FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / third-party-data-sharing-risk-assessment.docx
third-party-data-sharing-risk-assessment.docx · 1038-00010

Parties

Harkness LLP
Cascade Retail Holdings Inc
Fieldhaven Consulting Group LLC
Thornbridge Media Corp
OnPoint Data Solutions Inc
Ecosystem Cascade Retail Holdings Inc
Peakview Analytics Inc
Cascade Digital Marketplace LLC

Dates

August 4, 2025
May 19, 2025
October 31, 2025
December 15, 2025
August 15, 2025
July 14, 2025
February 6, 2024
March 8, 2024
September 14, 2023
April 3, 2024

Amounts

$18.4
$3.87

Obligations

In the absence of a compliant written contract, each of these partners defaults to "third-party" status under the CCPA/CPRA, and data transfers to these partners likely constitute a "sale" or "sharing" of personal information ("PI") for which consumers must be afforded opt-out rights that Cascade is not currently providing
A business that "sells" personal information must provide consumers with the right to opt out of such sale under § 1798
Under the VCDPA (Virginia), CPA (Colorado), CTDPA (Connecticut), TDPSA (Texas), OCPA (Oregon), and other Applicable State Statutes, the Thornbridge arrangement constitutes "targeted advertising" from which consumers must be able to opt out
121, precise geolocation data (defined as location information sufficient to identify a consumer's location within a radius of 1,850 feet) constitutes sensitive personal information for which businesses must provide consumers with the right to limit the use and disclosure of such information
Under CCPA/CPRA regulations (11 CCR § 7025), a business must treat an opt-out preference signal (including GPC) as a valid request to opt out of the sale and sharing of personal information
(b) Opt-Out signal compliance: Thornbridge must agree to honor consumer opt-out-of-sale/sharing signals, including GPC, in real time