Just noticed this on Pandora: The page footer contains a link to “Your CA Privacy Rights,” which takes you to this:
California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we disclosed their personal information (if any) for direct marketing purposes in the preceding calendar year and the categories of personal information disclosed to those third parties. If you wish to make such a request or have any questions about Pandora’s information sharing practices, you may contact us by sending us an email at firstname.lastname@example.org or write to us at Pandora Media, Inc., 2101 Webster Street, Suite 1650 Oakland, CA 94612, Attn: Listener Support.
As the text discloses, this is the fruit of California Civil Code § 1793.83. It’s an internet era law, dating back to 2005, that puts obligations on businesses who disclose personal customer data to third parties that then use that data for direct marketing.
When I start to read the statute, I get that feeling I so often get when I read California statutes, of wanting to spite my eyeballs for what they are seeing. It’s not only confusing, it’s not even clearly confusing. Which is to say it’s confusing in a confusing way. After I read it, I’m not even clear on how I’m confused. So I really don’t want to try to explain to you what the statute requires because I’m not sure what it requires, and I’m not even sure I could be sure if I spent a lot of time on it.
A business required to comply with this section shall, at its election, do at least one of the following:
(A) Notify all agents and managers who directly supervise employees who regularly have contact with customers of the designated addresses or numbers or the means to obtain those addresses or numbers and instruct those employees that customers who inquire about the business’s privacy practices or the business’s compliance with this section shall be informed of the designated addresses or numbers or the means to obtain the addresses or numbers.
(C) Make the designated addresses or numbers, or means to obtain the designated addresses or numbers, readily available upon request of a customer at every place of business in California where the business or its agents regularly have contact with customers.
Really, do they just go with their first draft of these things? Because I’m not sure most people could write such a confusing first draft. They must draft a first draft and then do some undrafting work on it to walk it back.
I know, I keep railing on California statutes over and over and over and over.
At any rate, I note that Pandora is saying “Your CA Privacy Rights” rather than “Your Privacy Rights” or “Your California Privacy Rights.” Risky, I guess. Or not. Hard to tell.
Anyway, I e-mailed Pandora to ask for a disclosure under the law – and I disclosed that I am not a California resident, but I’d appreciate it all the same if they would honor it – and I’ll post a follow-up here.