The California Delete Act (2023) created a public register of "data brokers" and a central deletion system called DROP, the Delete Request and Opt-out Platform, run by the California Privacy Protection Agency. Customers ask us whether using Happierleads puts them on that register. For almost everyone the answer is no, and this article explains why in plain language. We are not lawyers and this is not legal advice; it is how the rules read and how they apply in practice.

The law defines a data broker as a business that knowingly collects 

. Both parts have to be true. A "direct relationship" means the person intentionally interacted with your business to learn about, buy or use your products within the last three years.

Why identifying your own website visitors does not make you one

Either point on its own takes you outside the definition. Businesses that use Happierleads to identify and contact their own visitors do not need to register, do not pay the fee and do not need to connect to DROP. You can identify visitors at the exact-person level and go build pipeline.

We act as your service provider. We process visitor data on your instructions, for your purposes only, under our 

. We never sell or share one customer's leads with another, and we run a public opt-out form at 

If you resell Happierleads under your own brand to your own clients, the same logic protects you, with one condition. Your client owns the website, the visitor came to your client's site, and you process that visit on the client's behalf. That is the service-provider position, and it holds as long as your contract with each client says so: you process on their instructions, for their purpose only, you do not sell the data on and you do not combine data across clients. Put those four sentences in your client agreement and you mirror the same chain we sign with you.

If you ever do register, this is the whole job

Some partners grow into selling data more widely, or their lawyer prefers to register. It is admin work, not a rebuild:

In practice that is a privacy page on your brand with a deletion route, a 45-day calendar reminder, and a hashed email list you check the DROP file against.

If you are early stage, unfunded or pre-revenue, this is not where your time goes. Get customers, get them results, and revisit the registration question with a lawyer when the revenue makes the fee a rounding error. The businesses that fail at that stage fail from no revenue, not from a filing they skipped at zero.

Sources: the California Privacy Protection Agency's DROP page for data brokers (privacy.ca.gov/drop-for-data-brokers) and the Delete Act regulations. Related reading: 

Is it legal to identify website visitors?

For most Happierleads customers, no. What a "data broker" is, why identifying visitors to your own site does not make you one, where white-label resellers stand, and exactly what DROP requires if you ever do register.

California Delete Act, DROP and data brokers: does it apply to you?

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