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ARTICLE · 30 MAY 2023

With July 1st In View, Google Updates CCPA Contract Terms

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

Kelley Drye & Warren LLP

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Google updated its privacy terms earlier this month, shifting away from offering many of its advertising services on a "service provider" basis.

United StatesMedia, Telecoms, IT, Entertainment

Google updated its privacy terms earlier this month, shifting away from offering many of its advertising services on a "service provider" basis. With the change, Google states that its Customer Match, Audience Partner API, and certain audience-building services no longer meet the CCPA's strict new requirements to be offered on a "service provider" basis. The implication of this change is that companies leveraging these services are "selling" or "sharing" personal information and will need to offer consumers an opportunity to opt out.

"Restricted Data Processing" Under the CCPA

Since 2019, Google has offered a number of its services on a "restricted data processing" basis. Where a service is configured for restricted data processing, Google acts as a service provider with respect to personal information (i.e., names, email addresses, online identifiers) that Google collects from advertisers, publishers, and other partners.

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