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Duty to Delete Retailers

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Survey of the Retail Industry’s Privacy Practices - December 2019

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With the enactment of the European General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act ("CCPA”), retailers have been forced to cope with a shifting privacy landscape that impacts the data that...more

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CCPA Privacy FAQs: Is a business required to delete loyalty program information if it receives a deletion request from an inactive...

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Typically no. Loyalty programs are typically permitted to deny a deletion request from an active member as information that was collected about the member from third party sources is outside the scope of the deletion right...more

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CCPA Loyalty Club FAQ: Is a Retailer Required to Delete Information Concerning a Loyalty Member?

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Typically no. Loyalty programs can be, and are, structured in a variety of different ways.  Some programs track dollars spent by a consumer, others track products purchased.  Some programs are free to participate in,...more

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