- 1798.100 – Consumers right to receive information on privacy practices and access information
- 1798.105 – Consumers right to deletion
- 1798.110 – Information required to be provided as part of an access request
- 1798.115 – Consumers right to receive information about onward disclosures
- 1798.120 – Consumer right to prohibit the sale of their information
- 1798.125 – Price discrimination based upon the exercise of the opt-out right
Does the CCPA require that the benefits conferred by a loyalty program be “directly related” to the value of a consumer’s data to the business?
The CCPA states that a business “may offer” different prices or rates to consumers if those prices or rates are “directly related to the value provided to the business by the consumer’s data.”1 Interestingly, the CCPA does not prohibit a business from the opposite activity. In other words, it does not state that a business is prohibited from offering different prices or rates if the benefits of a loyalty program are not directly related to the value provided to the business.