Top Ten Things EU Companies Should Consider In Light Of CCPA

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  1. Yes, CCPA can apply to you even if you have no physical presence in California.
  2.  Yes, if you have done some GDPR compliance you are in better shape for CCPA.
  3. No, your GDPR compliance work is NOT sufficient for CCPA compliance and there are still things to do.
  4. Yes, if you are a non EU controller you may be able to take advantage of some of the things CCPA does differently than GDPR.
  5. Yes, you will need to amend your privacy notice even if it is GDPR Article 13/14 compliant.
  6. Yes, you will likely need to amend your GDPR Art 28 Data Processing Agreements.
  7. Yes, if you have re-targeting cookies you will need a CCPA solution for them as well.
  8. Yes, if you collect information of children under 16 you have things to think about under CCPA as well.
  9. Yes, if you have loyalty programs and financial incentives you may need to address them under CCPA.
  10. No, CCPA is not the last we have heard of U.S. state privacy laws and many are on the horizon.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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