[mirror] CCPA 合规

[phy25]

The California Consumer Privacy Act (CCPA) is a bill intended to enhance privacy rights and consumer protection for residents of California, United States. The CCPA becomes effective on January 1, 2020.

Per Cal. Civ. Code § 1798.140(c):

(c) “Business” means: (1) A sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that collects consumers’ personal information, or on the behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California, and that satisfies one or more of the following thresholds: (A) Has annual gross revenues in excess of twenty-five million dollars ($25,000,000), as adjusted pursuant to paragraph (5) of subdivision (a) of Section 1798.185. (B) Alone or in combination, annually buys, receives for the business’ commercial purposes, sells, or shares for commercial purposes, alone or in combination, the personal information of 50,000 or more consumers, households, or devices. (C) Derives 50 percent or more of its annual revenues from selling consumers’ personal information. (2) Any entity that controls or is controlled by a business, as defined in paragraph (1), and that shares common branding with the business. “Control” or “controlled” means ownership of, or the power to vote, more than 50 percent of the outstanding shares of any class of voting security of a business; control in any manner over the election of a majority of the directors, or of individuals exercising similar functions; or the power to exercise a controlling influence over the management of a company. “Common branding” means a shared name, servicemark, or trademark.

[phy25]

• 因为我们不是 commercial 所以不需要 CCPA 合规。
• 我之前还比较担心的一个问题是，我们从加州的镜像站拉内容是否会有限制，大概看了下应该是没有关系的。

参见：

• https://www.varonis.com/blog/ccpa-vs-gdpr/
• https://siteimprove.com/en/gdpr/who-gdpr-affects-and-whose-data-is-protected/

但是依然存在的几个问题：

• GDPR 还是要遵守的（这个就不弄得那么透明好了（反例），有机会我可能要找其他镜像站的朋友聊一聊，尤其 TUNA 那边现在有公开日志也可以拉下来分析一下）。

  “Any “data controllers” (who determine the purpose and means of processing the data) and “data processors” (who process this data for the controller) that holds personal data of EU citizens”

• 我们还有两个源镜像在 es.net 上，而这是“Federal computer system, the property of the United States Government”。为了避免近期可预见的风险，有必要把这个源切走（虽然的确是访问起来很快）

不过 es.net 这个 TOS 跟院校的比，写得的确挺暴力的。不知道当时 lonecat 有没有协调这个上游同步（也不敢问不敢 at）。

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