The California Attorney General ('AG') announced, on 28 January 2022, the initiation of an investigative sweep of several businesses which operate loyalty programs in California and which received notices for their alleged non-compliance with the California Consumer Privacy Act of 2018 ('CCPA'). In particular, the AG stated that the CCPA requires businesses offering financial incentives in exchange for personal information to provide consumers with a notice of financial incentives, which must also 'clearly describe the material terms of the financial incentive program to the consumer before they opt into the program'. As such, the AG detailed that letters had been sent to companies in the various sectors, including retail, travel, and food services industries, providing for a 30-day cure period for violations of the CCPA.

You can read the press release here.