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California Consumer Privacy Act (CCPA) Addendum

Last Updated: October 30, 2024

California Consumer Privacy Act (CCPA) Addendum (FAQs)

Introduction

This California Consumer Privacy Act Addendum ("CCPA Addendum") forms part of the [Master Agreement/Terms of Service] ("Principal Agreement") between Pairenthesis ("we," "us," or "our") and you ("you" or "Customer"). This CCPA Addendum outlines the terms under which we process your personal information in compliance with the California Consumer Privacy Act of 2018 ("CCPA").

By using our Service, you agree to the terms of this CCPA Addendum.

Definitions

  • CCPA: The California Consumer Privacy Act of 2018, as amended.
  • Business: As defined in the CCPA, a for-profit entity that determines the purposes and means of processing personal information.
  • Consumer: A natural person who is a California resident.
  • Personal Information: As defined in the CCPA, includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  • Service Provider: As defined in the CCPA, an entity that processes personal information on behalf of a Business.
  • Subprocessor: Any third-party service provider engaged by Pairenthesis to process personal information on behalf of the Customer.

Roles of the Parties

  • Customer: Acts as a "Business" under the CCPA.
  • Pairenthesis: Acts as a "Service Provider" under the CCPA.

Personal Information Categories

We categorize the Personal Information we collect from you as follows:

  1. Identifiers: Name, email address, postal address, phone number, IP address, device identifiers.
  2. Commercial Information: Transaction history, billing information.
  3. Internet or Other Electronic Network Activity Information: Browsing history, search history, interaction with the Service.
  4. Geolocation Data: IP address-based location information.
  5. Professional or Employment-Related Information: Job title, company name, industry.
  6. Non-Personally Identifiable Information: Aggregated or anonymized data.

Business Purposes for Processing Personal Information

We process your Personal Information for the following business purposes:

  1. Service Provision: To provide, maintain, and improve the Service, including account management, transaction processing, and customer support.
  2. Personalization: To personalize your experience and deliver content tailored to your interests and needs.
  3. Analytics and Research: To analyze usage trends and conduct research to enhance our AI models and develop new features.
  4. Marketing and Advertising: To send you promotional communications in accordance with your preferences.
  5. Legal Compliance: To comply with legal obligations, respond to lawful requests, and protect our rights and property.
  6. Fraud Prevention: To monitor and prevent fraudulent or unauthorized activities.

Consumer Rights

Under the CCPA, you have the following rights regarding your Personal Information:

  1. Right to Know: You have the right to request information about the categories and specific pieces of Personal Information we have collected about you, the sources of that information, the purposes for which it is used, and the categories of third parties with whom it is shared.
  2. Right to Delete: You have the right to request the deletion of your Personal Information, subject to certain exceptions.
  3. Right to Opt-Out of Sale: Note: We do not sell Personal Information. Therefore, this right is not applicable.
  4. Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your rights, please submit a verifiable consumer request to us using the contact information provided below.

Obligations of Pairenthesis

As a Service Provider, Pairenthesis agrees to:

  1. Process Personal Information Only for Authorized Purposes: We will only process Personal Information in accordance with the instructions provided by you and for the purposes outlined in this CCPA Addendum.
  2. Maintain Confidentiality: Ensure that employees and subprocessors with access to Personal Information are bound by confidentiality obligations.
  3. Implement Security Measures: Protect Personal Information using appropriate technical and organizational measures to prevent unauthorized access, disclosure, alteration, or destruction.
  4. Assist with Consumer Requests: Support you in fulfilling consumer rights requests, such as providing information or deleting Personal Information, as per your instructions.
  5. Notify of Data Breaches: Promptly inform you of any data breaches involving Personal Information, as required by law.
  6. Subprocessor Compliance: Ensure that any subprocessors engaged to process Personal Information comply with obligations similar to those in this CCPA Addendum.

Use of Subprocessors

  • List of Subprocessors: Our current subprocessors are listed in our Sub-processors List.
  • Authorization: We may engage additional subprocessors with your consent or as outlined in our Data Processing Agreement (DPA).
  • Compliance: All subprocessors are required to comply with data protection obligations consistent with this CCPA Addendum.

No Sale of Personal Information

We do not sell your Personal Information. For purposes of the CCPA, a sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating Personal Information to third parties for monetary or other valuable consideration. Since we do not engage in such activities, the right to opt-out of the sale of your Personal Information does not apply to you.

Request Handling

To exercise your CCPA rights, please submit a verifiable consumer request to us by contacting:

  • Email: privacy@pairenthesis.com
  • Address: Pairenthesis, Attn: Privacy Team, 166 Geary St. STE 1500 San Francisco, CA 94108 United States

Your request must:

  1. Be Written and Contain Sufficient Information: Include enough information to verify your identity and specify your request.
  2. Follow Applicable Instructions: Ensure you follow the instructions outlined in our Privacy Policy.

We will respond to your request within the timeframes specified by the CCPA.

Confidentiality and Security

We are committed to safeguarding your Personal Information. Our security measures include:

  • Encryption: Using SSL/TLS encryption for data in transit and encryption at rest.
  • Access Controls: Limiting access to Personal Information to authorized personnel only, in accordance with our Security Policy.
  • Regular Security Assessments: Conducting regular reviews of our security practices and technologies.
  • Anonymization and Pseudonymization: Applying techniques to reduce the identifiability of Personal Information used in AI processing.
  • Data Breach Response Plan: Maintaining a plan to respond to potential data breaches, including notifying you and relevant authorities when required by law.

Data Retention and Deletion

We retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this CCPA Addendum and our Privacy Policy, including:

  • Service Provision: As long as you have an active account or as needed to provide you with the Service.
  • Legal Obligations: To comply with legal, accounting, or reporting requirements.
  • Dispute Resolution: To resolve disputes and enforce our agreements.

Upon your request, we will delete your Personal Information in accordance with your rights under the CCPA, subject to applicable legal obligations and exceptions.

Governing Law

This CCPA Addendum is governed by and construed in accordance with the laws of the State of California, United States, without regard to its conflict of laws principles.

Miscellaneous

  • Conflict of Terms: In the event of any conflict between this CCPA Addendum and the Principal Agreement, the terms of the Principal Agreement shall prevail except where this Addendum provides more protective terms for California consumers.
  • Amendments: We may update this CCPA Addendum from time to time to reflect changes in our data practices or legal requirements. We will notify you of significant changes through the Service or by other means.
  • Severability: If any provision of this CCPA Addendum is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect.

Contact Information

For any questions or concerns about this CCPA Addendum or our privacy practices, please contact us at: