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, and after that until Accolgo deletes it at the customer's request or, once automatic deletion is switched on, on the schedule 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.
The private word. A “private word” with someone senior who is not the starter's own manager is accessible only to the organisation's head of people (and owner), the roles every named senior contact on the account must hold. The person's manager is not told, unless the organisation has nobody senior besides the manager, in which case the starter is told this before sending. The words are stored in the database, encrypted at rest by our database provider but not separately encrypted by Accolgo, with the organisation's other check-in answers, and only Accolgo's own authorised technical staff with database administrator access, running the service, could technically read them.
Security compromises (breach notification)
Draft only, not legal advice. For Dermot’s own review and his solicitor’s confirmation before this is relied on or shown to any customer. The specific timeframe below is stated from general knowledge, not independently verified live in this session, and must be checked against the current law of every US state Accolgo actually has customers or data subjects in before this is treated as final.
Where Accolgo has reasonable grounds to believe personal information it processes on the customer’s behalf has been accessed, acquired, or disclosed without authorization, Accolgo will notify the customer without unreasonable delay, and in any event within 30 days of becoming aware, so that the customer can meet its own notification duties to affected individuals and to any state attorney general or regulator, under whichever US state law applies to them. Accolgo will provide the information reasonably available to it about the nature of the incident, the categories and approximate number of individuals and records involved, and the steps Accolgo has taken or plans to take in response, and will assist the customer’s own notification efforts as reasonably requested.
This commitment is Accolgo’s own to the customer, separate from and in addition to whatever the customer’s own applicable state law requires of the customer directly.
Sub-processors
| Provider | Purpose | Region |
|---|---|---|
| Supabase | Database, authentication, storage | UK (London) |
| Vercel | Application hosting | Application code runs in London (United Kingdom), the same place as the database. Vercel’s network passes requests through the nearest point of presence, and Vercel states its primary processing facilities are in the United States |
| Resend | Transactional email | US / per sending configuration |
| Sentry | Error monitoring | United States or EU |
| Anthropic | Powers the in-app help assistant, which picks help articles to show. Receives the question a signed-in user types | United States |
| Twilio | Will send the WhatsApp check-in message to a line manager or buddy who chooses WhatsApp, once WhatsApp check-ins start, which is coming soon. It will handle their mobile phone number and the message, which can name the new starter and holds a private check-in link. WhatsApp is only used when a line manager or buddy chooses it. | Not yet confirmed |
| Meta (WhatsApp Business) | Will provide the WhatsApp Business service that carries that message, once WhatsApp check-ins start, which is coming soon. It will handle the same mobile phone number and message. WhatsApp is only used when a line manager or buddy chooses it. | Not yet confirmed |
| Stripe | Takes subscription payments | United States (Stripe, LLC) and Stripe affiliates elsewhere. UK and EEA customers contract with Stripe Payments Europe, Limited |
Each is bound by written terms at least as protective as these. We will tell you before adding or replacing one.
Stripe acts as an independent controller for choosing payment networks, fraud prevention and legal compliance, under its own privacy notice, and never receives check-in answers or notes.
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, the customer can ask for a copy of its personal information and for it to be deleted, in writing. Until automatic deletion is switched on, Accolgo deletes it by hand when asked. Once it is on, Accolgo deletes it on the schedule in the retention policy. In both cases Accolgo keeps only what the law requires us to keep.