CCPA Data Processing Addendum

This CCPA Data Processing Addendum (the “Addendum”) reflects the requirements of the California Consumer Privacy Act of 2018 and its implementing regulations, as amended or superseded from time to time (California Civil Code §§ 1798.100 to 1798.199) (the “CCPA”). This Addendum makes clear that TRIDENT1, LLC is acting as a Service T1 for CCPA purposes.

This Addendum is an addendum to the Enterprise Terms and Conditions (“Terms”) between TRIDENT1, LLC (“T1”) and the Client found on the applicable Order (sometimes referred to as “you,” “your,” OR “Client”) (each a “Party”; collectively the “Parties”) and is in effect for so long as T1 maintains Personal Information (as defined in and to the extent protected by the CCPA) provided by Client or which is collected on behalf of Client by T1 (hereinafter, the “Personal Information”). This Addendum shall only apply and bind the Parties if and to the extent Client is considered a “Business” as defined under the CCPA. This Addendum prevails over any conflicting terms of the Agreement, but does not otherwise modify the Agreement. All capitalized terms not defined in this Addendum shall have the meanings set forth in the CCPA. Client enters into this Addendum on behalf of itself and, to the extent required under the CCPA, in the name and on behalf of Client’s Authorized Affiliates (defined below).

The parties further agree as follows:


“Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.

“Authorized Affiliate” means any of Clients’ Affiliate(s) permitted to or otherwise receiving the benefit of the Services pursuant to the Scope and Applicability of this Addendum.


This Addendum applies to the collection, retention, use, and disclosure of the Personal Information to provide Services to Client pursuant to the Agreement or to perform a Business Purpose.

Client is a Business and appoints T1 as a Service T1 to process the Personal Information on behalf of Client. Client is responsible for compliance with the requirements of the CCPA applicable to Businesses.

T1’s collection, retention, use, or disclosure of Personal Information for its own purposes independent of providing the Services specified in the Agreement are outside the scope of this Addendum.


T1 is prohibited from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the Services specified in the Agreement for Client, as set out in this Addendum, or as otherwise permitted by the CCPA.

T1 shall not further collect, sell, or use the Personal Information except as necessary to perform the Business Purpose. For the avoidance of doubt, T1 shall not use the Personal Information for the purpose of providing services to another person or entity, except that T1 may combine Personal Information received from one or more entities to which it provides similar services to the extent necessary to detect data security incidents, or protect against fraudulent or illegal activity.


Client represents and warrants that it has provided notice that the Personal Information is being used or shared consistent with Cal. Civ. Code 1798.140(t)(2)(C)(i).


T1 shall provide reasonable assistance to Client in facilitating compliance with Consumer rights requests.

Upon direction by Client and within a commercially reasonable amount of time, T1 shall delete the Personal Information.

T1 shall not be required to delete any of the Personal Information to comply with a Consumer’s request directed by Client if it is necessary to maintain such information in accordance with Cal. Civ. Code 1798.105(d), in which case T1 shall promptly inform Client of the exceptions relied upon under 1798.105(d) and T1 shall not use the Personal Information retained for any other purpose than provided for by that exception.


In the event that either Party shares Deidentified Information with the other Party, the receiving Party warrants that it: (i) has implemented technical safeguards that prohibit reidentification of the Consumer to whom the information may pertain; (ii) has implemented business processes that specifically prohibit reidentification of the information; (iii) has implemented business processes to prevent inadvertent release of Deidentified Information; (iv) will make no attempt to reidentify the information


In the event that either Party transfers to a Third Party the Personal Information of a Consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the Third Party assumes control of all or part of such Party to the Agreement, that information shall be used or shared consistently with applicable law. If a Third Party materially alters how it uses or shares the Personal Information of a Consumer in a manner that is materially inconsistent with the promises made at the time of collection, it shall provide prior notice of the new or changed practice to the Consumer in accordance with applicable law.


Notwithstanding any provision to the contrary of the Agreement or this Addendum, T1 may cooperate with law enforcement agencies concerning conduct or activity that it reasonably and in good faith believes may violate international, federal, state, or local law.


The Parties acknowledge and agree that the exchange of Personal Information between the Parties does not form part of any monetary or other valuable consideration exchanged between the Parties with respect to the Agreement or this Addendum.