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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
Don’t Let These Privacy Shifts Blindside You In 2026
AdExchanger quoted Holly Melton in an article examining the significant privacy and regulatory shifts expected to reshape the digital advertising landscape in 2026. Read more.
January 7 2026
FTC Weighs Petition to Revive ‘Click to Cancel’ Rule
Holly Melton was quoted in a Law.com in an article discussing the Federal Trade Commission's consideration of a petition to revive the "Click to Cancel" rule. Read more.
December 18 2025
Challenges in Opt-Out Design and Children’s Privacy Highlighted by Sling TV’s Settlement With California AG
Cybersecurity Law Report quoted Daniel Goldberg regarding California AG Rob Bonta's $530,000 settlement with Sling TV for CCPA violations related to opt-out processes and children's privacy protections. Read more.
December 1 2025
