California Consumer Privacy Act Becomes Effective January 1

On January 1, 2020, the California Consumer Privacy Act (CCPA) will become effective for all businesses that, among other things, have at least $25 million in annual revenue and collect or use any personal information of natural persons who are California residents. The revenue test generally will apply to any private fund manager if any managed fund has gross revenues of at least $25 million (even if the fund manager’s own revenues are less than $25 million). “Personal information” is broadly defined to include email addresses and telephone numbers, as well as other information more commonly understood to be private.

The CCPA imposes certain obligations on businesses and grants certain rights to California residents whose personal information is not otherwise exempt from the CCPA in whole or in part.