Path2Response --
Responsible Use of AI

Trust and Data Usage Statement
Dated: March 31, 2026

Overview

Path2Response (“P2R”) is an independent third party and operates as a Data Controller. P2R is not a data processor as defined under applicable law, including California.
P2R builds and maintains a cooperative database composed of data assets contributed by members, along with other data sources that may include online signals, browse data, third-party enrichment data, and derivative data uniquely created and owned by P2R.
P2R may use advanced statistical and machine learning techniques to deliver high-quality data products as ordered by Clients under the terms of a Membership Agreement, Statement of Work, or Order (“Order”). P2R’s use of AI and machine learning is limited to and aligned strictly with the services defined in the appliable Order.

AI Usage Principles

1. No Use of Client Data for Model Training
P2R does not use client data to train, fine-tune, or improve AI models. Statistical and machine learning methods may be applied to Client Data solely to perform services contracted under an applicable Order.
2. Closed Environment Only
P2R does not expose client data to external or open AI systems. All processing occurs within P2R-controlled environments. Client data is not shared with public large language models or third-party AI platforms.
3. No Generative AI in Production
P2R does not use generative AI in its production modeling or decisioning systems. Only statistical and machine learning methods may be used, and only for purposes defined in the applicable order.

Data Use and Control

Client data is processed solely:
  • In accordance with client instructions.
  • For the purposes defined in the applicable Order.
P2R does not use client data for any purpose outside of delivering contracted services.

Summary

  • No client data is used for training
  • No client data is shared with open AI systems
  • No generative AI is used in production

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