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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
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Cannes Lions brought important conversations to the stage about advertising’s most important stakeholder: the public. Read more.
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Global Brands Join Forces at Cannes to Champion Responsible Influencer Marketing
Hannah E. Taylor is quoted in the Wine Industry Network article covering the panel discussion, "#Ad to Impact: Embracing Responsibility, Empowering Creativity, Expanding Influence," held during Cannes Lions. Read more.
June 25 2026
The State of Google Consent Mode
Daniel M. Goldberg is quoted in Privado AI’s report, “The State of Google Consent Mode,” which examines how Google Consent Mode is increasing compliance risk for the top 250 websites. Read more.
June 22 2026
