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Mar 20th 2020

The Latest CCPA Updates

A few days ago, the California Attorney General released the latest modifications to the CCPA. The modified regulations add details to the requirements for the 4 categories of notice.

1. Collection

2. Right to Opt-Out of Sale

3. Financial Incentive

4. Privacy Policy

Collection

For notices of collection, the modifications address businesses that collect personal information on mobile devices. It allows businesses to provide links to the notice on their application download page and requiring businesses to provide a ‘just-in-time’ summary notice for collections “that the consumer would not reasonably expect” such as geo-location information collected from an app. 

For notices to opt out and privacy policies, the modified regulations permit businesses with mobile applications to provide links to these policies within their app settings.

Consumer Requests

The modified regulations contain a carve-out for businesses that interact with consumers ‘exclusively online’ and have a ‘direct relationship’ with consumers whose personal information they collect.

For requests to know, businesses are only required to provide an email address. Other businesses must provide two or more methods for consumers to submit requests, tailored according to the ways that a business typically interacts with consumers, but one method should include a toll-free number.

For requests to delete, all businesses must provid