When personal data is transferred from the EU, UK, or Switzerland to countries without adequate data protection laws (such as the United States), Pinecone relies on Standard Contractual Clauses and the UK Addendum as the legal mechanism to authorize those transfers.
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The incorporation of EU SCCs (Implementing Decision 2021/914) and the ICO UK Addendum provides the legal transfer mechanism for cross-border data flows from the EU, UK, and Switzerland to Pinecone's operations, which are based in the United States. Compliance with these transfer mechanisms requires that the relevant annexes be properly completed with data flow descriptions and security measures.
Interpretive note: The DPA references SCC incorporation but the visible document text does not confirm whether Annex I and Annex II are pre-completed or require separate negotiation and completion by the Customer, creating uncertainty about the operational completeness of the transfer mechanism.
Business customers transferring personal data from the EU, UK, or Switzerland to Pinecone rely on these SCCs and the UK Addendum as the legal basis for the transfer. If these mechanisms are not properly executed or if they are invalidated, the transfers may lose their legal basis under European Data Protection Laws.
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""Standard Contractual Clauses" or "SCCs" means the standard contractual clauses annexed to the European Commission's Implementing Decision 2021/914 of 4 June 2021, as may be amended, superseded or replaced from time to time. "UK Addendum" means the International Data Transfer Addendum (version B1.0) issued by the Information Commissioners Office under S.119 (a) of the UK Data Protection Act 2018, as updated or amended from time to time. "European Transfer" means a transfer (directly or via onward transfer) of personal data that is subject to European Data Protection Laws to a third country outside the European Economic Area, United Kingdom and Switzerland which is not subject to an adequacy determination by the European Commission, United Kingdom or Swiss authorities (as applicable).— Excerpt from Pinecone's Pinecone Data Processing Addendum
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V (international data transfers), specifically the SCC mechanism under Article 46(2)(c) of the EU GDPR, and the equivalent UK GDPR transfer mechanism. The EU Commission's Implementing Decision 2021/914 and the ICO's UK Addendum (B1.0) are the operative instruments. EU supervisory authorities and the ICO are the primary enforcement bodies. The Swiss FADP and its transfer requirements are also referenced. The Schrems II ruling established that SCCs require a Transfer Impact Assessment (TIA) to verify that the destination country's law does not undermine the SCC protections, and compliance teams should evaluate whether a TIA has been conducted. 2) GOVERNANCE EXPOSURE: High for EU and UK-facing operations. If the SCC annexes (Annex I describing data flows and Annex II describing technical measures) are not properly completed, the transfer mechanism may be deficient. The DPA references the SCCs as incorporated but the visible document text does not confirm whether the required annexes are pre-populated or require separate completion by the Customer. 3) JURISDICTION FLAGS: EU/EEA member states where supervisory authorities have actively enforced cross-border transfer requirements (including Germany, France, Ireland, and the Netherlands) present heightened exposure. UK operations require the separate UK Addendum in addition to the EU SCCs. Switzerland requires evaluation under the Swiss FADP, which has its own transfer rules that may differ from EU GDPR in certain respects. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should confirm that Annex I (data exporter and importer details, data flow descriptions, data subjects, purposes, and retention periods) and Annex II (technical and organizational measures) are fully completed as part of DPA execution. Enterprise customers should also evaluate whether a Transfer Impact Assessment is required given Pinecone's U.S. base of operations and applicable U.S. surveillance law frameworks. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain executed copies of the SCCs with completed annexes and the UK Addendum as part of their records of processing activities. Periodic review of the transfer mechanisms is recommended, particularly if the EU Commission or ICO amends or replaces the current SCC or UK Addendum versions. Organizations subject to sector-specific regulations should evaluate whether the SCCs alone are sufficient or whether additional safeguards are required.
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The incorporation of EU SCCs (Implementing Decision 2021/914) and the ICO UK Addendum provides the legal transfer mechanism for cross-border data flows from the EU, UK, and Switzerland to Pinecone's operations, which are based in the United States. Compliance with these transfer mechanisms requires that the relevant annexes be properly completed with data flow descriptions and security measures.
Business customers transferring personal data from the EU, UK, or Switzerland to Pinecone rely on these SCCs and the UK Addendum as the legal basis for the transfer. If these mechanisms are not properly executed or if they are invalidated, the transfers may lose their legal basis under European Data Protection Laws.
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