News & Analysis as of

Customer-Loyalty Programs Notice Requirements

Fisher Phillips

Proposed New Jersey Regulations Would Require Major Privacy Compliance Shifts for Businesses

Fisher Phillips on

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

Foster Garvey PC

What Hospitality Businesses With a Loyalty Program Can Do Now to Stay Compliant With the California Consumer Privacy Act

Foster Garvey PC on

To celebrate Data Privacy Day, on January 28, California Attorney General Rob Bonta announced an investigative sweep of businesses offering loyalty programs in California. This should come as no surprise, as Attorney General...more

Fisher Phillips

4 Takeaways for Businesses as California AG Targets Loyalty Rewards Programs

Fisher Phillips on

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

BakerHostetler

California AG Focuses CCPA Enforcement on Loyalty Programs

BakerHostetler on

On Jan. 28, 2022, the California Attorney General Rob Bonta (AG) published a statement putting businesses that operate loyalty programs on notice that the California Consumer Privacy Act (CCPA) requirements for a Notice of...more

BCLP

If a business that operates a loyalty program provides a “notice of financial incentive,” is it required to disclose a numeric...

BCLP on

Not necessarily. If a loyalty program constitutes a “financial incentive,” the regulations implementing the CCPA require that a business provide a “notice of financial incentives” which, among other things, should include...more

Holland & Knight LLP

California Attorney General Releases Draft Regulations on the California Consumer Privacy Act: New Requirements Have Potentially...

Holland & Knight LLP on

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

BCLP

CCPA Privacy FAQs: Is a business required to provide a privacy notice in conjunction with a loyalty program?

BCLP on

Generally, yes. To the extent that a loyalty program collects personal information, it is required to provide a privacy notice consistent with the CCPA. One of the rights granted to individuals under the CCPA is the...more

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