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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
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
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
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
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
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
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