BakerHostetler Partner Paul Karlsgodt Discusses Privacy Class Actions
In April of this year, the California Privacy Protection Agency imposed a $632,500.00 monetary penalty on American Honda Motor Co. In our discussion of that action - Are Cookies Banners Crumbling? – we raised the alarm for...more
Three quarters of retailers that deploy a significant number of third party behavioral advertising cookies on their websites do not utilize a cookie notice. The 25% of retailers that do deploy a cookie notice are split in...more
Retailers are divided about whether the use of third party behavioral advertising cookies do, or do not, constitute the sale of personal information. One in four retailers (28%) utilize behavioral advertising cookies and take...more
Yes. As the following chart indicates, there is a wide disparity between the quantity of third party behavioral advertising cookies used by retailers...more
Approximately 69% of pharmaceutical companies that deploy a significant number of third party behavioral advertising cookies on their websites do not utilize a cookie notice. The 31% of pharmaceutical companies that do deploy...more
Yes. As the following chart indicates there is a wide disparity between the quantity of third party behavioral advertising cookies used by pharmaceutical companies within the Fortune 500...more
Approximately 78% of banks and financial institutions that deploy a significant number of third party behavioral advertising cookies on their websites do not utilize a cookie notice. The 22% of banks and financial...more
Yes. As the following chart indicates there is a wide disparity between the quantity of third party behavioral advertising cookies used by banks and financial service companies within the Fortune 500...more
Many companies participate in behavioral advertising networks. In order to participate in a network, a company places code on its website that permits a third party (the behavioral advertising network) to either (1) place...more
11.6% The term “cookie banner” refers to a banner or splash page deployed on a website to inform visitors that the website uses cookies. Most cookie banners fall within three categories...more
When the CCPA was enacted last year, BCLP published a Practical Guide to help companies reduce the requirements of the Act into practice. Following publication of the Guide, we wrote a series of articles that addressed...more
To help identify trends in privacy representations, BCLP reviewed the websites and privacy notices of Fortune 500 companies identified as primarily engaged in the banking and financial service sectors. The following...more
In order to help companies understand and benchmark industry practice, BCLP analyzed a random sample of the homepages of the Fortune 500 to better understand their use of cookies, cookie notices, and cookie banners. As of...more
No. The CCPA does not expressly require that a company obtain consent from a website user before placing cookies on their browser...more
Arguably no. While the definition of “sale” under the CCPA contains an exception for situations in which information is shared with a service provider, that exception may not apply to the extent that a behavioral...more
Generally speaking, cookies simply are data files saved to a user’s computer. Certain cookies may qualify as “personal information” under the CCPA, since the CCPA defines “unique personal identifiers,” to include “cookies”...more