Legal Matters: Collecting Customer ZIP Codes? Beware the Legal Risks
Doing so might subject you to class-action lawsuits
The burden is on the retailer to demonstrate that it qualifies for the exemption. It should be quite easy for remote sellers to demonstrate that a ZIP code is necessary for delivery purposes. However, if a California resident makes a purchase but directs that delivery to another address as a gift, this exception may not apply. Likewise, if products are delivered electronically it may be difficult to demonstrate that collecting ZIP codes is necessary.
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