Despite multiple requests, the California Attorney General has refused to clarify whether the use of an advertising cookie does, or does not, constitute the sale of personal information. Instead, the Attorney General has taken the position that the question requires a “fact-specific determination” and has suggested that the following three factors may be relevant on a case-by-case basis: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. FSOR, Appendix A at 13 (Response 47).
2. FSOR, Appendix A at 13 (Response 47).
3. FSOR, Appendix A at 13 (Response 47).