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Publication - January 30, 2023

AdExchanger | So I’m a Third Party, Not a Service Provider. Now What?

Companies throughout the ad tech ecosystem are reckoning with the fact that, due to the revised definition of “business purpose” in the California Privacy Rights Act (CPRA), which amends the California Consumer Privacy Act (CCPA), they may no longer qualify as “service providers” under California privacy law. Instead, they might be treated as “third parties” – and possibly even as “businesses.” As a result, their compliance obligations are likely to be more challenging.

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  • Attorney Richard Eisert

    Richard S. Eisert

    Partner/Co-Chair Advertising + Marketing

    Area Of Focus

    • Privacy, Technology + Data Security
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    212 468 4863
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  • Attorney-Zachary-Klein

    Zachary N. Klein

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    212 237 1495
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