CCPA Privacy Notice

[Last Updated: April 01, 2024]

This CCPA Notice applies to Panaya Ltd.’s and its affiliates’ (collectively “Panaya” or “we“) Customers, Authorized Users and Prospects who are California residents (“Consumers” or “you“), in accordance with the California Consumer Privacy Act of 2018 as amended and revised by the California Privacy Rights Act of 2020 collectively “CCPA“), and any other California privacy law (“Data Protection Laws“).

This CCPA Notice applies to Consumers’ Personal Information (as defined below), which we collect directly or indirectly while using our Services or in order to provide our Services and business-to-business Personal Information.

This CCPA Notice is an integral part of Panaya Privacy Policy. Any capitalized terms not defined herein shall have the meaning ascribed to it under the Data Protection Laws or our Privacy Policy.


Part I: A Comprehensive Description of the Information Practices:

  1. Categories of Personal Information We Collect

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.

Personal Information further includes Sensitive Personal Information (“SPI”) or Sensitive Data, as detailed in the table below.

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; and information which is excluded from the Data Protection Laws’, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Panaya have collected the following categories of personal information within the past twelve (12) months:

A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Yes: online identifiers, Internet protocol address, unique identifiers, real name, email address. 
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Yes: B2B data will include also bank account and other payment information.   
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).No
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.No  
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.No
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.Yes: Prospect’s interaction with our website and Authorized Users’ interaction with the Services, including session replies.
G. Geolocation data.Physical location, approximate location derived from IP address or movements.Yes: approximate location derived from IP address.
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.No
I. Professional or employment-related information.Current or past job history or performance evaluations.No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.No  
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.No  
L. Sensitive personal information.Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.No

2) Categories of Sources of Personal Information

Depending on the nature of your interaction with Panaya, we may collect information as follows:

  • Automatically– we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website or the Services.
  • Provided by you voluntarily– we will collect information if and when you choose to provide us with the information, such as through contact us communications, account registration, etc.
  • Provided by third parties – such as third parties analytics providers.

3) Use of Personal Information

We may use the Personal Information collected as identified above, for the following purposes:

  • To fulfill or meet the reason you provided the Personal Information (book a demo, support, respond to a query, etc.);
  • To monitor and improve our Services;
  • To provide the Services;
  • To analyzing our Services and your use of the Services and website;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; or
  • Respond to law enforcement; or otherwise as detailed in our Privacy Policy.

We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4) Disclosures of Personal Information for A Business Purpose

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information.

In the past twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Business Purpose (as defined under CCPA)Category (corresponding with the table above)Category of Recipient
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.Category A
Category F
Category G
Advertising networks; data analytics providers; social media networks.
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.Category A
Category F
Category G
Affiliated companies, operational partner, security and fraud prevention providers, and operating systems.
Debugging to identify and repair errors that impair existing intended functionalityCategory A
Category F
Category G
Analytic providers, operational partner, security and fraud prevention providers, operating systems.
Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us.Category A
Category F
Category G
Advertising networks; data analytics providers; social media networks.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service providerCategory A
Category B
Category F
Category G
Hosting and server co-location services, communications and content delivery networks, internet service providers, operating systems and platforms, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, capital providers, and correspondents, customer engagement services, billing, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with the Company’s legal and regulatory obligations to screen and monitor transactions; and the Company’s business, legal, tax, financial and compliance advisors.
Undertaking internal research for technological development and demonstration.Category A
Category F
Category G
Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business.Category A
Category F
Category G
Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools.

5) Sale or Share of Personal Information

In the preceding twelve (12) months, we did not “sell” information as most people would commonly understand that term. We do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment. We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.

Further, as we promote our Service through online campaigns, we place third-party marketing and analytic cookies on our website, sharing the unique identifier with such partners for analytic and marketing purposes may also fall under the definition or “share and sell”, and therefore, we offer the opportunity to opt-out through the cookie setting presented on our website’s footer. For additional information regarding the tracking technologies, we use on our website please review our cookies list presented in the website’s footer.

In the past twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

Category (corresponding with the table above)CategoryPurpose of Sale or Share
Category A
Category F
Category G
Ad-network, Marketing Cookies, Analytic Cookies.Share for cross-context behavioral advertising.

6) Children Under the Age of 16

We do not knowingly collect information from children under the age of 16.

7) Data Retention

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out, where applicable.

The retention periods are determined according to the following criteria:

  1. For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
  2. To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
  3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

Part II: Your Rights Under the Data Protection Laws

  1. Your Rights

Depending on your interaction with us and your place of residence you might have certain rights regarding your Personal Information we process as detailed herein above.

The right to know what Personal Information Panaya has collected about you.Including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information that Panaya has collected about you.
Deletion Rights.The right to delete Personal Information that Panaya has collected from you, subject to certain exceptions.
We reserve the right to reject such request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, ensure the security and integrity, provide the services, a legal obligation, etc.
Correct Inaccurate InformationThe right to correct inaccurate Personal Information that Panaya maintains about you.
Opt-Out of Sharing for Cross-Contextual Behavioral AdvertisingYou have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.”
Opt-out from sellingThe right to opt-out of the sale or sharing of Personal Information by Panaya.
Limit the Use or Disclosure of SPIUnder certain circumstances, if Panaya uses or discloses SPI, the right to limit the use or disclosure of SPI by Panaya.
Opt-Out of the Use of Automated Decision MakingIn certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information, where applicable.
Non-DiscriminationThe right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
Data PortabilityYou may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

Note: You may only exercise this right, unless legally allowed otherwise, twice within 12 years.

2) How Can You Exercise Your Rights?

You may exercise your rights using the DSR available here. The instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer must provide are all detailed in the DSR.

Note, certain rights can be done by you independently without using the DSR. For example, depending on your interaction with us:

  • you can opt-out from receiving emails from us by clicking the “unsubscribe” link within the email; and
  • you can delete and correct any information available in your account, through your account settings.

Further, opt-out rights can be executed without filling the form:

  • Through our website footer: You can opt-out from processing of online identifiers or other marketing data, for analytics or marketing purposes, at any time, by using the cookie settings banner or the “Do Not Sell or Share my Personal Information” button all available through our website footer or as detailed under our cookie declaration available on our website footer.
  • Through Device-Level Choices: If you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings.
  • Use the Global Privacy Control (“GPC”) signals.

3) Authorized Agents

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

a. When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:

  • Provide the authorized agent signed permission to do so or power of attorney.
  • Verify their identity directly with the business.
  • Directly confirm with the business that they provided the authorized agent permission to submit the request.

b. A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.


Part III: Other State Laws and Rights

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit:


By email: [email protected]

By mail: Data Privacy Office, Infosys Limited, Electronics City, Hosur Road, Bangalore 560 100, India


This notice was last updated on April 1, 2024. As required under the CCPA, we will update this CCPA Notice every 12 months. The last revision date will be reflected in the “Last Updated” heading at the top of this CCPA Notice.

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