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Disclosure Requirements Customer-Loyalty Programs

McDermott Will & Emery

Colorado Attorney General’s Office Issues Draft Colorado Privacy Act Regulations

McDermott Will & Emery on

On September 30, 2022, the Colorado Attorney General’s Office (the AG’s Office) released draft regulations to the Colorado Privacy Act (the CPA). Before these proposed regulations take effect, however, there will be a lengthy...more

WilmerHale

CA AG Announces First Public CCPA Enforcement Decision

WilmerHale on

On August 24, 2022, California Attorney General Rob Bonta (“CA AG”) announced a $1.2 million settlement with Sephora, Inc. (“Sephora”), marking the first announced enforcement action under the California Consumer Privacy Act...more

King & Spalding

California Focuses on Business Loyalty Programs

King & Spalding on

On January 28, 2022, the California Attorney General (AG) sent out numerous notices alleging noncompliance with the California Consumer Privacy Act (CCPA) as part of an “investigative sweep” of covered businesses’ loyalty...more

BCLP

CCPA Privacy FAQs: If a business shares information through its loyalty program with a third party fulfillment company, is it...

BCLP on

Probably not. The CCPA broadly defines the term “sale” as including the act of “disclosing” or “making available” personal information “for monetary or other valuable consideration” from one business to another. The...more

BCLP

CCPA Privacy FAQs: Is a business required to post a “do not sell” link if it offers a loyalty program?

BCLP on

Not necessarily. California has two statutes that apply to the sale of information – The California Shine the Light Law and the California Consumer Protection Act. The California Shine the Light Law applies to companies...more

Holland & Knight LLP

California Consumer Privacy Act Update: Assembly Approves 12 Amendments - Changes Would Exclude Employees and Vehicle Information,...

Holland & Knight LLP on

• California's protracted legislative and regulatory process has complicated the landscape for businesses needing to implement the operational, technical and procedural changes required by the California Consumer Privacy Act....more

Ballard Spahr LLP

CFPB finalizes changes to the Prepaid Account Rule and further delays effective date

Ballard Spahr LLP on

On January 25, the CFPB finalized certain changes to the original Final Prepaid Rule (the “Rule”) proposed last summer. The amended Rule still contains onerous restrictions on credit features and complicated disclosure...more

Ballard Spahr LLP

CFPB proposes further changes to the Prepaid Account Rule in response to industry feedback

Ballard Spahr LLP on

As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and...more

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