CCPA Regulations: Is A Loyalty Program A Financial Incentive?

Fox Rothschild LLP

Fox Rothschild LLP

When asked in comments to the California Consumer Privacy Act regulations whether a loyalty program constitutes a financial incentive under the act, the California Attorney General responded “maybe.”

  • A bill attempting to exempt loyalty programs from certain requirements related to financial incentive programs failed
  • CCPA does not define or exempt loyalty programs
  • Loyalty programs may be related to the value of the consumer’s data to the business.

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