CCPA and Online Ads: Contract and Compliance Consequences

The combination of the intensifying public push for privacy protection and the CCPA’s strictures around the sale of third-party data has set off an array of commercial, compliance and contracting difficulties across online advertising companies and ad-supported industries. In this article, the second of a two-part series, we look at compliance choices and vendor contract issues facing these groups, including mixed CCPA classifications, data flows, data broker registration and industry competition. Part one discussed the commencement of the California Attorney General’s enforcement of the CCPA’s Do Not Sell provision, uncertainties about the interpretations of third-party sales of data, and Facebook’s new compliance tool for service providers. See “Did Adtech Fix Its CCPA Problem? IAB’s GC Discusses New Contract for Data Sales” (May 27, 2020).

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