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Scope check

Am I a California data broker?

Five questions against the definition in California's Delete Act. The definition is broad, and many businesses fall inside it without realizing, including lead vendors, enrichment shops, audience providers, and analytics firms.

Not legal advice

This is an educational tool, not a legal determination. It does not create an attorney-client relationship, and it cannot confirm that you are outside scope. Confirm your status with qualified counsel before acting.

The definition

What California means by data broker

A business that knowingly collects and sells to third parties the personal information of a consumer it does not have a direct relationship with. There is no revenue threshold and no exemption for selling only part of your data. First-party businesses can still qualify if they also source and sell data from elsewhere.

Cal. Civ. Code § 1798.99.80

Q1Do you sell, rent, license, or share consumers' personal information with third parties?
Q2Does some of that data concern people your business has no direct relationship with, meaning not your own customers?
Q3Does your data include California residents?
Q4Do you obtain personal information from sources other than the individuals themselves, such as data partners, public records, or other companies?
Q5Are you already registered as a data broker with the California Privacy Protection Agency?