California residents must complete two separate steps to fully opt out of the sale or sharing of their personal data: submit a webform request and disable advertising cookies via the website footer link on each browser and device used.
This analysis describes what Zendesk's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision requires California residents to take two distinct actions to exercise their CCPA opt-out right, and states that cookie blocking or clearing will negate the opt-out for automatically collected device data. The operational complexity of this mechanism may affect whether residents can effectively exercise their statutory opt-out right, particularly across multiple devices and browsers.
Interpretive note: Whether the two-step, per-device opt-out mechanism satisfies the CPRA's 'easy opt-out' standard is subject to regulatory interpretation by the CPPA and has not been definitively resolved by published enforcement guidance.
Under this clause, California residents who do not complete both steps, or who block or clear cookies, will not have their opt-out fully honored for device-level data automatically collected and shared with advertising technology partners. The agreement requires this process to be repeated on each browser and device.
Cross-platform context
See how other platforms handle California Two-Step Opt-Out Requirement and similar clauses.
Compare across platforms →"In order to fully exercise the Right to Opt Out of Sale or Sharing with respect to any 'sale' or 'sharing' of information, you must undertake both of the following steps: Submit a Right to Opt Out of Sale or Sharing request using our webform; and Disable the use of advertising cookies and other tracking technologies by clicking the 'Do Not Sell or Share My Personal Information' link in our website footer. You must complete this step on each of our Sites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use. If you block cookies, we will be unable to comply with your Right to Opt Out of Sale or Sharing request for device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies. If you clear the cookies in your browser, you will need to follow Step 2 above again.Excerpt from Zendesk's Privacy Policy
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This provision requires California residents to take two distinct actions to exercise their CCPA opt-out right, and states that cookie blocking or clearing will negate the opt-out for automatically collected device data. The operational complexity of this mechanism may affect whether residents can effectively exercise their statutory opt-out right, particularly across multiple devices and browsers.
Under this clause, California residents who do not complete both steps, or who block or clear cookies, will not have their opt-out fully honored for device-level data automatically collected and shared with advertising technology partners. The agreement requires this process to be repeated on each browser and device.
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