Does the CCPA require that the benefits conferred by a loyalty program be “directly related” to the value of a consumer’s data to the business?

Bryan Cave Leighton Paisner
Contact

Arguably no.

The CCPA states that a business “may []offer” different prices or rates to consumers if those prices or rates are “directly related to the value provided to the business by the consumer’s data.”1 Interestingly, the CCPA does not prohibit a business from the opposite activity.  In other words, it does not state that a business is prohibited from offering different prices or rates if the benefits of a loyalty program are not directly related to the value provided to the business. 

For more information and resources about the CCPA visit http://www.CCPA-info.com.


This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes.  You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.

1. CCPA, Section 1798.125(b)(1).

[View source.]

Written by:

Bryan Cave Leighton Paisner
Contact
more
less

Bryan Cave Leighton Paisner on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.