Global Privacy Rules

While GDPR is widely considered the "gold standard" for privacy, it is not the only standard you need to worry about. Most countries have modeled their laws after GDPR, but there are significant outliers—most notably the United States and China.

If you have a global user base, you are navigating two conflicting philosophies:

• Opt-In (Europe, Brazil, China): You cannot take data unless the user explicitly says "Yes."
• Opt-Out (USA/California): You can generally take data until the user explicitly says "No."

Here is a breakdown of the major players and the specific rules that affect how you design your forms.

1. The Major Outlier: CCPA/CPRA (California, USA)

Philosophy: Opt-Out.
California sets the de facto standard for the US. Unlike GDPR, it generally allows data collection by default but demands strict transparency and an easy exit ramp.

Specific Requirements

1. "Do Not Sell or Share" Rule:
   If you use third-party analytics (like Google Analytics) or share form data with ad networks, California classifies this as "selling/sharing."
   • Requirement: You must include a link in your form footer titled: "Do Not Sell or Share My Personal Information."
2. Sensitive Data Limit:
   If you collect sensitive data (race, religion, geolocation, health, etc.), you may also need a link titled "Limit the Use of My Sensitive Personal Information."

Form Design Implication

• GDPR: Requires an unchecked box saying "I consent to marketing."
• CCPA: Theoretically allows a pre-checked box (though we recommend against it for global consistency), but mandates the specific footer links mentioned above.

2. The Strict Sovereign: PIPL (China)

Philosophy: Strict Opt-In & Localization.
China's Personal Information Protection Law (PIPL) is stricter than GDPR in specific areas, particularly regarding where data goes and how consents are bundled.

Specific Requirements

1. Separate Consent:
   GDPR often allows you to bundle related consents. PIPL frequently requires Separate Consent for high-risk actions. You cannot have one checkbox for "Terms, Privacy, and Overseas Transfer."
2. Cross-Border Transfer:
   If your Flux server is hosted outside of China (e.g., AWS US-East), you are transferring data "cross-border."
   • Requirement: You likely need a specific, separate checkbox: "I consent to my personal info being transferred overseas."
3. Data Localization:
   Strict rules apply to storing data inside China. If you collect large volumes of data, storing it solely on a foreign server may be non-compliant.

3. The "GDPR Cousins" (Brazil, Canada, UK)

These laws are 90% similar to GDPR but have unique "flavors" that affect your operations.

Brazil (LGPD)

• Key Difference: Speed.
• Implication: While GDPR gives you 30 days to respond to a "Data Access Request" (a user asking for their data), Brazil's LGPD requires a response within 15 days.
• Action: Ensure your Flux "Proof of Submission" logs are organized and easily searchable so you can react quickly.

Canada (PIPEDA / Bill C-27)

• Key Difference: Meaningful Consent.
• Implication: Canada is stricter about "Implied Consent." You cannot bury the purpose of the form inside a long legal text.
• Action: Your form submit button must be descriptive.
  • Bad: "Submit"
  • Good: "Register for Webinar" or "Sign Up for Newsletter"

Summary Comparison

The "Universal Safe" Strategy

To satisfy all regions without building five different forms:

1. Use GDPR Standards for Checkboxes: Always use unchecked, granular opt-ins. This satisfies GDPR, PIPL, and exceeds CCPA requirements.
2. Add CCPA Footer Links: Even if you are EU-based, adding the "Do Not Sell" link in the footer protects you against California audits.
3. Use Descriptive Buttons: Satisfies Canadian "Meaningful Consent."