If an individual asks Pinecone about their personal data, Pinecone will forward that request to the business customer rather than responding directly. Business customers are responsible for handling all such requests themselves.
This analysis describes what Pinecone's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This clause establishes that data subjects seeking to exercise rights such as access, deletion, or correction under GDPR or CCPA must work through the business customer, not directly with Pinecone. Business customers must therefore have operational processes in place to handle these requests within regulatory deadlines.
Individuals whose data is processed through Pinecone's systems cannot exercise their data rights directly with Pinecone. They must contact the business customer that originally submitted their data to Pinecone, who is solely responsible for fulfilling the request.
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"Customer is responsible for responding to, and complying with, Data Subject Requests. To the extent Customer is unable through its use of Pinecone Services to address a particular Data Subject Request on its own, Pinecone will, taking into account the nature of the processing, provide reasonable assistance to Customer to enable Customer to respond to the Data Subject Request. If Pinecone receives a Data Subject Request directly, Pinecone will promptly forward such request to Customer and Pinecone shall not, unless legally compelled to do so, respond directly to the data subject except to refer them to the Customer to allow Customer to respond as appropriate.— Excerpt from Pinecone's Pinecone Data Processing Addendum
1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 12 through 22 (data subject rights), CCPA/CPRA consumer rights provisions, and equivalent rights under the Colorado, Connecticut, Utah, and Virginia state privacy laws. Under GDPR, controllers must respond to data subject access requests within one month, with possible extension to three months. EU supervisory authorities and the California Privacy Protection Agency are the primary enforcement bodies. The DPA's allocation of data subject request responsibility to the Customer is consistent with the controller/processor framework under GDPR Article 28. 2) GOVERNANCE EXPOSURE: Medium. Business customers must have operational systems capable of fulfilling data subject requests for data held within Pinecone's infrastructure. If Pinecone's Services do not provide Customer-facing tools to locate, extract, correct, or delete specific personal data, compliance with data subject request timelines may be operationally challenging. 3) JURISDICTION FLAGS: EU/EEA and UK operations face the most acute exposure given GDPR's enforceable data subject rights and supervisory authority complaint mechanisms. California residents have CCPA/CPRA rights including access, deletion, and correction that business customers must be prepared to fulfill. Heightened exposure exists where data subjects are EU residents and the business customer is a non-EU entity subject to GDPR's extraterritorial reach. 4) CONTRACT AND VENDOR IMPLICATIONS: Business customers should confirm that Pinecone's Services include technical capabilities enabling data location, extraction, and deletion sufficient to fulfill data subject requests. If gaps exist, the DPA's reasonable assistance obligation may require negotiation of specific service-level commitments. Procurement teams should document the data subject request fulfillment workflow as part of vendor management records. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should map the data subject request workflow to confirm that requests received by Pinecone will be forwarded promptly and that internal processes can meet applicable regulatory deadlines. Privacy notices presented to data subjects should accurately describe how to submit data rights requests and should identify the business customer (not Pinecone) as the contact for such requests.
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This clause establishes that data subjects seeking to exercise rights such as access, deletion, or correction under GDPR or CCPA must work through the business customer, not directly with Pinecone. Business customers must therefore have operational processes in place to handle these requests within regulatory deadlines.
Individuals whose data is processed through Pinecone's systems cannot exercise their data rights directly with Pinecone. They must contact the business customer that originally submitted their data to Pinecone, who is solely responsible for fulfilling the request.
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