Do Your Loyalty Programs Run Afoul Of Calif. Privacy Law?

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By Sarah Bruno, Monique Bhargava and Karim Alhassan (February 25, 2022, 10:36 AM EST) — As California Attorney General Rob Bonta continues to bring enforcement actions under the California Consumer Privacy Act, covered entities should take note of a marketing practice often overlooked under the CCPA — loyalty programs.

On Jan. 28, Bonta’s office announced an investigative sweep of a number of businesses operating loyalty programs in California. Bonta’s office targeted companies in the retail, home improvement, travel and foodservice industries with these CCPA noncompliance notice letters.

The argument Bonta made was that these programs, when offered to California consumers, require more clear notices related to the data collection and use.

This announcement had a ripple…

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