CPRA Do Not Sell & Do Not Share
Do Not Sell/Share is an operational guarantee, not a checkbox. We assume every identifiable flow is sharing under the CPRA definition unless we can prove the opposite. This page ties the disclosures to every client-side banner, server-side API, and internal vendor that touches personal information.
The default state for every visitor is Do Not Sell or Share. Analytics, experiments, AI training data, and Firebase exports do not execute unless a visitor explicitly reverses that preference. Ambiguity is treated as sharing, so every log and vendor integration is disabled until the visitor switches the toggle below.
Each of these flows leaves the organization’s direct control and therefore demands Do Not Sell enforcement.
Every authenticated action is captured by `activityTracker` (src/services/analytics/comprehensive-activity-tracker.ts), stored in Firestore collections such as `user_activities`, `user_activity_summaries`, and `user_enhanced_analytics`. This includes page views, clicks, device metadata, and inferred location. Under CPRA this is treated as sharing/sale until the visitor opts out.
The `EnhancedUserAnalyticsService` (src/services/analytics/enhanced-user-analytics-service.ts) materializes dashboards for stakeholders by reading the same Firestore summaries. Data is surfaced in admins’ consoles, reports, and exports; those exports are in scope for Do Not Sell/Do Not Share as third-party disclosures.
The client-side `AnalyticsProvider` (now located in src/components/Analytics/AnalyticsProvider.tsx) initializes `@vercel/analytics/react` and SpeedInsights. Events are only emitted when both analytics consent and Do Not Sell opt-out are satisfied. Without an explicit switch, no page or click data leaves the browser.
`/api/analytics/anonymous` (src/app/api/analytics/anonymous/route.ts) receives browser events and hashes the request IP before writing to internal systems. Because these payloads travel off-device, they qualify as sharing unless the banner, Do Not Sell, or GPC signal prevents them.
The new `ExperimentProvider` (src/components/Experiments/ExperimentProvider.tsx) gates all experiments with Do Not Sell. When an opt-out is active, we clear experiment assignments, avoid writing to localStorage, and never call vendor SDKs.
Every enforcement touchpoint is wired to the same Do Not Sell preference. No vendor receives personal data until every signal is green.
<CookieConsentBanner> reuses PrivacyPreferences to surface Do Not Sell, GPC detection, and the clear fallback path (reset + delete cookies). It also loads before any tracking scripts run.ActivityTrackingProvider now checks isDoNotSellOptedOut() before starting a session or saving to Firestore. The tracker itself rejects events if Do Not Sell is active.ExperimentProvider clears assignments, deletes local experiment storage, and keeps vendor SDKs from running when Do Not Sell is active.A GPC signal (`navigator.globalPrivacyControl === true`) is honored automatically through `honorGlobalPrivacyControl()` in `src/utils/do-not-sell.ts`. The banner prioritizes that signal, persists it via `localStorage` + secure cookie, and informs every downstream vendor.
Do Not Sell or Share My Personal Information
Applies to analytics, experiments, Firebase logging, vendor dashboards, and any downstream exports.
The vendors below receive personal information only after opt-in; Do Not Sell prevents the outbound flow entirely.
If any vendor cannot honor the opt-out, we keep the data minimised to the absolute minimum (hashed IPs, no identifiers) and document purpose & retention in our internal compliance logs.
Questions? Reach us at privacy@filmclusive.com or use the in-app privacy inbox to request log reports, deletion, or proof that opt-out was honored.
This page is updated whenever new scripts, vendors, or experiments are introduced. Check back before releasing new features so we can document the risk and enforcement point.