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#2284449 - 05/11/23 08:17 PM Re: NEW California Privacy Law Reg Warrior
WIBanker91 Offline
100 Club
Joined: Nov 2011
Posts: 185
WI
Wondering how everyone is going about getting vendors to signing and amendment to contracts. Are they having issues with signing? Any advice would be appreciated. Also, where do I find exemptions? Specifically, are attorneys, appraisers, title companies..... exempt. Sorry coming in late to the party.

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#2284453 - 05/12/23 12:32 PM Re: NEW California Privacy Law Reg Warrior
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Suggest you read the regulation at ccpa.ca.gov

Our legal counsel advised that our agreements already included sufficient language. Have you reviewed your agreements?
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TryingToComply
CRCM

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#2284470 - 05/12/23 03:48 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
100 Club
Joined: Jan 2017
Posts: 214
For the exemption read the regulation. We worked with our counsel to identify the third-parties that should have signed addendums. At this point, about 95% of those who we asked have signed and return the addendum.

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#2292449 - 01/16/24 07:07 PM Re: NEW California Privacy Law Reg Warrior
Newbie06 Offline
Platinum Poster
Joined: Mar 2006
Posts: 738
We are an Indiana bank that has a couple of customers that live in California. The new privacy rules only apply to California businesses correct?

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#2292459 - 01/16/24 10:38 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
100 Club
Joined: Jan 2017
Posts: 214
No. It applies to businesses that have California residents as customers and/or employees that meets one of the following criteria: A) As of January 1 of the calendar year, had annual gross revenues in excess of twenty-five million dollars ($25,000,000) in the preceding calendar year, as adjusted pursuant to paragraph (5) of subdivision (a) of Section 1798.185. OR (B) Alone or in combination, annually buys, sells, or shares the personal information of 100,000 or more consumers or households. OR (C) Derives 50 percent or more of its annual revenues from selling or sharing consumers’ personal information.

Depending how many customers and/or employees you have in California, you may want to reach out to your counsel for guidance.

CCPA: https://leginfo.legislature.ca.gov/...5.&part=4.&chapter=&article=

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#2292460 - 01/16/24 10:50 PM Re: NEW California Privacy Law Reg Warrior
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
I thought there was some exemptions for businesses covered under the GLBA also? Is that not true. I am by far not a CCPA expert.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2292461 - 01/16/24 11:02 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
100 Club
Joined: Jan 2017
Posts: 214
Yes, there are exemptions for data covered by GLBA, but employees and customers associated with business accounts/loans do not qualify for the exemption. Depending on the guidance given by your counsel, if you are using (not an all inclusive list) geolocation or cookies/pixel that can identify a person, that information may be covered by CCPA..

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