Tool
Are You a Data Broker?
California’s Delete Act defines a data broker as a business that knowingly collects and sells personal information about consumers it has no direct relationship with — with carve-outs for data already covered by other laws. Four questions will tell you where you likely stand.
1. Does your business collect personal information about consumers?
2. Do you sell or share that personal information with third parties?
Selling lead data to buyers counts.
3. Is at least some of that information about consumers you do NOT have a direct relationship with?
A "direct relationship" generally means the consumer intentionally interacted with your business.
4. Is essentially all of that data already covered by the GLBA, FCRA, or HIPAA?
Data governed by those regimes is generally carved out of the data-broker definition.
Assessment
Answer the questions to see where you likely stand under the California Delete Act.
This is an educational tool, not legal advice. It offers general, best-practice guidance from an operator's perspective and does not account for your specific facts or jurisdiction. Using it does not create an attorney–client relationship. For advice on your situation, consult qualified counsel.