Pinecone states it may receive personal information about you from marketing partners, data brokers, publicly available sources, and business partners, not just directly from you.
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
The policy authorizes Pinecone to obtain personal data about individuals from data providers and marketing partners, meaning individuals may have personal data held by Pinecone without having directly interacted with the company.
Your name, contact information, or other personal data may be held by Pinecone based on information purchased or received from third-party data providers or marketing partners, independent of any direct interaction with Pinecone's website.
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"We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you are attending a jointly sponsored corporate event or have otherwise expressed interest in learning specially about our services. We may obtain your personal information from other third parties such as marketing and advertising partners, publicly-available sources and data providers.— Excerpt from Pinecone's Pinecone Privacy Policy
REGULATORY LANDSCAPE: Under GDPR, the receipt of personal data from third parties requires a lawful basis and, where the data subject has not been notified of the original collection, a transparency obligation to inform the individual within a reasonable period. The FTC has enforcement authority over unfair or deceptive practices relating to data broker use. California's CPRA requires disclosure of the categories of sources from which personal information is collected, which this provision addresses in general terms. GOVERNANCE EXPOSURE: Medium. The broad reference to data providers and marketing partners as sources of personal information, without identifying specific providers or the categories of data obtained, limits the ability of data subjects or regulatory authorities to assess the transparency of these practices. Under GDPR Article 14, individuals must be informed when their data is obtained from sources other than themselves. JURISDICTION FLAGS: EU and UK users face the highest exposure given GDPR Article 14 transparency requirements. California residents are entitled under CPRA to request disclosure of the specific sources from which their personal information was obtained. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should assess whether data providers used by Pinecone are licensed data brokers and whether their data sourcing practices comply with applicable law. Downstream use of third-party sourced personal data in marketing contexts should be reviewed for compliance with anti-spam and consent requirements. COMPLIANCE CONSIDERATIONS: Legal teams should verify that Pinecone's GDPR Article 14 notices adequately inform European users when their data is obtained from third parties. California-facing compliance should confirm that source category disclosures in the CCPA section align with actual data provider practices.
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The policy authorizes Pinecone to obtain personal data about individuals from data providers and marketing partners, meaning individuals may have personal data held by Pinecone without having directly interacted with the company.
Your name, contact information, or other personal data may be held by Pinecone based on information purchased or received from third-party data providers or marketing partners, independent of any direct interaction with Pinecone's website.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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