Famous Birthdays LLC

Please note there is a major discrepancy between the numbers of requests Famous Birthdays LLC ("Famous Birthdays") receives. This is because Famous Birthdays uses consumer personal information in two distinct ways:

1. Running an advertising-supported public website, which shares consumer information with advertising agencies; and

2. Maintaining and licensing access to a database of information concerning celebrities, the overwhelming majority of which is "publicly available" information under the CCPA.

Use #1 attracts large numbers of opts outs from selling/sharing, which are received through Famous Birthdays' consent management platform (including via global privacy control) and processed instantaneously.

Use #2 attracts very modest numbers of requests to delete from the profiled celebrities, which are processed manually. Please note that it is only use #2 that qualifies Famous Birthdays as a data broker.

Information is being provided about both uses because we understand that to be required, but we would note that conflating the two kinds of data uses is more likely to confuse consumers than it is to inform them.

Separately, we'd ask that the CPPA uses its regulatory authority to reduce the burdens this process places on small businesses like Famous Birthdays that only barely qualify as Data Brokers under the law and appear to be on the margins of what the State is seeking to regulate with this process. The reporting could be better directed to only those uses implicated by a business' data brokerage operations, and could also levy fees that are better tailored to business' ability to pay. On the latter score, note that the current fees are extremely onerous on small business.