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?

Arguably no.

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.