In an age of real-time delivery apps, location-based advertising, and mobile workforce tracking, collecting geolocation data has become routine for many U.S. businesses. But if you’re serving California residents, this type of data isn’t just useful — it’s legally sensitive.
The California Privacy Rights Act (CPRA), California’s most advanced data privacy law, treats precise geolocation data as “sensitive personal information.” That means your business cannot collect, use, retain, or share it freely. There are specific legal rules you need to follow — and failing to do so could lead to fines, consumer complaints, and reputational damage.
This blog will help you understand:
- What counts as geolocation data under CPRA
- What the CPRA legally requires
- What risks your business could face
- How to stay compliant
- How Curated Privacy LLC can help
What Is Geolocation Data?
Geolocation data is information that identifies the physical location of an individual or their device. It can come from:
- GPS signals (e.g., from mobile apps)
- Wi-Fi or Bluetooth signals
- IP address estimates
- Cell tower triangulation
- Internet-connected vehicles or devices
Under CPRA, geolocation becomes “precise” when it identifies a location within a radius of 1,850 feet — accurate enough to locate someone’s home, work, or travel route.
Legal definition: California Civil Code §1798.140(v)(1)(L)
CPRA Requirements for Geolocation Data
The California Privacy Rights Act (CPRA), which expanded the California Consumer Privacy Act (CCPA), treats precise geolocation data as sensitive personal information. This comes with legal obligations that all covered businesses must follow.
Here’s what you must do if your business collects or uses precise geolocation data from California residents:
1. Disclose It Clearly
You must clearly inform users — through your privacy policy and data collection interfaces — that you collect geolocation data, why you collect it, how you use it, and who you may share it with.
Your privacy policy should include:
- A list of what data is collected
- The specific purpose for collection
- A description of consumer rights under CPRA
Learn more: California Privacy Protection Agency CPRA Fact Sheet
2. Provide a “Limit the Use” Option
If you collect sensitive personal information like precise geolocation, you must give consumers the right to limit its use and disclosure.
This means:
- Displaying a “Limit the Use of My Sensitive Personal Information” link or mechanism
- Honoring requests to stop using that data beyond essential services
You can only continue using geolocation data for purposes like:
- Providing requested goods or services
- Ensuring system or network security
- Preventing fraud or illegal activity
3. Limit Retention
CPRA requires that businesses do not retain personal data longer than necessary for the purpose it was collected. That applies directly to geolocation data.
This means:
- Setting a time limit or clear retention criteria
- Avoiding “indefinite” storage of location history
4. Secure It as Sensitive Information
As sensitive personal information, geolocation data requires strong access controls, encryption, and minimal sharing. It should not be stored or shared unless absolutely necessary and documented.
Why Geolocation Data Compliance Matters
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It’s Legally Required
Businesses that fail to meet CPRA obligations can face investigations and enforcement actions from the California Privacy Protection Agency (CPPA).
The CPPA has full authority to audit and fine businesses for violations, even if the data was collected through a third-party tool, plugin, or analytics platform.
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It Can Harm Your Reputation
Location data is personal. When customers discover that a business is tracking their movement — especially without clarity or control — it erodes trust. If mishandled, this can result in negative press and public backlash.
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It’s Often Collected Unintentionally
Many websites, mobile apps, and advertising platforms silently collect geolocation data through cookies, analytics tools, or SDKs. You’re still responsible, even if you didn’t intend to collect it.
How to Make Your Business Compliant
Here are five practical steps to align your practices with CPRA’s rules:
1. Conduct a Geolocation Data Audit
Review all platforms, apps, tools, and services your business uses to determine whether any of them collect geolocation data — directly or indirectly.
2. Update Your Privacy Notice
Make sure your privacy policy:
- Mentions geolocation data specifically
- States its purpose
- Lists any third parties involved
- Provides a link to limit use
3. Create a “Limit Use” Control
Add a clear mechanism to your website or app that lets California users restrict your use of their sensitive personal information.
4. Implement Data Retention Limits
Set defined retention timelines for geolocation data and delete it once it’s no longer necessary for the original purpose.
5. Train Your Teams and Vendors
Ensure employees, developers, and vendors understand your obligations around geolocation data. Update contracts to reflect data minimization and compliance terms.
How Curated Privacy LLC Can Help
Geolocation privacy is a growing compliance risk — especially in states like California, where laws are already active and enforcement is ramping up.
At Curated Privacy LLC, we help businesses:
- Audit and flag hidden geolocation data collection
- Draft compliant privacy policies
- Build “Limit the Use” mechanisms
- Secure data pipelines and storage
- Train internal teams and review vendor contracts
We offer free consultations to evaluate your current data practices and help you build a stronger, CPRA-aligned privacy program.
Visit www.curatedprivacy.com or email us at info@curatedprivacy.com to get started.
Final Thoughts
Geolocation data may feel like just another analytics tool — but California law sees it as highly sensitive. If you collect or process this data in any form, you must take action now to limit your legal exposure and protect your business reputation.
If you track where users go, make sure you’re also tracking your compliance.
