Rewards Programs and Co-Brand Relationships Between Credit Card Issuers and Merchants - The Consumer Finance Podcast
Do Gift Cards Keep on Giving How the Law Affects the Consumer, the Retailer and the State
New Jersey officials recently released proposed privacy regulations that would create several new compliance obligations for businesses above and beyond what existing state law and many other state laws require, meaning you...more
On June 2, the New Jersey Division of Consumer Affairs announced the publication of new proposed regulations to implement the New Jersey Data Privacy Act (NJDPA), N.J. Stat. §§ 56:8-166.4 et seq., which went into effect on...more
On January 16, Governor Murphy signed legislation requiring legal entities who collect consumer information to make certain disclosure to consumers. The law further requires that businesses provide consumers with an option to...more
Among the various requirements under US state comprehensive privacy laws, those that relate to loyalty programs may be some of the most confusing. Only three states — California, Colorado and Florida — regulate these...more
On March 15, 2023, the Colorado Attorney General’s Office announced the finalization of the Regulations implementing the Colorado Privacy Act (CPA), which will take effect on July 1, 2023. Covered businesses that make use of...more
On August 24, 2022, California Attorney General Rob Bonta (“CA AG”) announced a $1.2 million settlement with Sephora, Inc. (“Sephora”), marking the first announced enforcement action under the California Consumer Privacy Act...more
Since its enactment at the beginning of 2020, the California Consumer Privacy Act (CCPA) has garnered a significant amount of attention. The watershed legislation, which is intended to strengthen privacy rights in the state...more
On January 28, 2022, the California Attorney General (AG) announced an “investigative sweep” of businesses operating loyalty programs in the state, which it launched by sending multiple businesses notice of noncompliance with...more
The California Attorney General put loyalty rewards programs directly in his sights when he recently announced an “investigative sweep” of a number of businesses operating such programs in state. While it is lawful for...more
CYBERSECURITY - FBI Warns Olympics/Paralympics Participants of Cyber “Activities” - On January 31, 2022, the FBI issued a Private Industry Notification entitled “Potential for Malicious Cyber Activities to Disrupt the...more
Keypoint: With the CCPA’s “right to cure” violations expiring at the end of the year, businesses should take note of the AG’s recent enforcement efforts and, to the extent necessary, provide the requisite notice of financial...more
California Attorney General Rob Bonta is serious about compliance with the California Consumer Privacy Act (CCPA). So serious, that on January 28, 2022, also known as Data Privacy Day, he announced that his office was...more
Be part of this renowned event which shape the law, policy and proceedings of Canadian advertising and marketing law. Attend the Canadian Institute’s 27th Annual Virtual Conference on Advertising & Marketing Law to delve...more
Arguably no. The CCPA makes clear that a business can offer different prices or rates to consumers as part of a financial incentive program if those different prices or rates are “directly related to the value provided to...more
Loyalty programs are structured in a variety of different ways. Some programs track dollars spent by consumers, others track products purchased. Some programs are free to participate in, others require consumers to purchase...more
On March 11, the California Attorney General released revised draft regulations for the California Consumer Privacy Act (CCPA). This third version of the revised regulations is available here. The comment period for those...more
- The Washington state Senate has passed its version of a consumer data privacy bill as state lawmakers debate proposed legislation for the Washington Privacy Act, the state’s first data privacy law. - In their own bill,...more
Our holiday-abbreviated OTA & Travel Distribution Update is below. Happy Holidays....more
The California Attorney General Xavier Becerra on Oct. 10, 2019, released the proposed text for the California Consumer Privacy Act Regulations (Regulations). The Regulations are intended to guide businesses on CCPA...more
With the January 1, 2020 effective date of the California Consumer Privacy Act (the “CCPA”) rapidly approaching, all eyes have been on the California legislature’s consideration of a robust suite of amendments that would...more
Probably not. The CCPA broadly defines the term “sale” as including the act of “disclosing” or “making available” personal information “for monetary or other valuable consideration” from one business to another. The...more
No. The CCPA broadly defines the term “sale” as including the act of “disclosing” or “making available” personal information “for monetary or other valuable consideration” from one business to another. In the context of...more
Typically no. Loyalty programs are typically permitted to deny a deletion request from an active member as information that was collected about the member from third party sources is outside the scope of the deletion right...more
Typically no. Loyalty programs can be, and are, structured in a variety of different ways. Some programs track dollars spent by a consumer, others track products purchased. Some programs are free to participate in,...more