Does the CCPA impose any additional obligations on companies that market to business contacts identified during conferences and trade shows?

Federal law sometimes requires that companies obtain consent prior to sending marketing communications to business contacts identified during conferences and trade shows.  In addition to any consent requirement required under federal law, the CCPA imposes the following additional requirements when information is collected from California residents: 1

Note that to the extent that the business contact or prospect is an “employee, owner, director, officer, or contractor” of a company, some of the requirements of the CCPA may be deferred until 2021.2 Whether the requirements are, or are not, deferred, however, may depend upon whether the marketing communication relates to “due diligence regarding,” or “providing or receiving a product or service.”  While the deferral should extend to marketing communications relating to future products or services, it is possible that a privacy advocate might argue that marketing is neither due diligence regarding, or the actual provision of, a product or service.