Which data privacy laws apply to my business?
Start with the three questions that decide scope
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Where are you established and where do you target?
Most laws key off establishment (where you operate) and/or targeting (whose data you collect or whose market you serve).
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Whose data do you collect and how much?
Thresholds often depend on number of people/households you affect, your revenue, or whether you sell/share data for ads.
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What kind of data and for what purpose?
Rules tighten for sensitive data (health, financial, children, precise location), profiling/ads, and children’s data.
Global baseline you should assume by default
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GDPR (EU/EEA + UK variant):
Applies if you’re established in the EU/EEA or if, from outside, you offer goods/services to people in the EU/EEA or monitor their behavior (think analytics/ads). That’s Article 3’s “territorial scope.”
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ePrivacy rules for cookies and similar tech (EU/EEA):
Separate from GDPR. If you store or access information on a user’s device (cookies, localStorage, SDKs, fingerprinting), you generally need prior consent unless a narrow exception applies.
- UK: GDPR-style regime remains in force, with reforms enacted in 2025 that refine (not replace) the framework. If you target UK users, treat it as GDPR-like with some differences.
United States (consumer privacy, state-by-state)
The U.S. has sector laws (see below) and state consumer privacy laws with differing thresholds. As a baseline, if you do business with residents of a state and meet thresholds, the law applies—even if you’re not physically there.
- California CCPA/CPRA (most influential): Applies to for-profit businesses doing business in CA that (a) exceed $25M revenue, or (b) buy/sell/share personal info of 100,000+ residents/households, or (c) get ≥50% of revenue from selling CA personal info. CPRA amended CCPA; it’s one law.
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Colorado CPA (illustrative of other states): No revenue threshold; applies from 100,000 consumers (or 25,000 if you get revenue from selling data). Many states mirror this style with tweaks.
(Tip: If California applies to you, assume other enacted state laws may as well and run a state-by-state check.)
The Americas beyond the U.S.
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Brazil LGPD: GDPR-style law with extraterritorial scope; applies if you process data in Brazil or offer/collect data from people in Brazil.
Canada:
- PIPEDA (federal, private sector) + provincial laws (e.g., Quebec Law 25) create obligations when handling residents’ personal information, including new governance and DPIA-style expectations in Quebec.
APAC and Africa (quick compass)
- Singapore PDPA: Baseline personal data law covering collection, use, and disclosure; applies to organizations handling personal data in Singapore, with specific obligations and exceptions.
- (Also consider) Australia Privacy Act, New Zealand Privacy Act 2020, South Africa POPIA, and others—each with GDPR-like concepts but local nuances.
Sector-specific laws you can’t ignore
These apply because of what you do or which data you handle—regardless of general consumer privacy laws:
- HIPAA (U.S. health): If you’re a covered entity (health plans, most providers, clearinghouses) or a business associate handling PHI for them, HIPAA’s Privacy/Security Rules apply. Not a covered entity/BA? HIPAA likely doesn’t apply.
- GLBA (U.S. financial): If you’re a financial institution (broadly defined)—loans, investment advice, insurance—you must provide privacy notices and safeguard nonpublic personal information.
- COPPA (U.S. children): If your site/app is directed to children under 13 or you have actual knowledge you’re collecting from under-13s, you need verifiable parental consent and other controls.
A 10-minute self-assessment (decision path)
- Map the data: What personal data do you collect (including cookies/IDs), from whom (countries/states), and for what purposes (analytics, ads, personalization, support)?
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List audiences by location: EU/EEA, UK, U.S. states, Brazil, Canada (incl. Quebec), Singapore, etc.
Check thresholds:
- California: $25M revenue or 100k residents/households or ≥50% revenue from selling/sharing.
- Colorado: 100k consumers or 25k + revenue from sales.
- GDPR/ePrivacy: Target EU/EEA residents or monitor behavior? Use cookies/SDKs requiring consent?
- LGPD/Canada/others: Do you collect from residents there? If yes, assume applicability.
- Identify special data/uses: Health (HIPAA), finance (GLBA), children (COPPA), sensitive categories, selling/sharing for ads, cross-border transfers.
- Decide your role: Controller/processor (GDPR terms) or service provider/third party (U.S. terms). Your role changes your obligations.
- Document your conclusion: Keep a short record of which laws you believe apply and why. It becomes your accountability artifact.
What “compliance” usually means in practice
- Consent and preferences: When the law requires consent (e.g., EU ePrivacy for most cookies; GDPR for certain processing), show a banner, record choices, and respect GPC/“Do Not Track” if your policy says so. (Cookie Compliance supports consent banners, GPC detection, and consent logs.)
- Notices: Maintain a privacy notice tailored to the applicable regimes (EU, CA, CO, etc.).
- Data rights: Provide access/deletion/opt-out controls where required.
- Contracts: Put DPA/DPAs and state law addenda in place with vendors.