> IANAL, but my understanding is that it's not even clear you can avoid the "don't sell my data" language in CCPA even if you don't sell/share/collect data.

This is how my company's counsel (and other attorneys with whom our counsel consults with) has read the CCPA. If you don't sell data you don't need to include language to opt out of data sales since you don't do it. If that changes you have to message customers of change and provide the button.