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Settlement · 24 August 2022

People v. Sephora USA, Inc. (CCPA)

California Attorney General settlement, 24 August 2022 · California Attorney General

What it means for your code

Honour the Sec-GPC header / navigator.globalPrivacyControl and disclose third-party tracking as 'sale or sharing' in California.

What happened

Sephora let third-party trackers on its site collect shoppers' data in exchange for analytics and advertising benefits, did not disclose this as a sale, and ignored Global Privacy Control signals.

What was decided

Exchanging personal data with ad-tech vendors for services can be a 'sale' under the CCPA, requiring notice and a working opt-out, and Global Privacy Control must be honoured as an opt-out.

⚖ USD 1.2 million

The legal test applied

  • Exchanging personal data with third-party trackers for analytics or advertising benefits can be a 'sale' under the CCPA
  • Global Privacy Control signals must be honoured as opt-out requests

What would have changed the outcome

  • Vendors bound by CCPA-compliant service-provider contracts
Read the decision at the source

Summary and analysis by Lawpatch, checked by an editor against the source. Risk analysis, not legal advice; the law may have moved on since this decision.