Draft for review. The United States has no single federal privacy law, so this wording is written to the strictest commonly applicable state standard, principally California’s CCPA as amended by the CPRA. It has not yet completed a legal review, so it does not yet bind anyone.

Data processing terms

These terms apply whenever Accolgo processes personal information on behalf of a customer organization. Under the CCPA the customer is the business and Accolgo is its service provider. The CCPA requires that relationship to be set out in a written contract containing specific terms, and this page is that contract.

Subject matter and duration

Processing of onboarding check-in information (identities and contact details of starters, managers and buddies; worded check-in replies; optional notes; follow-up records) for the duration of the customer’s subscription plus the deletion window in the retention policy.

The service provider commitments

Accolgo processes personal information only on the customer’s documented instructions, and for the specific purpose of running the onboarding check-in service.
Accolgo does not sell personal information and does not share it for cross-context behavioral advertising, as both terms are defined in the CCPA.
Accolgo does not retain, use or disclose personal information for any purpose other than performing the service, and specifically not for its own commercial purposes.
Accolgo does not combine personal information received from one customer with information received from another, or from any other source, except as the CCPA expressly permits.
Accolgo will notify the customer if it determines it can no longer meet these obligations.
The customer may take reasonable and appropriate steps to confirm that Accolgo uses personal information consistently with these obligations.

Confidentiality and security

Everyone with access is bound by confidentiality. The security measures are set out in full on the security page and are applied to every customer alike, not tiered by plan.

Sub-processors

Accolgo uses a small number of operators to run the service: the database and authentication provider, the transactional email provider, the error-monitoring provider, the hosting provider, and, where nudge drafting is enabled, the drafting provider. Each is bound by written terms at least as protective as these. We will tell you before adding or replacing one.

Helping you meet your own obligations

Accolgo will assist the customer, taking into account the nature of the processing, in responding to requests from individuals to know, access, correct or delete their information, and in meeting the customer’s own security and breach-notification duties under applicable state law.

Return and deletion

On termination, personal information is deleted on the schedule in the retention policy, or returned or deleted earlier at the customer’s written request, save for anything the law requires us to keep.