An update on the most recent settlement with the Privacy Police. On October 30, 2025, streaming service Sling TV settled a California Consumer Privacy Act (CCPA) case for $530,000. The State claimed that the company failed to provide a simple method for consumers to opt out of the sale of personal information as required by the CCPA and by failing to provide sufficient privacy protections for children.
The settlement, pending court approval, requires Sling TV to implement changes to ensure the CCPA opt-out is easy for consumers to execute, involves minimal steps, and requires the company to provide parents with disclosures and the means to minimize the collection and use of their children’s data.
Sling TV had a link labeled “Your Privacy Choices,” which directed consumers to various cookie preferences instead of a simple “Do Not Sell My Personal Information” link. In order to opt out of the sale of personal information, Consumers had to locate and click an additional link that directed them to a web form which they could click through to complete their request. Even consumers who were logged in and had already provided their information were required to fill out a web form with their name, address, email, and phone number.
Sling TV did not provide any opt-out methods within its apps on various devices, and consumers were required to visit the website to opt out.
Regarding the privacy rights of children, Sling TV did not restrict the use of targeted advertising to children or require an affirmative opt-in when minors under the age of 16 were watching (or a parental “opt-in” for children under 13). Under the settlement, Sling TV is required to pay civil penalties and fix many of the issues listed above.
As CCPA enforcement continues to ramp up, businesses with websites, apps, or that otherwise collect consumer information online should carefully comply with CCPA opt-out requirements, as the civil penalties can be steep.
In order to remain compliant, businesses should consult with counsel about the need to implement the following:
- Maintaining an opt-out function on all websites or apps that is easy to locate and requires minimal steps to use.
- Not hiding the opt-out function behind other links and clearly labeling the opt-out function.
- Not requiring consumers to fill out information that is already available to the business.
- Provide parents with the ability to designate one or more user profiles as a “kid’s profile” that has default settings which automatically opt out of the sale and sharing of personal information and targeted advertising.
- Provide parents with disclosures and the means to protect their children’s privacy.
Now is a good time for businesses subject to the CCPA to consult with their favorite CDF Privacy Practice lawyer to review policies and practices to better ensure compliance and avoid future legal pitfalls.
