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Guide · US state law

CCPA and CPRA explained for people who live off ads

California has the most detailed privacy law in the United States and the one that issues the most fines. In this guide you will understand when it applies to your site, why personalized ads count as a sale or sharing of data and what must appear on the page for the visitor to say no.

  • ✓Based on the text of the law, the agency's rules and public settlements
  • ✓Examples designed for sites with AdSense and Ad Manager
  • ✓Read-only scan, no changes to the site
100,000California consumers or households per year: one of the thresholds that bring a company within the law
$7,988maximum fine per intentional violation or one involving minors under 16, amount adjusted in 2025
16age below which selling or sharing data requires prior authorization
2026year the new rules on risk assessments, automated decisions and audits took effect

What it is

The law that gave visitors the right to say no to the sale of their data

The California Consumer Privacy Act, or CCPA, was passed in 2018 and took effect on January 1, 2020. It gives California residents the right to know what data a company collects, to ask for that data to be deleted and to prevent it from being sold.

In November 2020, voters approved the California Privacy Rights Act, the CPRA, which rewrote a good part of the CCPA. The changes have applied since January 1, 2023. That is why, when people talk about the CCPA today, they almost always mean the law as amended by the CPRA.

The CPRA created the California Privacy Protection Agency, an agency devoted only to privacy, which now presents itself to the public as CalPrivacy. It writes the detailed rules, investigates companies and issues fines. California's attorney general still has the power to sue those who break the law.

For a site with ads, the central point is simple: when the visitor's cookies and identifiers are used to show ads based on what they did on other sites, the law treats that as sharing data. And the visitor has the right to refuse.

Checklist

What you need to meet

They apply to companies that exceed one of the law's thresholds and sell or share data of California residents.

  1. Put the opt-out link on the home page

    Anyone who sells or shares data needs a clear link in the header or footer of the home page. The rules also accept a single link called Your Privacy Choices or Your California Privacy Choices, with the official icon next to it.

    Example

    Footer: Do Not Sell or Share My Personal Information

  2. Accept GPC as a valid opt-out

    The attorney general says GPC must be respected as a valid opt-out request. The rules in force since 2026 require the site to show the visitor the status of their choice.

    Example

    Privacy panel: We received your GPC signal. We do not sell or share your data.

  3. Honor the opt-out quickly

    The opt-out must be honored as soon as possible, within 15 business days at most. Requests to know, delete or correct have a 45-day deadline, with another 45 if the visitor is notified.

  4. Give notice at collection and keep the full policy

    The notice appears before or at the time data is collected and includes the link to the privacy policy. The policy explains the visitor's rights and how to use them.

    Example

    We use cookies from ad partners. Under California law, this may be sharing of data. To opt out, click Do Not Sell or Share My Personal Information.

  5. Offer at least two channels

    Anyone who sells or shares data needs two or more ways to opt out. For access or deletion requests, an online-only business may offer just an email.

    Example

    Privacy requests: privacy@yoursite.com

  6. Keep the choices balanced

    The rules require symmetry in the choices. A notice that only offers Yes and Ask me later is not balanced, because there is no way to refuse.

    Example

    Two buttons of the same size and color: Accept and Decline

  7. Ask for authorization for under 16

    To sell or share data of someone you know is under 16, prior authorization is required. Under 13, the authorization comes from the parents or guardians.

  8. Pass the opt-out to Google

    In the California section of the GPP string, an opt-out of sale or sharing turns on RDP. Another option is to turn on RDP in the tag for people who clicked the link.

    // GPT: liga o processamento restrito de dados (RDP)
    // para quem recusou a venda ou a publicidade direcionada
    googletag.cmd.push(function () {
      googletag.pubads().setPrivacySettings({
        restrictDataProcessing: true
      });
    });

In practice

Right and wrong

Official tools

Certified CMPs and official links

Google does not require a certified CMP for California. You can use Google's US states message, a CMP that generates GPP, or RDP in the tag. These are the official links.

Who it applies to

Passing any one of these three thresholds is enough

The law applies to for-profit businesses that do business in California, collect data from residents of the state and reach at least one of the thresholds below. Being headquartered there is not a condition: companies from elsewhere that serve Californians can also be covered.

Revenue above $26,625,000

Annual gross revenue above this amount, which was $25 million and was adjusted for inflation in January 2025. Revenue counts in total, not just what comes from California.

100,000 consumers or households

Buying, selling or sharing data of 100,000 or more California consumers or households per year. A portal with a lot of Californian traffic and personalized ads can get there without noticing.

Half of revenue from data

Getting 50% or more of annual revenue from selling or sharing Californians' personal data, regardless of the size of the company.

Who is left out

Nonprofits and public agencies are, as a rule, not covered. Companies below all three thresholds are not either, but ad partners may require opt-out signals anyway.

