality of your visit by streamlining your ability to navigate the Site and to develop featured programs and content that will be of interest to our customers and Site visitors. We do not track our Site visitors when they are on third-party websites.

Aggregated Information: Paragon Micro may collect and aggregate demographic information about our Site visitors. For example we may seek to aggregate information regarding the gender make-up, average age and range of income levels of Site visitors in order to better service our user community. We may use such information in its aggregated form without restriction.

Information About Corporate and Other Organisational Customers: We may collect information pertaining solely to corporations, government or educational entities, or other business or non-profit entities, such as, for example, a company's address. We may use any such corporate information without restriction. In an effort to better support our customers by delivering more relevant marketing communications, Paragon Micro will, on occasion, purchase third party information about businesses and other entities that are our customers. The company information we purchase may include number of employees or annual sales information or similar information to better serve our organisational customers.

Advertisers

Paragon Micro uses outside advertising companies ("Advertisers") to serve advertisements on the Site. Please be advised that such Advertisers may place or recognise a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.

Google Analytics

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and similar technologies to help analyse how users use the Site. The information generated about Site usage, including visitor IP address, is transmitted to Google. This information is then used to evaluate visitors’ use of the Site, compile statistical reports on website activity, and provide other services relating to website activity and internet usage. Google may also collect information about Site visitors’ use of other websites. Google offers the ability to opt out from tracking through Google Analytics cookies; for more information, visit http://tools.google.com/dlpage/gaoptout.

Remarketing with Google Analytics

We use Remarketing with Google Analytics to advertise online. Remarketing with Google Analytics allows third- party vendors, including Google to display our ads on third-party sites across the Internet. Paragon Micro and third-party vendors, including Google, use first-party cookies (such as Google Analytics cookies) and third-party cookies (such as DoubleClick cookies) together to inform, optimize, and serve ads based on a visitor’s past visits to and activity on our Site. You can learn about Google’s practices in connection with this remarketing and opt out of it by visiting http://www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Google Display Network Impression Reporting

We use Google Display Network Impression Reporting to analyze users’ interactions with our ads. Paragon Micro and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third- party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site. You can 3learn about Google’s practices in connection with this reporting and opt out of it by visiting http://www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Sweepstakes and Promotions

We may from time to time offer sweepstakes, contests, or other similar promotions on the Site. Additional PI may be required in order to participate in such promotions, so that we may, for example, verify entrants’ eligibility, and identify and notify winners. Participation in such promotions is completely voluntary. If and when we sponsor such promotions, we will post relevant privacy information in the respective "official rules" and/or registration areas for such promotions. That privacy information, to the extent it conflicts with this policy, will govern that particular sweepstakes, contest or promotion--please remember to read it carefully.

We are not responsible for any such promotions offered by third parties. Please read all related terms and conditions carefully, or contact the applicable third party for more information. The collection and use of PI in connection with such third-party promotions is governed by such third party's privacy policy, and not by the policies of Paragon Micro.

Co Branded Sites: Links to Other Sites

The Site offers certain features that are provided and/or hosted by third parties, but that may be presented on pages displaying Paragon Micro's branding. For example, our branded pages featuring investor relations information about Paragon Micro may be created and operated by a third party data provider specialising in such information. The Site may also contain links to other Web sites, or affiliated sites (e.g. events, sponsors, or companies offering rebates or other promotions.We are not responsible for the privacy practices or the content of any such Web sites, including such site's use of any information (such as IP address, browser type or operating system) collected when visitors to the Site click through links to those sites. Even though such information may not identify you personally, we strongly encourage you to become familiar with the privacy practices of any third party sites.

Online vs. Offline Practices

Please note that this Policy applies solely to our online information-gathering and dissemination practices in connection with the Site and does not apply to any of our practices conducted offline other than as expressly set forth in this Policy.

Contacting Paragon Micro

Should you have any questions, please email enquiriesuk@paragonmicro.com