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Rob Bonta, California Attorney General (California AG), January 27, 2023 announced retail, travel, and retail for not providing or accepting a mechanism for consumer opt-out requests to stop selling their data under the California Consumer Privacy Act (CCPA). A “scrub cleanup” of mobile apps in the foodservice industry is taking place.According to California AG Tweetthe mobile app has already received a letter of alleged violation.
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California AG expands its enforcement focus to mobile apps. In 2021 and 2022, California AG will review online retailers who have not honored or provided an opt-out request mechanism for using third-party online trackers without a contract with the appropriate service provider. We conducted a similar survey on This time around, California AG has signaled its focus on mobile apps “especially given the variety of sensitive information these apps can access from cell phones and other mobile devices.”
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Your 30-day treatment period has endedA series of investigations against the aforementioned online retailer resulted in only one settlement. Sephora — Other retailers who received letters of suspected violations have complied with their opt-out rights within the 30-day remediation period. This time around, however, his right to remediation expired on January 1, 2023, when the California Privacy Rights Act amendment to the CCPA went into effect, so this sweep could result in more enforcement action.
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Investigative sweep includes failure to ‘respect’ requests from consumer authorized distributorsThe CCPA allows consumers to submit verifiable requests through an authorized agent, a natural person or business entity registered to do business in California. Permission slip, app developed by consumer report, specifically under the CCPA, aims to streamline the process for consumers to submit privacy rights requests by acting as an authorized agent. California AG Continues to Support Self-Service Tools as Investigative Sweep Jan. 27 Announcement Highlights that Failure to Honor Opt-Out and Delete Requests from Permission Slips and Similar Tools Violates CCPA indicates that
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California AG urges the technology industry to develop and adopt user-facing global privacy controls for mobile devices.In its announcement, California AG also encouraged the technology industry to develop user-facing global privacy controls for mobile operating systems. However, to date, neither California AG nor the California Privacy Protection Agency (CPPA) have clarified how such controls should be implemented in the mobile environment. For example, despite public comments asking the CPPA to clarify its technical specifications for handling opt-out preference signals, a CPPA staff member said at his CPPA board meeting in October that the regulations would not include other technologies. I took the position that the specification is not necessary. Colorado AG publishes and updates a list of approved universal opt-out mechanisms, but California enforcement agencies have yet to make such a commitment.
California AG’s announcement should provide covered companies with an incentive to reassess and update their CCPA compliance programs with respect to opt-out and takedown requests. In particular, we encourage businesses to closely monitor industry standards and updates to self-service tools such as permission slips and global opt-out mechanisms such as: Global privacy controls, as evidenced by California AG’s continued support for respecting and developing such tools.
Wilson Sonsini Goodrich & Rosati routinely helps companies solve complex privacy and data security issues and oversees the Attorney General’s guidance, enforcement, and litigation in accordance with the CCPA to help clients comply. To do. For more information or advice on your CCPA compliance efforts, please contact us. Tracy Shapiro Eddie Holman Yeji Kim, or company member Privacy and cybersecurity training.
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