The proposal reflects an ambitious approach without parallel in US privacy law. These rules impose three overarching obligations: (1) make robust disclosures (pre and post use); (2) offer the ability to opt out; and (3) provide detailed information in response to queries from consumers (which is California Consumer Protection Act (CCPA) jargon for 'data subjects'). But fear not! These are not final rules. Formal rulemaking has not even started. The CPPA is sharing this early draft to facilitate internal and public discussion before beginning formal rulemaking—likely sometime this year. With final rules probably taking effect sometime in 2025. What are the top-line takeaways? The key points t