Sign Up for Alerts
Sign up to receive receive industry-specific emails from our legal team.
Sign Up for Alerts
We provide tailored, industry-specific legal updates to our clients and other friends of the firm.
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
AI Governance Strategies for Privacy Pros
Cybersecurity Law Report quotes Daniel M. Goldberg on the current AI legal landscape and how to practically approach AI governance. View Article
April 19 2024
Contradictory CIPA Rulings Leave Both Sides Saying They’re Right
Daily Journal quotes Jeremy S. Goldman on recent CIPA rulings in Los Angeles courts that reveal a conflicting landscape, where opposing interpretations have left both sides claiming legitimacy. View Article
April 8 2024
‘100%’ Sustainable Claims Pose Mounting Legal Risk for Companies
Bloomberg Law quotes Jeffrey A. Greenbaum on new lawsuits targeting bold marketing claims such as “100% sustainable” that could be misleading consumers. View Article
February 27 2024