Definitions

The words that change everything for a site with ads

The CCPA uses its own terms. Understanding the four below avoids most of the confusion.

Personal information

Any data linked, or that can be linked, to a person or household. The law itself includes online identifiers, IP address, browsing history and interactions with sites and ads.

Sensitive personal information

Data such as government IDs, account logins, precise location, racial origin, religion, health, sex life and biometrics. The visitor can ask for the use of this data to be limited.

Sale

Passing data to third parties in exchange for money or other value. There does not have to be a direct payment: letting a partner collect data in exchange for a service can count as a sale.

Sharing

Passing data to third parties for cross-context behavioral advertising, that is, ads chosen based on what the person did on other sites and apps. It applies even without payment.

Rights

What a California visitor can ask for

The company has 45 days to respond to requests, with an extension of another 45 when necessary. Opt-out requests must be handled much faster and without red tape.

Know and access

Find out what data was collected, where it came from, what it is used for and who it was sold or shared with.

Delete and correct

Ask for the collected data to be deleted and for wrong data to be corrected, with some exceptions set out in the law.

Refuse sale and sharing

Tell the company to stop selling or sharing their data, including for personalized ads, through a link on the site or an automatic browser signal.

Limit sensitive data and avoid retaliation

Restrict the use of sensitive data to what is necessary and not be treated worse, with a higher price or a reduced service, for having used these rights.

Site obligations

Opt-out link, GPC signal and privacy notice

Anyone who sells or shares data must offer a clear link with the text Do Not Sell or Share My Personal Information, normally in the footer of every page. The agency's rules allow replacing that link and the sensitive data link with a single link called Your Privacy Choices, along with the official icon. Clicking it must lead to a simple way to opt out, without registration and without requiring documents.

The automatic opt-out signal is also mandatory. The best-known example is the Global Privacy Control, the GPC, a browser or extension setting that tells every site that the person does not want their data sold or shared. Since January 1, 2026, the rules require the site to show whether it processed this signal, for example with a message saying the opt-out request was honored.

A notice at collection and a complete privacy policy are also required. The policy lists the categories of data collected, the purposes, the categories of companies that receive the data, whether there is a sale or sharing, how long the data is kept and how to exercise each right. The agency's rules also ask for the date of the last update.

The rules ban so-called dark patterns: refusing cannot take more steps than accepting, and closing a pop-up does not count as consent. To sell or share data of anyone the company knows to be under 16, prior authorization is needed. Between 13 and 16, the teenager authorizes it themselves; under 13, the parents do.

Timeline

How California's law got here

Dates confirmed in official California state sources.

  1. January 1, 2020

    CCPA takes effect

    The right to know, delete and refuse the sale of data is born.

  2. August 24, 2022

    First fine: Sephora

    A $1.2 million settlement for selling data through third-party trackers and ignoring the GPC.

  3. January 1, 2023

    CPRA takes effect

    Sharing for ads, correction and the limit on sensitive data come in, and the mandatory 30-day cure period before punishment ends.

  4. January 1, 2025

    Adjusted amounts

    The revenue threshold rises to $26,625,000 and the fines to $2,663 and $7,988.

  5. January 1, 2026

    New package of rules

    Risk assessments for significant-risk activities, the visible confirmation of the opt-out signal and the new rules against dark patterns take effect.

  6. January 1, 2027

    Automated decisions and browsers

    The automated decision-making rules for important decisions begin. The 2025 law AB 566 starts requiring browsers to offer a built-in opt-out signal.

  7. April 1, 2028

    Filings with the agency

    Deadline to submit the attestation and the summary of risk assessments. Security audit certifications begin on this date for anyone with revenue above $100 million and follow in 2029 and 2030 for the rest.

Enforcement and fines

Who enforces it and what a mistake costs

The privacy agency and the attorney general can both act. Since 2023 there is no longer a mandatory 30-day cure period before punishment. The agency can take good faith into account, but does not have to warn first.

The fines were adjusted in January 2025: up to $2,663 per violation and up to $7,988 per intentional violation or one involving minors under 16. Because each visitor or each request can count as a violation, the total grows fast. Individuals can sue directly only in cases of data breach, with damages between $107 and $799 per person per incident.

Sephora paid $1.2 million in 2022 over trackers and the GPC. In March 2025, Honda paid $632,500 to the agency for requiring too much data for the opt-out and for a tool that did not present the choices in a balanced way. In May 2025, the clothing brand Todd Snyder paid $345,178 because a poorly configured portal failed to process opt-out requests for 40 days.

In July 2025, the attorney general reached a $1.55 million settlement with the health site Healthline, which did not honor opt-outs of targeted advertising, including through the GPC. In September 2025, Tractor Supply was fined $1.35 million, which includes failures in handling the GPC. In February 2026, Disney reached the largest settlement so far, $2.75 million, because the opt-out and the GPC applied only on one device or service.

