7026(f)(3)(B)—7026(f)(3)(B)
>Control Description
Business V is a marketing company that discloses consumers’ personal information to its clients via a batched upload every Friday. Business V’s disclosure of personal information is a sale because it receives valuable consideration in exchange for the information. Siobhan submits a request to opt-out of sale/sharing to Business V through the mail, which Business V receives on Thursday. Business V finishes processing Siobhan’s request on Tuesday because it requires a few days to update all internal systems and databases with Siobhan’s request. Accordingly, Siobhan’s personal information was not removed from the disclosure that occurred on the first Friday after receiving her request, though it was removed from the disclosure that occurred on the second Friday. Business V must notify all its clients that received Siobhan’s information on the first Friday after Siobhan made her request to opt-out of sale/sharing and direct them to comply with her request and forward the request to any other person to whom they made Siobhan’s personal information available.
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