Persooa Customer Data Ethics Charter 2026 Version 2026.1
Preamble
Customer data is a resource entrusted to us, not our property. In CDP, loyalty, personalization and agentic commerce projects, we have access to some of our customers' most sensitive assets - data about their customers. This charter describes the ethical principles that guide us above and beyond the minimum required by law.
Customer trust
- We treat trust as a strategic asset that must not be burned for a short-term result.
- We assess every scenario by asking: "if the end customer knew how this works, would they consider it fair?".
- We do not design mechanics that work precisely because the customer does not understand them.
Transparency
- We support customers in clearly communicating what data they collect and for what purpose.
- Personalization should not be "magic" - the end customer should be able to understand why they see a given offer.
- In the area of AI agents, we support labelling interactions with AI systems.
Consent management
- Data activation takes place within the bounds of the consents and preferences expressed by the end customer.
- Withdrawing consent and changing preferences must be just as easy as giving them.
- Channel and frequency preferences are respected at the level of campaign execution.
- We distinguish between processing bases and do not "stretch" consent to purposes it does not cover.
Personalization ethics
- Value, not exploitation - personalization should serve the customer, not exploit their vulnerabilities.
- Protection of vulnerable groups - special caution toward people in difficult circumstances; no targeting based on sensitive characteristics.
- No dark patterns - we do not use false urgency, hidden costs, an obstructed opt-out or manipulative pressure.
- Contact hygiene - frequency capping and fatigue control protect the customer experience.
Data ownership
- The customer (the company) remains the owner of their data at every stage of the engagement.
- Persooa acts as a processor on behalf of the customer and on their documented instructions.
- After the engagement ends, data is returned or deleted in accordance with the contractual arrangements.
- We do not use one customer's data for the benefit of another or for our own commercial purposes.
Responsible recommendation strategies
- We optimize for long-term customer value (CLV) and customer satisfaction, not solely for a single conversion.
- We avoid the "filter bubble" and the excessive exploitation of a single purchasing pattern when it harms the experience.
- We treat recommendations of sensitive products (e.g. health, financial) with extra caution.
- We do not recommend in a way that misleads the customer about availability, price or popularity.
Applying the charter
- The charter is binding on all Persooa teams involved in working with customer data.
- In the event of a conflict between a business goal and the principles of the charter, we escalate to the project owner and - if necessary - to the customer.
- The charter complements legal obligations (GDPR) and the Persooa Code of Conduct (including protection of confidential information); it does not replace them.
Related: Responsible AI Policy 路 Security & Governance Statement. This document is informational and does not constitute a binding contractual commitment.