Commenters on the final California Consumer Privacy Act (CCPA) regulations asked if a company gives you a product without charge but in consideration for your information,  could that still be deemed a financial incentive requiring the company to calculate and disclose the value of the consumer’s data?

The California Attorney General’s answer: Yes.

• If you offer a service or a product in exchange for data you are bound by the “financial incentive” and “price difference” requirements to the same extent as if you offer a product or service for cash payment.
• Non-monetary benefits or product or service differences related to the sale of personal information trigger notice requirements and may be deemed discriminatory.

This raises a discussion similar to that of cookie walls, and paid alternatives to cookies which have been discussed by various European Union supervisory authorities in the context of “freely given consent.”

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