Customer Data Platform Product Privacy Notice

Customer Data Platform Product Privacy Notice

For details about these Products, refer to the Product Description available online at Product and Services guide. 

1. Processing Operation(s)

   The objective of Processing of Personal Data by data importer is the performance of the Services pursuant to the Agreement.

   • Processing of Personal Data to deliver its core functionalities required: ⌧ yes  ☐ no
   • Optional features processing Personal Data:  ☐yes  ⌧ no
     • The optional features are deactivated by default:  ☐ yes  ⌧ no ☐ n/a*
   • Processing of sensitive Personal Data: ⌧ yes**    ☐no ☐ n/a*
   • Profiling of individuals based on personal characteristics: ⌧ yes ** ☐no ☐ n/a*
   • Automated decision making that produces legal or other significant impacts on individuals:  ☐ yes  ⌧ no ☐ n/a*

   • Processing via an AI  tool available with the Product ☐ yes  ⌧ no

     • The AI feature is deactivated by default: ☐ yes  ☐ no ⌧ n/a*
     • The AI feature processes Personal Data: ☐ yes  ☐ no ⌧ n/a*
     • The AI feature processes sensitive Personal Data ☐ yes  ☐ no ⌧ n/a*
     • The Customer can control what data the AI tool processes: ☐ yes  ☐ no ⌧ n/a*

     * (n/a = not applicable)

     ** (optional; depends on the Customer’s configuration of the system, the connection to other systems, and the categories chosen by the Customer to be collected from Third Party Users)

2. Details of Personal Data being processed

   Categories of Personal Data	Categories of Data Subjects	Purpose of Processing	Categories of Data Recipients	Needed for Core Features	Processing Location	Acquia Inc. acts as Processor
   Through the configuration, design, and administration of their own Acquia CDPinstance, Customer in its sole discretion determines and controls the categories of data subjects collected by their Acquia CDPinstance. Customer has full access and autonomy over what types of data is tracked and has access to this data and can manipulate it in various ways. Primarily, the categories of Personal Data could be individual identifiers, contact details, online identifiers, network activity, location data, travel data, expense and financial data, browsing information, and any sensitive data categories.	Through the configuration, design, and administration of their own Acquia CDPinstance, Customer in its sole discretion determines and controls the categories of data subjects collected by their Acquia CDPinstance. Customer has full access and autonomy over what types of data is tracked and has access to this data and can manipulate it in various ways. Primarily, the categories of Data Subjects could be Customer’s end-users including visitors to Customer’s website, online shop, or physical store.	Provision of the Services by Acquia to Customer	Customer’s personnel	Yes	Depends on the data centre location chosen by Customer; data collected in a given region will exist only within that region. Subprocessors, Support: see Acquia Affiliates	Yes

3. Privacy Enhancements

   Objective	Technology / Measure	Data at Rest	Data in Transit
   Anonymization and Pseudonymization	Data anonymization at Customer level optional for Customer	Yes	Yes
   Data confidentiality	Access control measures	Yes	Yes
   	Encryption at customer level	No	No
   	Encryption at Acquia level Visit Security Annex and Product Description	Yes	Yes
   Data integrity	Ant-tampering technology Visit Security Annex	Yes	Yes
   Data availability including restoring availability, restoring access to personal data, and data resilience	Business continuity and disaster recovery measures

4. Certifications

   SOC 2 Type II

5. Data Subject Rights

   N/A

6. (Personal) Data Retention Cycles

   Personal data is retained at the Customer’s discretion. By default, data retention cycles exist only for time series data (such as transactions and events), but not other personal data (such as email address and name).

7. Sub-processing

   The specific list of Acquia’s sub-processors is available from: Acquia Sub-processors.

   Any current Acquia customer with a data processing agreement in place with Acquia may subscribe to receive notifications of new or changed sub-processors through the above website.

8. Description of the technical and organisational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached)

   Data importer has implemented and will maintain appropriate administrative, physical, and technical safeguards for the protection of the security, confidentiality and integrity of Personal Data uploaded to the Services, as described in the Acquia Security Annex (available from Acquia & GDPR Compliance) applicable to the specific Services purchased by data exporter, as updated from time to time, and made available by data importer upon request.  The data exporter is wholly responsible for implementing and maintaining security and data administration within any data exporter applications, configuration settings, or log settings used by data exporter in conjunction with the Services.

Visit Security Annex