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Areas of Interest
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
Climate Diaries Cannes Lions 2026
Jeffrey A. Greenbaum is featured in the 51toCarbonZero article, Climate Diaries Cannes Lions 2026, which features eleven interviews with senior leaders from across the media and advertising industry conducted at the Cannes Lions International Festival of Creativity. Read more.
August 5 2026
‘I have been hunted down by HR reps, lawyers, and comms people:’ Developers discuss the pain and prevalence of side work clauses
Wendy Stryker was quoted in a Game Developer article discussing "side work clauses," also known as "moonlighting clauses," in video game industry employment contracts. Read more.
July 30 2026
Experts: Ending Adequate Provision Would Shut Down Prescription Drug Ads
Jeffrey A. Greenbaum was quoted in the Regulatory Affairs Professionals Society (RAPS) article, "Experts: Ending Adequate Provision Would Shut Down Prescription Drug Ads." The article discusses the FDA's proposal to eliminate the "adequate provision" requirement in direct-to-consumer (DTC) prescription drug advertising, a change that experts say could effectively result in a de facto ban on prescription drug advertisements. Read more.
July 21 2026
