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During this time of year our thoughts turn gratefully to our relationships and to all those who have helped enrich our lives personally and helped make our business progress and professional growth possible.  To all my family and friends, loved ones, colleagues, connections and contacts, the holidays and new year seem like perfect times for me to say ‘thank you’ and express appreciation to each of you.

There are so many things we can be thankful for and among them I count your friendship and support, as well as your contributions to my growth as a person and professional – in short, our relationship, whether near or far, close or casual, constant or sporadic.

In the year ahead, I look forward to being better at staying in touch with many of you whose time and schedules have not intersected with mine as often as I might like;  to facing challenges together and in the process, learning and growing; to listen more to those who mean well, to ignore those who don’t and to try and have the wisdom to know the difference.

Most of all to appreciate the countless blessings around us every day that we far too often take for granted. Thank you!

I wish each of you a new year filled with health, happiness and prosperity.

Best wishes,

Joe Rosenbaum

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Random Acts of Kindness

It was raining when a man driving down a rural road saw an old woman stranded up ahead. He slowed his car and noticed she was hunched over the back of her Mercedes. The car was slightly tilted and the woman looked troubled. He realized she probably had a flat tire and so the man decided to pull over and help.
The old woman, who was very wealthy and wary of strangers, was concerned about the man approaching her. Was he going to hurt her? Why would someone, a complete stranger, be so ready to come to her aid on a rainy, dreary day in the middle of nowhere? But she knew she couldn’t fix the flat tire by herself and was stranded, so having little choice she thought she would let him take a look at it.
“Please don’t worry ma’am, I’m here to help you,” the man said. “My name is Bryan Anderson and I live not too far from here” and before the elderly woman knew it, he was getting the spare tire from her trunk and switching it out in record time. The old lady thanked the man and offered to pay him. Of course, he never considered taking any money and instead simply smiled at her and said, “All I ask is that you just think of me the next time you see someone in need. Just remember me and pay the kindness forward.” The man waited only a brief moment to be sure she could start the car and then he was gone down the road. The old lady was so astounded and impressed with the man’s generosity she almost felt dizzy. She drove her Mercedes half a mile up the road, saw a diner and decided to stop and freshen up a bit having been out in the rain and perhaps grab something to eat before continuing onward.
As she entered, she was greeted by a lovely smiling face. The waitress welcomed her in and even offered her a towel to dry her hair, which had gotten wet from the rain. At that point, the old lady noticed the waitress seemed to be about eight months pregnant. Though she must have been tired and weary at the end of what must have been a very long day for her, the waitress looked to be the most pleasant person on Earth.
The old lady ordered a grilled cheese sandwich and some lemonade and as she sat at the counter, noticing the waitress smiling and helpful to everyone, she remembered what Bryan Anderson had said to her. She had previously thought perhaps to look him up and reward his kindness – he said he didn’t live far away, but then she had a better idea. So she got the check, paid it quietly and left. When the waitress went to retrieve the check, she saw a $100 bill. She looked everywhere for the old lady, sure that she had probably made a mistake – she was wet and tired. But the old lady was gone – she had already driven off.
As the waitress cleared the table she saw four more $100 bills inside the napkin and it was only then, when the waitress turned the napkin over, that she noticed a handwritten note scribbled on the back. It said simply, “I have been where you are and someone very kind once helped me the way I’m helping you now and he asked me to remember his kindness. So all I’m asking you is to also remember to pay the love forward.” The waitress’s head was spinning. With the baby coming next month, it would be a tight few weeks and the money would certainly help. She folded the bills, put them in her pocket, and finished her shift.
Hours later, the waitress finally made it home after her long day. She climbed into bed and told her husband, who was half asleep beside her, the story of this kind old lady. Thinking of how lucky they truly were, she leaned over and kissed his forehead, and said simply, “I love you, Bryan Anderson.”

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California Consumer Privacy Act (CCPA)

Although amended twice (September 13th and October 11th of 2018) after its initial passage by the California State Legislature and being signed into law by Governor Jerry Brown in June of 2018, the California Consumer Privacy Act (California Civil Code Section 1798.100) (“CCPA”) becomes effective with the new year (January 1, 2020).

Although it is intended to protect and afford California residents with certain rights (in some areas, greater or somewhat different than the European Union’s General Data Protection Directive 2016/679), it affects non-profit entities that do business in California, and that collect personal information of consumers and either has annual gross revenues over $25 million OR buys or sells personal data of 50,000 or more consumers/households OR earns over half its annual revenue from selling consumer personal information.

If your organization fits into any of those categories, you are required to establish, put into place and maintain reasonable security procedures and practices to protect consumer data and to afford California residents the right to know what personal data is being collected about them; to know whether and to whom the consumer’s personal data is sold or disclosed; to refuse to permit the sale of their personal data; to access their personal information; and to ask you to delete personal information collected from them.  The law also prohibits discrimination against any consumer for exercising any of their privacy rights under the CCPA.

While many business have been busily amending their agreements with suppliers, service providers and likely have been presented updated and revised contracts with “CCPA” amendments in order to ensure those in the chain of collection, storage, handling, distribution and use are in compliance, if you do any business in or with California residents, don’t forget to update your privacy policies and any terms of use that apply to your websites, e-commerce and online/mobile presence generally.  Those sites, even those that do not require any registration or input directly from consumers, almost certainly will be collecting information that is covered by the broad definition of “personal information” under the CCPA.

If you would like to know more about the CCPA or have any questions about this post, don’t hesitate to contact me Joe Rosenbaum, or any of the Rimon lawyers with whom you regularly work.