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CCPA Enforcement Priorities Include Loyalty and Rewards Programs

The California Attorney General continues to bring enforcement actions relating to the California Consumer Privacy Act (CCPA). While advertisers and marketers have generally focused on CCPA compliance with respect to privacy practices, it is important to highlight a marketing practice that may be overlooked — loyalty and reward programs.

Loyalty and Reward ProgramsLoyalty and reward programs are generally optional programs whereby participants receive points, coupons, credits, rewards certificates or other benefits that can be redeemed for making purchases at a given company. They are often redeemed for merchandise, cash discounts or rewards certificates. A hallmark feature of these programs is that, in order to opt-into the program, a potential participant must provide personal information, such as full name, email and phone number. Read more…