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Areas of Interest
February 17th, 2022
Calif. AG Sets Sights on Loyalty Programs’ Privacy Pitfalls
Privacy & Data Security Group Chair Daniel M. Goldberg was quoted in the article, “Calif. AG Sets Sights on Loyalty Programs' Privacy Pitfalls” published by Law360. The article discusses the pressure businesses are facing to comply with the California Consumer Privacy Act requirement that companies offering loyalty programs explain to consumers how they’re profiting from the personal data they collect. The state's attorney general recently sent warning letters to a number of major corporations that offer loyalty rewards, and is making the issue a priority. Daniel explained that the challenges for brands include the difficulty of valuing customer data in relation to the benefits the companies receive – for example, because the value of free hotel rooms or flights can fluctuate many companies “say we're not going to address it right now because we don't know how to address it, or we don't want to address it because that could disclose trade secrets that give our competitors an advantage."
Daniel added that: "What's interesting is that the notices didn't talk about deficiencies in the notice but rather a lack of notice completely, and that's low-hanging fruit that [a] regulator [can] walk into a store or go onto a website and check out." The takeaway? companies “need to understand that this is something the AG's office is looking at very closely, and it's no longer an issue that companies can avoid addressing."
Read the article here. (Behind paywall)
Other Quoted
CalPrivacy’s School Platform Action Highlights Opt-Outs, Protections for Vulnerable Users
Privacy Daily quotes Andrew Folks in the article, “CalPrivacy’s School Platform Action Highlights Opt-Outs, Protections for Vulnerable.” Read more.
March 10 2026
CalPrivacy Hits Ford for Opt-Out Friction in Connected Car Sweep Under CCPA
Privacy Daily recently quoted Andrew Folk’s blog post in the article “CalPrivacy Hits Ford for Opt-Out Friction in Connected Car Sweep Under CCPA.” Read more.
March 9 2026
California Disney Fine Pushes Companies to Fully Honor Opt-Outs
Bloomberg Law quoted Daniel M. Goldberg in their recent article about how California fined Disney $2.75 million for allegedly failing to fully honor consumers’ opt-out requests under the California Consumer Privacy Act, signaling increased scrutiny of how companies implement privacy rights across devices, services, and systems. The enforcement action underscores regulators’ growing expectation that opt-out mechanisms must work seamlessly and consistently, with technical compliance now under closer investigation. Read more.
February 25 2026
