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Applicability of California Consumer Privacy Act (“CCPA”)

The CCPA went into effect on January 1, 2020, with enforcement by the California Attorney General not commencing until July 1, 2020.

As a general matter, the CCPA applies to any for-profit company conducting any business in California which collects consumers’ personal information (which would include cookies and the like) and determines alone or with others the purpose and means of processing (using) this information, and:

(1) Has annual gross revenues in excess of $25 million (assume this applies to worldwide revenue); or (2) Buys or receives for commercial purposes, or sells, or shares for commercial purposes, the personal information of 50,000 or more consumers, households or devices; or (3) Derives 50% or more of its annual revenue from selling consumers’ personal information.

            To the extent the CCPA is applicable to your business, compliance requires implementing the following:

  • Specific customer notices and disclosures.
  • Implementation of processes to obtain and respond to consumer requests for certain information concerning the collection, handling, sale, deletion and disclosure of specific consumer personal information.
  • Implementation of processes to allow the opt-out of (and for minors, to opt-in to) the sale of personal information.
  • The development of any financial incentive programs for the acquisition, sale and deletion of personal information.
  • Internal employee training.

If you have any questions about the CCPA, its applicability to you or your business, or seek additional details concerning any data privacy and protection matters related to your business, please contact Michael J. Feldman, Esq.  at or 908-964-2486.