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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
The use of online tracking technologies for online behavioral advertising, analytics and related activities has come under increasing scrutiny by regulators in the U.S., Europe and elsewhere. The obligations under various...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
Yes, provided that the “opt-out” selection is the default when the banner loads and no behavioural or analytics cookies load prior to an “opt-in” by the data subject. A data subject’s consent to the use of analytics or...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
Behavioral advertising refers to the use of information to predict the types of products or services of greatest interest to a particular consumer. Online behavioral advertising takes two forms. ...more