Exhibit 1 to Gardner Declaration (Jambekar Declaration) — Plaid Privacy (Dkt. 191.3)

Summary

Exhibit 1, Doc. 191-3, filed August 21, 2023 in In re Plaid Inc. Privacy Litigation, Case No. 4:20-cv-03056-DMR (N.D. Cal.): the Declaration of Sheila Jambekar, Chief Privacy Officer of Plaid Inc. The declarant states personal knowledge of Plaid's compliance with the injunctive relief provisions of the Cottle Class Action Settlement Agreement, which was approved by the Court on July 20, 2022, and submits the declaration pursuant to paragraph 70 of the Agreement. It states that Plaid published annual updates to its End User Privacy Policy on February 22, 2022 and February 28, 2023, and that Plaid has deleted the data described in the Agreement and complied with the timeframes in Paragraphs 64-66. The declaration states it was executed on March 15, 2023.

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Exhibit 1 
Case 4:20-cv-03056-DMR   Document 191-3   Filed 08/21/23   Page 1 of 4

 
 
 
DECL. OF SHEILA JAMBEKAR 
NO. 4:20-CV-3056-DMR 
 
COOLEY LLP 
 
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COOLEY LLP 
MICHAEL G. RHODES (116127) 
(rhodesmg@cooley.com) 
WHITTY SOMVICHIAN (194463) 
(wsomvichian@cooley.com) 
KYLE C. WONG (224021)  
(kwong@cooley.com) 
ELLIE BARCZAK (329180)  
(ebarczak@cooley.com) 
3 Embarcadero Center, 20th floor 
San Francisco, CA 94111-4004 
Telephone: 
+1 415 693 2000 
Facsimile: 
+1 415 693 2222 
Attorneys for Defendant 
Plaid Inc. 
 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
IN RE PLAID INC. PRIVACY LITIGATION 
 
_____________________________________ 
THIS DOCUMENT RELATES TO: 
  
ALL ACTIONS 
Case No. 4:20-cv-03056-DMR 
DECLARATION OF SHEILA JAMBEKAR, 
CHIEF PRIVACY OFFICER OF PLAID INC. 
 
 
 
 
Case 4:20-cv-03056-DMR   Document 191-3   Filed 08/21/23   Page 2 of 4

 
 
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DECL. OF SHEILA JAMBEKAR 
NO. 4:20-CV-3056-DMR 
 
COOLEY LLP 
 
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I, SHEILA JAMBEKAR hereby declare as follows: 
1. 
I am the Chief Privacy Officer of Plaid Inc (“Plaid”).  I have personal knowledge 
regarding Plaid’s compliance with the injunctive relief provisions in the above-captioned class 
action (the “Cottle Class Action”) Settlement Agreement (the “Agreement”), which was approved 
by the Court on July 20, 2022.  If called to testify about the statements made in this declaration, I 
could and would testify competently to them. I submit this declaration pursuant to paragraph 70 of 
the Agreement.  
Website and End User Privacy Policy 
2. 
On February 22, 2022, Plaid published annual updates to its End User Privacy Policy 
(the “EUPP”) available on Plaid’s website at www.plaid.com/legal/#end-user-privacy-policy. Plaid 
published annual updates to its EUPP on the same webpage on February 28, 2023. In compliance 
with the Agreement, Plaid’s EUPP contains the enhancements set forth in Paragraphs 53(a)-(e) of 
the Settlement Agreement.   
3. 
Plaid’s website continues to include the disclosures described in Paragraphs 54(a)-
(b) of the Agreement.  
Implemented Changes 
4. 
As stated in the Agreement, Plaid continuously makes updates to its business 
practices, including the changes that were implemented or finalized, in part, after the filing of the 
initial class action complaint in this litigation on May 4, 2020, as described in Paragraph 55(a)-(c).  
Plaid Link 
5. 
Plaid’s standard Plaid Link flow continues to include the parameters outlined in 
Paragraph 56(a)-(d) of the Agreement.  
6. 
Plaid continues to take reasonable commercial efforts to ensure that Plaid’s 
customers using Plaid’s standard Link flow continue to comply with the parameters set out in 
Paragraph 56(a)-(d) of the Agreement, except as otherwise noted in the Agreement.  
Plaid Portal 
7. 
In compliance with Paragraph 59 of the Agreement, Plaid takes reasonable 
commercial efforts to send periodic email reminders to Plaid Portal account holders generally 
Case 4:20-cv-03056-DMR   Document 191-3   Filed 08/21/23   Page 3 of 4

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DECL. OF SHEILA JAMBEKAR 
NO. 4:20-CV-3056-DMR 
COOLEY LLP 
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describing the user controls available in Plaid Portal, including, to the extent technically feasible, 
enable users to disconnect apps from their financial accounts and delete financial data stored in 
Plaid’s systems. 
Data Minimization 
8.
Pursuant to Paragraph 64(a) of the Agreement, prior to the end of 2022, Plaid took
reasonable commercial efforts to begin implementation of the relief set forth in Paragraph 60 of the 
Agreement (subject to the limitations described in Paragraph 61).  
9.
In compliance with Paragraph 62 of the Agreement, Plaid uses its best efforts to
continue to inform its customers about its /item/remove endpoint. 
Data Deletion 
10.
In accordance with the time periods specified in Paragraphs 64-66 of the Agreement,
Plaid has deleted the data described in Paragraph 63(a)-(b), to the extent not already deleted. 
Time Frames 
11.
Plaid has complied with the timeframes outlined in Paragraphs 64-66 of the
Agreement and will continue to comply on a go-forward basis with the timeframes set forth in those 
Paragraphs.  
Executed at San Francisco, California on March 15, 2023. 
Case 4:20-cv-03056-DMR   Document 191-3   Filed 08/21/23   Page 4 of 4

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