Selling Online? Your Customers’ State Privacy Laws May Apply to You

When you run an online store—whether on Shopify, Etsy, WooCommerce, or through your own website—you’re not just selling in Texas anymore. You’re selling to anyone who can access your site. And that raises a big question:

Do the privacy laws of other states apply to your Texas business?

In some cases, yes.
In other cases, you’re exempt.
But in every case, the Texas Deceptive Trade Practices Act (DTPA) still requires transparency about what data you collect and how you use it.

Let’s break down what matters most for small business owners and online sellers.

Your Website Has No Geographic Boundary

Even if your physical business exists only in Texas, your online store is available nationwide. That means people from California, Colorado, Virginia, Connecticut, and other states with strict privacy laws may browse, purchase, or submit their information.

Some of these laws apply only to larger companies.
Others are stricter.
But nearly all of them expect clear disclosure, especially regarding:

  • What data you collect

  • Tracking and analytics

  • Targeted advertising

  • Third-party integrations

And even if another state’s law doesn’t apply to you, the lack of disclosure can still violate the Texas DTPA.

Which States Have Privacy Laws That Might Impact You?

Here’s a simple breakdown:

California (CCPA/CPRA)

Often does not apply to small businesses unless you hit:

  • $25M+ revenue

  • 100,000+ consumers

  • Or earn 50%+ from selling data

But California consumers expect strong privacy notices, and many platforms require them.

Colorado, Connecticut, Virginia, Utah, Oregon

Most small businesses do not meet their thresholds (e.g., 100,000+ consumers per year).

But these states still influence best practices for transparency.

Delaware (2025)

Lower thresholds that could affect smaller online sellers.

Texas (TDPSA, 2024)

Exempts many small businesses unless they sell sensitive data.

But this law doesn’t replace the DTPA—and the DTPA has no small business exemption.

Why the DTPA Still Matters (Even When Other States Don’t Apply)

The Texas Deceptive Trade Practices Act prohibits misleading or confusing statements. This includes privacy practices.

❗ If you fail to disclose how you collect or use personal information, a customer can argue they were misled — even if you violated no other privacy law.

Examples:

1. Not Disclosing Tracking/Analytics Tools

Online sellers commonly use:

  • Google Analytics

  • Meta Pixel

  • TikTok Pixel

  • Retargeting ads

These tools automatically collect customer behavior.

If your website does not tell visitors this is happening, that omission may be misleading under the DTPA.

2. Email Marketing Without Clear Disclosure

If someone signs up for a free download and ends up on a newsletter list without warning, that is a transparency problem.

3. Saying “We Don’t Share Data” When You Actually Do

Using Shopify, Etsy, Stripe, Square, PayPal, or Mailchimp means you are sharing data.

Even if it’s automatic, it must be disclosed.

Online Sellers Are at Highest Risk for Unintentional Non-Disclosure

E-commerce stores and digital product businesses collect more information than many owners realize:

  • Customer names

  • Addresses

  • Email addresses

  • Payment information

  • Shopping behavior

  • IP addresses

  • Browsing activity

  • Abandoned cart details

Not explaining these uses can violate the DTPA—even if you’re exempt from other states' laws.

What You Should Disclose as an Online Seller

Here are the essentials every Texas online business should explain:

✔ What information you collect

✔ How you use customer information

✔ Who receives customer data (third-party services)

✔ What tracking tools you use

✔ How customers can opt out of marketing

✔ How customers can contact you

This is not about heavy legal compliance—it’s about clarity and honesty.

Simple Checklist for Online Sellers

If you answer yes to ANY of these, you should have a privacy policy:

  • You sell products outside Texas

  • You collect emails

  • You use Google Analytics or Meta Pixel

  • You run ads on Meta or Google

  • You accept payments online

  • You use Shopify, Etsy, or Wix

  • You use a scheduling or CRM tool

  • You have contact forms on your website

Bottom Line

You may be exempt from complex privacy regulations—but you are never exempt from the Texas DTPA.

Having a privacy policy ensures transparency, prevents misunderstandings, and protects your business as it grows online.

Not sure what your online store should disclose? Schedule a meeting — we’ll walk through it together.

Legal Disclaimer: The information in this blog is provided for general educational purposes only and does not constitute legal advice. Laws and regulations change frequently, and the application of law depends on the specific facts of each situation. Reading this post does not create an attorney-client relationship with Fair Winds Law PLLC.

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Are You a Small Business? It Still Matters: Understanding Privacy Law Thresholds

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Do Texas Small Businesses Need a Privacy Policy? What You Really Need to Know