Those little automated data tracking mechanisms are subject to special treatment, consent, opt in and opt out requirements. Have you properly accounted for cookies for GDPR and CCPA?
Corporate Special Council at Baker Botts
Cynthia J. Cole is Special Counsel at Baker Botts L.L.P in Palo Alto, California and formerly CEO and General Counsel in public and private companies, particularly related to technology, corporate transactional and data privacy issues such as the California Consumer Privacy Act of 2018 (CCPA) and the EU's General Data Protection Regulation (GDPR). She counsels clients on technology transactions and deals, big data, data privacy, data sharing and IP licensing. Cynthia is a recognized thought leader in data privacy, named a “California Trailblazer 2019” and one of the Women Leaders in Tech Law by The Recorder, 2017.
Hundreds of written comments received by the California Office of the Attorney General show that there is still confusion and possible expansion of the CCPA.