by DataSapien
July 17, 2025
Overview
This document encapsulates DataSapien’s voluntary fiduciary pledge to its paying clients, as a matter of its internal governance and business model.
The pledge is rooted in the template of the GliaNet Alliance’s “PEP” model, derived from the duties of care, fidelity, and loyalty attributable to common law fiduciaries. These duties have been modified and updated to apply to interactions between Web-based entities (B2B) and to individuals/end users who are now bona fide clients (B2C).
As a member of the GliaNet Alliance, DataSapien is entitled to emblemize this commitment by use of a trustmark, styled as a GliaNet Fiduciaries™ “pledgemark” [Figure 1]. This pledgemark can be placed on various DataSapien documents, including online terms of service, Master Service Agreements, and client contracts, and link to this pledge.
This pledgemark relates only to DataSapien’s primary paying clients, and not to those clients’ own end user customers, vendors, or other unrelated entities.
By utilizing the GliaNet Fiduciaries™ pledgemark in this manner, DataSapien agrees to retain ultimate responsibility for its actions in furtherance of the pledged duties (to the extent consistent with applicable laws, technical feasibility, and commercially reasonable efforts). Any potential recourse is tied to the company, and not to any outside organization, including the GliaNet Alliance.
The DataSapien Pledge Tiers
Tier One: Protect (Guardian): Duty of Care
This pledged commitment combines two elements of care: the fiduciary duty of care (taking reasonable and prudent steps to help ensure that the individual client is not harmed by DataSapien’s actions), and the tort-like liability standard (doing no actual harm to the client). This is the foundational principle of the PEP Model, which amounts to taking a protective, “do no harm” posture to defend the client.
In Web terms, DataSapien agrees to take certain steps to safeguard the client’s personal data. Beyond compliance with any applicable data protection legal requirements, such as GDPR, DataSapien will utilise a variety of techniques, such as data localisation and minimisation, to help keep the client’s personal data safe and secure. [list specific techniques]
Tier Two: Enhance (Mediator): Duty of Fidelity
The “thin” duty of loyalty states that DataSapien will resolve any conflicts of interest or duties in favour of the individual client.
In the Web context, DataSapien agrees not to share the client’s personal data with a third party without express and authentic consent. This duty also encompasses agreeing not to use cookies or other mechanisms to surveil or track the customer’s online activities, extract data outside of the acknowledged commercial relationship, or use the data in any way to manipulate the client’s actions or behaviors. Depending on the context, DataSapien can also take on the role of mediator by, for example, helping the client establish social media or news feeds that better represent the interests of their end user customers, and not those of outside data brokers or surreptitious marketers and advertisers.
Tier Three: Promote (Advocate): Duty of Loyalty
The “thick” duty of loyalty is the high-water mark of the PEP Model. Here, DataSapien agrees to take proactive steps to promote the best interests of the client, in agreed alignment with DataSapien’s product capabilities and strategic direction. Examples could include recommending additional/more advanced technologies to advance the client’s interests, such as helping promulgate intent-casting applications or algorithmic middleware decision engines to serve the client’s end user customers.
Disclaimer:
This pledge reflects DataSapien’s voluntary governance commitments and design principles. It does not establish a legal fiduciary relationship, and all responsibilities are subject to applicable law, technical feasibility, and commercially reasonable efforts as defined in client agreements.
For more information about the GliaNet Alliance Fiduciary Pledge, please check out their website here or contact hello@glianetalliance.org