AdSense and Ad Manager

What changes on a site with Google ads

Google offers restricted data processing, called RDP. When the signal is present, Google does not show ads based on the visitor's past behavior and sends non-personalized requests to buyers. In this mode, Google acts as a service provider, a role that California law does not treat as a sale.

There are two paths. The first is a CMP that generates the GPP string, the IAB Tech Lab format for privacy signals. AdSense and Ad Manager read the US National section and the California section. In the California section, refusing the sale or sharing turns on RDP, and the opt-out for under-16s triggers the treatment for children. The second path is to turn on RDP directly in the tag, for example with restrictDataProcessing in GPT, only for people who clicked the opt-out link.

The US states privacy message, in the Privacy & messaging menu of AdSense and Ad Manager, covers California. It shows the Do Not Sell or Share My Personal Information link, records the opt-out and saves the choice in GPP. Google reminds you, however, that responsibility for complying with the law remains with the site.

Header bidding, video networks and social media pixels also receive data. The opt-out needs to reach all of them, not just Google.

In practice

What is and is not allowed in California

Everyday examples from a site with AdSense or Ad Manager and Californian visitors.

Allowed

  • Show personalized ads until the visitor opts out, as long as the opt-out link is visible
  • Use a single Your Privacy Choices link with the official icon in the footer
  • Read the GPC and automatically mark the visitor as opted out in the GPP string
  • Show a short message confirming that the opt-out signal was honored
  • Show non-personalized ads to people who opted out
  • Use Google's US states message

Not allowed

  • Ask for registration or a document to record the opt-out
  • Make the accept button colorful and hide the reject button in gray
  • Treat closing the pop-up as acceptance
  • Turn off only Google and leave header bidding and pixels receiving data
  • Ignore the GPC because the visitor did not click the link
  • Use data of people you know to be under 16 for personalized ads without authorization

Common errors

Failures that show up in enforcement cases

Almost all public settlements involve an opt-out that seems to work but does not.

Link that leads to a text

The Do Not Sell or Share link opens the privacy policy instead of a screen where the visitor can actually opt out.

GPC read but with no effect

The CMP detects the GPC, but the ad tags load earlier or keep receiving the not-opted-out signal.

Opt-out only for Google

RDP is turned on in Google, but header bidding partners and third-party pixels keep collecting data.

Unbalanced banner

Accept all with one click and refuse only after opening settings. The lack of balance in the choices weighed in the Honda case.

Outdated policy

A policy with no update date, no data categories or no mention that there is sharing for ads.

California-only message, with no string

The banner appears, but no GPP string is generated, so Google and partners do not receive the visitor's choice.

In ConsentMode

What the audit checks about the CCPA

  • Opens the site as a California visitor and looks for the Do Not Sell or Share or Your Privacy Choices link on every page analyzed.
  • Repeats the visit with the GPC on and watches whether the GPP string, RDP and the confirmation message change on the page.
  • Reads the GPP string in the ad requests and shows whether the US National or California sections indicate the opt-out.
  • Identifies the CMP from the page code and checks that the ad tags wait for its response.
  • Reads the privacy policy and points out missing items, such as data categories, sharing for ads and the update date.

Frequently asked questions about the CCPA

My site is Brazilian. Does the CCPA apply to me?

It may. The law does not require a headquarters in California. If the company serves residents of the state and passes one of the three thresholds, such as 100,000 consumers or households per year with data shared for ads, it is covered. Below the thresholds, the law does not apply, but Google and other partners still read the opt-out signals.

Do AdSense ads count as a sale?

Personalized ads based on browsing on other sites fit the concept of sharing. With RDP on, Google acts as a service provider and shows only non-personalized ads to that visitor.

Do I need a cookie banner for California?

The CCPA works on an opt-out basis, so it does not require asking permission first for adults. What it requires is the notice at collection, the opt-out link and honoring the GPC. For under-16s, opt-in is required.

Is the GPC really mandatory?

Yes. The attorney general and the agency treat the GPC as a valid opt-out request, and several settlements, such as those with Sephora, Tractor Supply and Disney, cite GPC failures. Since 2026 the site must also show whether it processed the signal.

Does the risk assessment apply to a blog?

It applies to businesses covered by the law whose activities are on the significant-risk list in the agency's rules. Anyone running personalized ads should check that list with a lawyer. A blog below the CCPA thresholds does not need one. Anyone above them who fits the list must document the assessment and submit the attestation by April 1, 2028.

Does ConsentMode solve the CCPA for me?

No. ConsentMode is not a CMP and does not show a banner. It audits the site from the outside and shows what to fix. The legal decision is up to your lawyer.

Library

Official sources

This guide was written from these official pages. Read them directly at the source:

See whether your opt-out really works

The audit opens the site as a California visitor, with and without GPC, and shows what to fix without changing anything.

Start the audit