SanfordWhiteman
Level 10 - Community Moderator

Re: Brief Summary : CCPA Compliance Requirements

Absolutely, Dan!

I have 2 clients covered by CCPA who exchange lists as part of a partnership agreement. A too-literal framing would say they don't "sell" the lists because there's no invoice that says, "Here's your list, thanks for your prompt payment" and the businesses have an ongoing relationship as opposed to a one-time thing.  But clearly that's a sale.

Also:

... and the consumer can be verified by double opt-in via a single click in the confirmation email.

This is technically infeasible. You have to require human interaction, not a click on the email alone, or else mail scanners will "confirm" people without their consent.

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