To the extent that a loyalty program collects personal information, it is required to provide a privacy notice consistent with the CCPA.
For more information and resources about the CCPA visit http://www.CCPA-info.com.
This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes. You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.
1. Cal. Civ. Code § 1798.100(b).
3. Cal. Civ. Code § 1798.130(a)(5)(A)-C).