San Diego Law Review

Library of Congress Authority File


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On January 28, 2022, the Office of the Attorney General of the State of California (OAG or the California Attorney General) put businesses operating loyalty programs on notice for violations of the California Privacy Protection Act (CCPA). Immediately following this press release, the California Attorney General sent a number of Notice of Violation letters to businesses, which alleged that if a business is offering “discounts, free items, or other rewards, in exchange for personal information[, it] must provide consumers with a notice of financial incentive.” These letters were sent to “major corporations in the retail, home improvement, travel, and food service industries.” The businesses were given thirty days to cure, which included not only providing notice to consumers that describe the material terms of the financial incentive program, but also included a good faith estimate of the value of the consumer data. As California Attorney General Rob Bonta stated in the press release, California “is committed to the robust enforcement of the nation’s toughest data privacy law” and businesses will need to assess how to calculate the value of the consumer data and whether and how this value should be disclosed to the public.

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