News & Analysis as of

Retailers California Consumer Privacy Act (CCPA)

Wiley Rein LLP

Wiley Consumer Protection Download (July 15, 2025)

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FTC Sends Warning Letters Regarding Potential Noncompliance With “Made in USA” Requirements. On July 8, the FTC sent letters to a flagpole retailer, footwear maker, football equipment company, and personal care products...more

Benesch

Updates on CIPA Reform: CA SB 690 Progresses to the Assembly Without Retroactivity Provision.

Benesch on

A national leader in privacy law, California was among the first states to include an express right to privacy in its constitution, create a data breach notification law, and codify robust consumer data protections. ...more

CDF Labor Law LLP

Todd Snyder Agrees to Pay $345,178 Fine to The CPPA and Other Equitable Relief

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Last month, the Enforcement Division of the California Privacy Protection Agency (“the Privacy Police”) and Todd Snyder, Inc. (“Snyder”) resolved the investigation into Snyder’s website’s opt-out methods from November 1, 2023...more

Venable LLP

Retailer Todd Snyder Fined for CCPA Violations Related to Opt-Out Compliance, Vendor Management, and Data Collection

Venable LLP on

Another month brings another California Privacy Protection Agency (CPPA) enforcement action, the agency's second enforcement action under the California Consumer Privacy Act (CCPA)....more

Robinson+Cole Data Privacy + Security Insider

Todd Snyder Fined for Technical CCPA Violations

The California Consumer Privacy Protection Agency (CPPA) Board issued a stipulated final order against Todd Snyder, Inc., a clothing retailer based in New York, requiring the company to pay a $345,178 fine and update its...more

Kelley Drye & Warren LLP

California Privacy Agency Continues Enforcement Spree with Todd Snyder Settlement

On May 6, the California Privacy Protection Agency (CPPA) announced a settlement with Todd Snyder, Inc. over allegations that the men’s retail brand violated CCPA rules on submission and fulfillment of privacy rights...more

Maynard Nexsen

CPPA Enforcement Action Against Retailer for Failing to Monitor Cookie Consent and Requiring Excessive Verification Information...

Maynard Nexsen on

On May 6, the California Privacy Protection Agency (CPPA) issued a decision requiring national clothing retailer Todd Snyder, Inc. to change its business practices and pay a $345,178 administrative fine....more

Clark Hill PLC

A view from California: Privacy Agency enforcement, CCPA rulemaking and CIPA reform

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There is never a boring moment in California privacy law, and these past weeks have been no exception. From major modifications to proposed California Consumer Protection Act (CCPA) rulemaking on automated decision-making...more

Baker Botts L.L.P.

California Privacy Protection Agency Enters Stipulated Final Order Regarding DSAR Process

Baker Botts L.L.P. on

On May 1, 2025, the California Privacy Protection Agency (CPPA) issued a Stipulated Final Order against Todd Snyder, Inc., (Snyder) a national retailer of men’s clothing and accessories, for multiple violations of the...more

Husch Blackwell LLP

CPPA Announces New CCPA Enforcement Action

Husch Blackwell LLP on

Keypoint: In its second non-data broker enforcement action for violations of the CCPA, the California Privacy Protection Agency entered into a stipulated final order with a retailer for a $345,178 administrative fine and...more

BakerHostetler

Privacy vs. Perks: Comparing the CCPA’s Notice of Financial Incentive and the Colorado Privacy Act’s Bona Fide Loyalty Program...

BakerHostetler on

What is loyalty? Ask a mob boss, a Los Angeles Lakers fan and a Labrador retriever, and you might get three different answers. Ask a retailer, and they’ll likely tell you that a loyalty program can be a great tool for...more

Perkins Coie

Coal in the Stocking for Retail Employers: The California Privacy Rights Act

Perkins Coie on

As the California Privacy Rights Act (CPRA) replaces its predecessor, the California Consumer Privacy Act (CCPA), on January 1, 2023, retailers face a significant amount of compliance preparation—and right at peak season. The...more

DarrowEverett LLP

Apply Foundation To Your Privacy Policy Before You Become The Next Sephora

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On August 24, 2022, the California Attorney General released a statement regarding a settlement agreement that the State of California reached with Sephora, Inc. (“Sephora”), the international consumer product retailer...more

Wyrick Robbins Yates & Ponton LLP

Glow Up or Blow Up: Five Takeaways from the CCPA Enforcement Action Against Sephora

As we discussed last year, the California Attorney General’s Office (“OAG”) has been wielding its enforcement authority under the California Consumer Privacy Act since the law became enforceable in July 2020.  But for two...more

Proskauer on Privacy

Message Sent! California Attorney General Announces $1.2 Million CCPA Settlement with Retailer and Its Focus on the Sale of...

Proskauer on Privacy on

On August 24, 2022, California Attorney General (AG) Rob Bonta announced a settlement with beauty products retailer, Sephora USA, Inc. (“Sephora”), resolving claims that Sephora violated the California Consumer Privacy Act...more

WilmerHale

CA AG Announces First Public CCPA Enforcement Decision

WilmerHale on

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

Robinson+Cole Data Privacy + Security Insider

Sephora Settles with California AG for CCPA Violations over Sale of Data

In the first of its kind under the California Consumer Privacy Act (CCPA), Sephora settled an enforcement action with the California Attorney General for violation of the CCPA. Sephora must pay $1.2 million in penalties and...more

BCLP

Are retailers offering access and deletion rights?

BCLP on

Yes. The vast majority of retailers are notifying Californians of their right to request access to, or the deletion of, their personal information....more

BCLP

Do retailers that sell personal information comply with the requirement to post a “Do Not Sell My Personal Information” link?

BCLP on

Yes. 99% of the retailers that state that they sell personal information are posting a “Do Not Sell My Personal Information” link on their homepage or in their privacy notices....more

BCLP

Has the retail industry adopted the “Do Not Sell My Personal Information” link?

BCLP on

Yes and no. While the majority of retailers include a “Do Not Sell My Personal Information” link on their homepage or in their privacy notice, 38.89% do not....more

BCLP

Do retailers that use third party behavioral advertising cookies deploy cookie notices?

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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

BCLP

Do most retailers take the position that the use of third party behavioral advertising cookies is, or is not, the “sale” of...

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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

BCLP

Have retailers disclosed whether they “sell” personal information?

BCLP on

Most have, but some have not. While the majority of retailers within the Fortune 500 affirmatively state that they do not sell personal information, a small minority have been silent, or unclear, about their selling...more

BCLP

What is the average size of a retailer’s California privacy notice?

BCLP on

4993 words (or 19 double spaced pages). In addition to their primary privacy policies, retail companies often post separate California-specific supplemental privacy notices or appendices that comply (or attempt to comply)...more

BCLP

Do most retailers use third party behavioral advertising cookies?

BCLP on

Yes. As the following chart indicates, there is a wide disparity between the quantity of third party behavioral advertising cookies used by retailers...more

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