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ARTICLE · 11 MARCH 2024

California AG Announces Second CCPA Enforcement Action

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On February 21, the California Attorney General ("AG") announced a settlement with DoorDash, an online food delivery service, to resolve allegations that the company violated the California Consumer...

United StatesPrivacy
Kirk J. Nahra
Kirk J. Nahra
Ali A. Jessani
Ali A. Jessani
Samuel Kane
Samuel Kane
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On February 21, the California Attorney General ("AG") announced a settlement with DoorDash, an online food delivery service, to resolve allegations that the company violated the California Consumer Privacy Act (CCPA) and California Online Privacy Protection Act (CalOPPA) through its participation in a marketing cooperative. As part of its involvement in this arrangement, DoorDash provided consumer personal information to the cooperative in exchange for the ability to advertise to customers of other cooperative participants. The California AG alleged that this constituted a "sale" of personal information within the meaning of the CCPA, and that DoorDash failed to comply with the relevant legal requirements accompanying such sale (e.g., making appropriate privacy policy disclosures; posting a "Do Not Sell My Personal Information" link on its website and mobile app). The AG further alleged that DoorDash's failure to disclose this sharing of personal information in its

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