If your mobile app works with California residents and your business exceeds thresholds ($25M annual revenue, or 100K+ consumers, or 50%+ revenue from data sales), CCPA is mandatory. We implement CCPA compliance turnkey — configure opt-out, deletion and data export rights, integrate GPP. We have 5 years of experience and over 30 projects bringing apps into compliance with US privacy laws.
The key difference from GDPR: CCPA does not require consent before data collection, but requires the right to opt out of data sale and the right to deletion. This changes the implementation architecture. CCPA is softer on consent but stricter on opt-out.
Why is "sale of data" under CCPA broader than it seems?
CCPA defines "sale" very broadly: any transfer of data to a third party for "valuable consideration" — including ad networks, analytics platforms with behavioral data, data brokers. Transmitting data to Facebook SDK for advertising purposes is a "sale" under CCPA. This means: most apps with ad monetization technically "sell" data and must provide opt-out rights.
How to implement opt-out: technical details
The "Do Not Sell or Share My Personal Information" button must be conspicuous — the App Store won't accept it hidden in the fifth tab of settings. In practice, place it in the main profile settings menu.
// Storing CCPA opt-out status class CCPAManager { private let defaults = UserDefaults.standard private let optOutKey = "ccpa_do_not_sell" var isOptedOut: Bool { get { defaults.bool(forKey: optOutKey) } set { defaults.set(newValue, forKey: optOutKey) updateThirdPartySDKs(optOut: newValue) syncToServer() } } private func updateThirdPartySDKs(optOut: Bool) { // Meta Audience Network Settings.shared.isAdvertiserDataCollectionEnabled = !optOut // Google AdMob — limited data processing let extras = GADExtras() extras.additionalParameters = ["npa": optOut ? "1" : "0"] // Adjust if optOut { Adjust.disableThirdPartySharing() } } } Important: the opt-out must persist across sessions and sync to the server — so that on app reinstall the setting is restored.
What is Global Privacy Control and how to implement it in a mobile app?
Browsers have begun supporting Global Privacy Control (GPC) — a "do not sell" signal at the HTTP header level Sec-GPC: 1. CPRA (the latest update) requires operators to respect GPC. In a mobile app, there is no browser GPC, but IAB's Global Privacy Platform (GPP) for mobile fills this niche — it stores a consent string in NSUserDefaults / SharedPreferences under standard keys that all compatible SDKs read automatically.
Comparison of CCPA and GDPR
| Aspect | CCPA | GDPR |
|---|---|---|
| Basis of processing | Opt-out (withdrawal after collection) | Consent (before collection) |
| Right to deletion | Yes, 45 days | Yes, without delay |
| Fines | $2,500–7,500 per violation | €20M or 4% of revenue |
| Scope | California, business > $25M | Entire EEA |
Consumer rights under CCPA
| Right | SLA | Technical implementation |
|---|---|---|
| Right to know | 45 days | "My Data" screen + export |
| Right to deletion | 45 days | Delete account workflow |
| Right to correction | 45 days | Edit profile + sync |
| Right to opt-out | Immediately | "Do Not Sell" toggle |
| Right to portability | 45 days | Export data as JSON/CSV |
"Right to know" is not just a list of categories in the Privacy Policy. Upon request, specific data of the specific user for the past 12 months must be provided. This requires a backend API that can aggregate data by userId.
How to verify deletion requests?
CCPA does not allow deletion requests to be executed without identity verification — otherwise an attacker could delete another account's data. Acceptable methods: email verification (link sent to email), re-authentication in the app, SMS OTP. For registered users, re-authentication is sufficient. For unregistered requests (via email or phone), two-step verification.
Limited processing of sensitive data (CPRA)
CPRA added the category "sensitive personal information" with the right to limit its use. This includes: SSN, financial data, precise geolocation, biometrics, health data, children's data. These require a separate button "Limit the Use of My Sensitive Personal Information".
Privacy Notice at collection
CCPA requires a "notice at collection" — notice at the moment of data collection. For mobile apps: before requesting location permission — a brief explanation of why and how long geolocation is stored. Before requesting contacts — the same.
What is included in CCPA compliance work
- Audit of current compliance and gap identification
- Implementation of opt-out button and integration with SDKs (AdMob, Meta, Adjust)
- Setup of deletion and data export rights (client + backend)
- Integration of IAB Global Privacy Platform (GPP)
- Request verification (email/SMS/re-auth)
- Documentation for App Store Review
- Testing against App Store Review Guidelines Section 5.1
Timelines: basic implementation — from 2 to 3 days; full set with backend — from 4 to 6 days. Pricing is determined individually.
Contact us to evaluate your project. Get a consultation on CCPA compliance — we guarantee passing App Store Review and compliance with the latest law changes.