Many small or solo franchisees, subsidiaries, and affiliates of larger businesses may think the California Consumer Privacy Act (CCPA), does not apply to your separate business entity because it does not meet one of the three threshold criteria for CCPA coverage: (1) your annual revenue is under $25 million; (2) you do not annually collect the personal information of 50,000 or more California residents, households or devices; and (3) you are not in the business of selling information. But upon closer inspection, you may be disappointed to learn that California’s groundbreaking new privacy law, which became effective January 1, 2020, may yet still apply to you based on a potentially broad "control" test.