Last Modified: 23 November 2020
Sale of Personal Information Under the CCPA
The CCPA broadens the definition of sale and personal information beyond how those terms may be commonly interpreted. Under the CCPA, personal information includes information that is not necessarily directly tied to an individual’s identity but may be associated with a device. This type of information may not be associated with an individual, but there are unique identifiers that could be. The term sell is defined to include not just selling in exchange for money, but also sharing or transferring personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which is not limited to the exchange of money. Certain things are not considered sales, including when personal information is shared with a service provider that is contractually prohibited from using the personal information for any purpose beyond the service specifically requested or when the consumer has directed a company to disclose the personal information.
Exercising Do Not Sell Right
Any individual who wishes to opt out of this kind of sharing should send an e-mail (including name, postal address, e-mail address, and telephone number) to email@example.com. IEM may only comply with a request if we can verify the individual’s identity or authority to make the request and confirm that their personal information is involved with the request. IEM only will use personal information provided in a request to verify identity and authority to implement the request. Please note that there is no right to opt out of IEM sharing personal information with service providers, who are parties IEM engages to perform a function on IEM’s behalf and are contractually obligated to use the information only for that function.
Third Party Requests
Any individual submitting a do not sell request on behalf of someone other than themselves should contact IEM at firstname.lastname@example.org and include proof that they are authorized to make the request. This may be in the form of a written authorization signed by the person whom the individual is acting on behalf of or a valid power of attorney.