I'll take a stab here, with the caveat that we don't share under this reason. But my understanding is that in the case you describe above, under CA SB1, you would need an Opt In. You can only share in a financial joint marketing arrangement with non-affiliated third parties under an "Opt Out" if the other party is a financial institution. If the other pary is not a financial institution, then you actually need an Opt In.
Maybe someone else who shares under CA law can opine here.
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