Almost all banks and financial institutions that utilize third party behavioral advertising cookies have taken the position that the collection of information utilizing such cookies on their websites does not constitute a “sale” under the CCPA.¹

For more information and resources about the CCPA visit http://www.CCPA-info.com.

This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes.  You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.

1. BCLP, February 2020: Survey of the Banking and Financial Service Privacy Representations.

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