How should a business classify transfers and honor opt-outs?
Inventory each disclosure by recipient, data category, purpose, consideration, advertising context, contract, and actual recipient use. A vendor label does not decide the analysis. A service provider or contractor must meet the statutory definition and written-contract restrictions; otherwise the recipient may be a third party.
A business that sells or shares must provide two or more designated opt-out methods suited to how it interacts with consumers. For online collection, those methods include processing a qualifying and providing an interactive form through the required link, alternative link, or privacy policy. A business may omit the link only if it meets every condition for frictionless signal processing; posting a cookie banner alone is not an opt-out method.
The request applies without identity verification, although the business may ask for information reasonably necessary to complete it. Stop covered transfers as soon as feasibly possible and no later than 15 business days, give the consumer a way to confirm completion, notify affected downstream third parties as required, use request data only to comply, and wait at least 12 months before asking the consumer to authorize or again, subject to the regulations.
- Map browser, app, account, offline, advertising, analytics, and vendor transfers separately.
- Classify each recipient as a third party, service provider, or contractor from the facts and contract.
- Offer the required link or compliant alternative and honor Global Privacy Control and other qualifying signals.
- Propagate the opt-out to tags, audiences, application programming interfaces (APIs), data warehouses, and downstream recipients that can sell or share.
- Retest after changes to consent tools, advertising partners, identity resolution, or data flows.
Citations (3)
- California Privacy Protection Agency FAQ
Plain-language explanation of the sale and sharing opt-out and qualifying preference signals.
- California Civil Code sections 1798.120 and 1798.135
Binding rules for the right to opt out, required links or signal alternative, downstream handling, request-data limits, and the 12-month consent interval.
- CPPA CCPA Regulations effective January 1, 2026
Sections 7025 and 7026 govern preference signals and requests to opt out of sale or sharing.