California Consumer Privacy Act (CCPA)
To support your CCPA preparedness, Sincro has developed solutions for Sincro Websites and Sincro Advertising that process and store your consumers’ personal information.
Sincro is providing tools as a service provider. The dealership is ultimately responsible for their CCPA compliance. We recommend dealers consult with their legal and/or advisory team(s) for a full compliancy implementation plan.
If you have questions, reach out to CCPAQuestions@sincrodigital.com
What Dealers Need To Know
What Is CCPA?
- The California Consumer Privacy Act is a state law that enhances the protection of the personal information (“PI”) of California residents.
- It requires businesses to be transparent about their PI data practice by disclosing to consumers about how they collect, use and share consumers’ PI and responding to consumers’ data access, opt-out of sale and deletion requests.
- Effective January 1, 2020.
Does CCPA Apply To You?
The CCPA applies to any business doing business in California that collects personal data of California consumers and one of the following thresholds:
- annual gross revenue ≥ $25 million
- annually buys, receives, sells, or shares persona data of 50,000 or more California consumers, households, or devices
- derives 50% or more of its annual revenues from selling California consumers’ personal information
What Does CCPA Require?
The CCPA grants consumers a series of rights and control over how their PI should be handled, and imposes extensive obligations on businesses to ensure the consumers’ exercise of their rights. The key rights consumers have under the CCPA include:
- Right to Notice – before collection, a business must inform the consumer as to what categories of PI is being collected, for what purpose.
- Right to Information – a business must, upon request, inform a consumer as to what PI was collected, from what sources, for what purpose, the categories of third parties with whom PI has been shared for a business purpose or to whom PI has been sold.
- Right to Opt-Out – a consumer has the right to opt out of the sale of his/her PI.
- Right to Deletion – a consumer has the right to request his/her PI to be deleted.
- Right to Equal Services & Prices – a consumer must not be discriminated against for exercising his/her privacy rights.
There are exceptions to the above consumer rights that could exempt some part of your business from certain CCPA requirements. For example, a consumer’s personal data that is collected for a vehicle loan transaction may be exempted from the CCPA because it is regulated by federal laws such as the Gramm-Leach-Bliley Act. It’s important that you consult your legal or other advisors for advice.
What Do Dealers Need To Do?
First and foremost, ensure that you understand how the CCPA will impact your business and establish a comprehensive CCPA compliance program.
Examples of what you need to do before 1/1/2020:
- Know where your consumers' PI is.
- Establish policies and processes to verify, accept and respond to consumer requests.
- Update your privacy notice to fulfill your disclosure obligations.
- Update your websites to include required Do-Not-Sell-My-Personal-Information link if you sell PI.
- Assess the strength of your data security.
- Work with your vendors to ensure that they will cooperate with you in responding to consumer requests.
How is Sincro Helping?
To support your CCPA preparedness, Sincro has developed solutions for Sincro Websites and Sincro Advertising that process and store your consumers' personal information.
Sincro Websites
How is Sincro helping me with my CCPA compliance efforts on my Sincro Website?
Sincro will provide the following capabilities to assist with privacy compliance:
- A CCPA-specific section within the privacy statement for dealers to inform consumers about the categories of PI collected, the business purpose, and 3rd parties with whom the data has been shared or sold. This section will also include dealer contacts for consumer requests to review, opt-out of sale, or deletion of personal data.
- A footer link labeled "California Consumer Privacy" has been added to every page on the site and will take users to the CCPA-specific privacy statement. If you sell consumers’ personal data, please update this link label to “Do-not-sell-my-personal-information”.
- A link to the CCPA-specific privacy statement within each website form that says "View Privacy Notice and Consumer Rights".
- A tool within Website Manager that enables dealers to fulfill consumer privacy requests across Sincro digital products. Capabilities include the following:
· Search for customers across digital product
· Review consumer personal information stored in digital data stores
· For verified customers:
â—‹ Print or share electronic copies of stored data
○ For dealers that sell data, set consumer preference to “opt-out” of personal data sale
â—‹ Delete consumer personal information
Sincro Advertising
If you have Sincro Advertising and a Sincro Website...
Sincro has provided a Digital Advertising portion to your Privacy Policy, where consumers can request to review, opt-out of the sale of personal information, or delete personal information. Sincro will respond to these requests, and no action is required of the dealer.
If you have Sincro Advertising and do NOT have a Sincro website...
Sincro provides a link which should be added to your Privacy Policy that will allow consumers to see a description of their rights under CCPA, the categories of information we collect and their uses, and also to request any actions around their data as defined by the law. Please reach out to your Sincro Advertising Analyst for the link.
Sincro collects data anonymously through browser behaviors and therefore cannot remove data for a consumer when given a name, address, or any well-established sources of personal information. Therefore, going through the provided link will be the only means for Dealers to allow their consumers access to Sincro Advertising data.
If you have questions, please reach out to CCPAQuestions@sincrodigital.com
Sincro is providing tools as a service provider. The dealership is ultimately responsible for their CCPA compliance. We recommend dealers consult with their legal and/or advisory team(s) for a full compliancy implementation plan.