Yes, we do. We further recommend that you consult with your compliance team at your broker dealer (BD) or registered investment advisor (RIA) for additional guidance.

Is my firm required to comply with the CCPA?

The California Consumer Privacy Act (CCPA), went into effect in January 2020 and applies to all California residents. Therefore, even if your firm does not have a physical branch in California, but you serve California residents, you are likely required to comply with the law. Consult with your compliance team or legal counsel for additional guidance.

What does the CCPA do for consumers?

The Act is similar to other current or proposed state privacy laws and specifically grants California consumers:

  • The right to know about the personal information a business collects about them and how it is used and shared

  • The right to delete personal information collected from them (Note: This right has some exceptions to comply with financial regulations -- in particular, the Gramm-Leach-Bliley Act, is exempted from most aspects of the CCPA. Depending on your compliance department’s regulations, this could mean placing someone on a Do Not Contact list or other restrictions)

  • The right to opt-out of the sale of their personal information

  • The right to non-discrimination for exercising their CCPA rights

How does Snappy Kraken help me comply with the CCPA?

Because Snappy Kraken works with thousands of individual firms that have differing compliance requirements, we have made our platform flexible, giving you (or your compliance supervision) the option to include (or not to include) appropriate CCPA disclosures and links in the footer of marketing elements such as landing pages and emails. NOTE: It is possible that your firm requires that specific disclosures related to the CCPA be added to your account, in which case you will not be able to remove them.

Our flexible disclosure feature enables all CCPA-related requests to come through whatever compliance approved channel your firm prefers, such as through email or via a specific form or page on your website, or a page of your RIA or BD's website.

How can I modify my disclosures to include CCPA language and links?

After logging into your Snappy Kraken account:

  1. Navigate to: Account > Business Information > Disclosure

  2. Edit your desired disclosure, adding appropriate links to the webpage or email address where your firm wishes for CCPA requests to be sent.

EXAMPLE DISCLOSURE:

We take protecting your data and privacy seriously. In support of the California Consumer Privacy Act (CCPA), we never sell your personal information. Requests for a copy of your personal information or for deletion of your personal information should be submitted to [INSERT COMPLIANCE APPROVED LINK OR EMAIL ADDRESS].

Is there anything else I should know?

This article is provided solely for informational purposes and should not be relied on as legal or compliance advice. Our individual member’s requirements often differ and Snappy Kraken strongly encourages you to obtain appropriate advice on your implementation of privacy and data protection requirements from your firm's supervision or legal counsel.

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