On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) will take effect. Building on the privacy foundation established through our GDPR compliance efforts, Branch is committed to ensuring that our services comply with CCPA.
We have created this CCPA resource page to help you understand the steps that Branch is taking to ensure its own CCPA compliance, and the tools available to our customers to enable the use of Branch’s services in a CCPA-compliant way.
In this guide, we have capitalized terms defined by CCPA so you can easily identify them.
If you are using Branch services as a customer, there is an agreement between you and Branch that describes the services that Branch provides to you. This agreement may include order forms, exhibits, or addenda, and serves as your instruction to Branch to process personal data as part of Branch’s performance of our services. For the purposes of CCPA, the data that Branch collects on behalf of its customers may include Personal Information.
In this context, if you are subject to CCPA, you are a Business and Branch is your Service Provider. Your sharing of Personal Information related to your end users with Branch, and Branch’s collection of Personal Information related to your end users, are done to facilitate Branch’s performance of its services that you contracted for.
Branch does not Sell Personal Information of your end users as defined under CCPA, or under any other circumstances. Pursuant to the terms of your agreement with Branch, you pay fees or other valuable consideration only in return for the services that Branch performs on your behalf. Branch does not receive from you, and you do not pay Branch, any monetary or other valuable consideration for making Personal Information available to Branch.
Branch has updated its terms to codify our position as your Service Provider (as defined by CCPA). We’ve made our CCPA addendum available for review, which reflects our CCPA standards. This California Privacy Addendum supplements our agreement with you and confirms our commitment to not Sell Personal Information.California Privacy Addendum
As a Business, it is your responsibility under CCPA to respond to requests relating to the Personal Information of your end users. It is at your sole discretion whether to accept or deny any request, and how to respond to the end user.
If your end users exercise their rights under CCPA to obtain access to or delete certain Personal Information that Branch processes, Branch will be prepared, on or before January 1, 2020, to honor the Verifiable Consumer Requests you submit to Branch. Further details and guidance on how to transmit these requests to Branch will be shared on or before January 1, 2020.
Branch will follow your instructions to delete Personal Information following a Verifiable Consumer Request as required under CCPA, unless Branch concludes that it is necessary for Branch to maintain such Personal Information for one or more permitted purposes under the CCPA (e.g., to detect fraudulent or illegal activity, or to prosecute those responsible for these activities), or Branch does not consider the information to be “Personal Information” (e.g., because it has been de-identified).
We maintain a list of vendors that process personal data on Branch's behalf, and the purpose for which we share data with each of these vendors.Third Party Vendors
This Addendum supplements our agreement with you and confirms our commitment to not Sell Personal Information.CCPA Addendum