Do you agree with the following? Conclude "yes" or "no" and explain why. In your explanation, be sure to provide the rule and apply the law to the facts.

The CCPA/CPRA and the GDPR both arise out of concerns for individual privacy rights, as guaranteed in the California Constitution (Art. I 1) and in the EU Charter of Fundamental Rights (Art. 7 "right to private and family life" and Art. 8 "protection of personal data"). Among the most important similarities are the establishment of private rights for natural persons, which includes rights to access data collected (CCPA 1798.100; GDPR Art. 15) and have it deleted (or "erased") on request (CCPA 1798.105; GDPR Art. 17). Both require providing the "data subject" (to use the GDPR term from Chapter 3) with disclosure/notice (CCPA 1798.100; GDPR Art. 12 & 14). Both require the implementation of security around the personal data (CCPA 1798.81.5; GDPR Art. 32), and both allow for monetary damages as remedy for violations (CCPA 1798.150; GDPR Art. 79). Finally, the GDPR definition of "personal data," which includes all of "name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person" (Art. 4(1)), is also shared in the CCPA's definition of "personal information," which includes "[i]dentifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers (CCPA 1798.140(v)(1)(A)). There are some significant differences, however, beginning with the scope of the GDPR versus the scope of the CCPA: the GDPR is applicable to the processing of data of any natural EU person, "regardless of whether the processing takes place in the Union or not" (Art. 3), whereas the CCPA applies only to "businesses" (for "profit" only) as defined in CCPA 1798.140. Consent is also differently understood between each, with the GDPR requiring "consent" to be "freely given, specific, informed and unambiguous" (Art. 4(11)), whereas the CCPA merely requires an "opt out" (CCPA 1798.120). Finally, the most significant difference between the CCPA and the GDPR is in the seriousness of the financial penalties that may be assessed for violations. For the CCPA, the California AG may impose civil penalties of up to $2,500 per violation or $7,500 per intentional violation (1798.155), but the GDPR allows for "administrative fines up to 20,000,000, or in the case of an undertaking, up to 4% of the total worldwide annual turnover of the preceding financial year, whichever is higher" (Art. 83(6)). Based on these similarities and differences, the GDPR is stronger in consumer protection, and may be the more challenging for companies to implement.