Excited about your customer rewards program or sweepstakes promotion but not sure if there are CCPA ramifications for collecting data upon registration?
DPSA CAN HELP.
If you’re in-scope for CCPA and you run a membership, rewards, or loyalty program where customers are eligible to earn a financial incentive in return for sharing personal data during registration, you probably need a CCPA Financial Incentive Notice.
A CCPA Financial Incentive is a program, benefit, or even payment to individuals related to the collection, retention, or sale of personal information. It requires a Financial Incentive Notice that clearly explains the program’s terms, how to opt-out, and the value of the incentive as it relates to the value of the personal information.
To comply, you must understand the value of the personal information and show that the incentive or price/service difference is related to it.
DPSA can help you identify any Financial Incentive programs, help you calculate the value of the personal information and incentive, and prepare each of the Financial Incentive Notices.