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February 3rd, 2022
Daniel M. Goldberg Quoted in MediaPost on California Attorney General Warnings About Company Loyalty Programs
Privacy & Data Security Group Chair Daniel M. Goldberg was quoted in the article, “California AG Warns Companies Over Loyalty Programs” published by MediaPost. The article discusses the warning letters sent by California Attorney General Rob Bonta’s office to various companies for allegedly not complying with the California Consumer Privacy Act (CCPA). Daniel opined on whether company loyalty programs were “financial incentives” under the CCPA.
Daniel said the California law itself doesn't define “financial incentives,” and that privacy experts have debated whether loyalty programs are considered financial incentives. But the statement issued Friday indicates that the Attorney General's office believes loyalty programs meet the definition of financial incentives.
“They've made it very clear that they consider loyalty programs to trigger the financial incentive obligation.”
Daniel added that some companies don't want their loyalty programs treated as “financial incentives,” because they treat the value of customer data as proprietary information: “Many businesses have resisted classifying their loyalty programs as financial incentives on the basis that how they value their consumer data is a trade secret which they don’t want to publicly disclose.”
Read the article here.
Other Quoted
Pay Attention to the Delete Act (Even If You Don’t Think You’re A Data Broker)
AdExchanger quotes Daniel M. Goldberg in an article on California’s Delete Act, noting data brokers are required to register by January 31. He explains the definition of data broker extends to any company that collects and sells personal data about consumers, which includes companies using third-party data for targeted advertising. Mr Goldberg also anticipates more enforcement in 2025. View Article
January 21 2025
Understanding Interactive Entertainment
Games Industry Law Summit quotes S. Gregory Boyd and Sean F. Kane on two decades shaping video game law. The discussion covers key insights on industry evolution and emerging legal challenges. View Article
December 30 2024
Advertising Opt Outs Drive New Privacy Strategies in 2025
Cybersecurity Law Report quotes Daniel M. Goldberg in an article on how the advertising industry is facing greater scrutiny from state attorneys general as more people opt out of targeted ads. Speaking on a California Lawyers Association (CLA) panel, Mr. Goldberg noted how adtech is now a key focus for regulators. Due to the extensive marketing of many companies, privacy program leaders across industries must assess the impact of adtech on their companies and mititgate risks. View article (available through trial or paid subscription).
December 18 2024
